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Sanction

Sanctions Update No. 35

16 Sept 20261 min read

Click the 'View PDF' option above to read the full Update

The United States has recently launched ‘Operation Economic Outcast’, described by the US Department of Treasury as an economic campaign against Iran and its enablers. This Update covers various actions by the US Department of Treasury’s Office of Foreign Assets Control under Operation Economic Outcast up until 14 September 2026.

Elaborately discussing various sanctions, the Update also provides relevant comments by the LKS International Trade Team. According to the Team, these actions indicate a clear willingness by the US to target not only Iranian parties, but also third-country individuals, businesses and financial institutions that facilitate Iran-related activities.

The Team also points out that businesses should be particularly mindful of indirect dealings involving sanctioned parties, including through service providers, intermediaries, ownership structures, or supply-chain relationships and should strengthen due diligence processes while treating counterparty screening, ownership analysis, and sectoral exposure assessments as essential components of sanctions compliance.

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