Secondary OFAC Sanctions Pose Growing Risks for Non-US Firms

New enforcement reveals increased secondary OFAC sanctions risks for non-US companies.

On August 24, 2026, U.S. Treasury Secretary Scott Bessent announced Operation Economic Outcast, a new wave of sanctions aimed at crippling Iran’s economy through secondary sanctions on companies engaged in economic activities with Iran. Bessent underscored the Treasury's goal to "shut down the financial infrastructure" supporting Iran’s threats to U.S. national security and global shipping.

Following this, on September 29, 2026, the U.S. Treasury Department sanctioned ten individuals and entities from Iran, Hong Kong, and Pakistan for facilitating Iran’s military supply chain, marking an aggressive escalation in targeting entities beyond the U.S. border (AP News).

In total, 2026 saw six OFAC civil penalties and settlements amounting to $282.7 million, a 6% increase from 2025's $265.7 million total enforcement. The largest penalty was a $275 million fine against Adani Enterprises Limited for Iran-related sanctions violations. This highlights the substantial financial risk non-U.S. companies face when violating secondary sanctions.

OFAC’s enforcement focus extends beyond major corporations to smaller companies, including fintech firms and payment processors, with fines commonly reaching six figures (OFAC Enforcement Trends 2025). Non-bank "gatekeepers," such as private equity and real estate firms managing assets linked to sanctioned Russian oligarchs, were similarly targeted in 2025 (Sidley Analysis).

OFAC emphasizes that compliance requires companies to consider the practical and economic realities underlying transactions, not just their legal formality. This advisory underscores the heightened scrutiny facing non-U.S. entities to globally enforce U.S. sanctions policies.

What's next: Companies should monitor evolving OFAC enforcement as Treasury likely continues expanding secondary sanctions and targeting facilitation networks.