The US Treasury has added Iran’s digital asset sector to the areas of the Iranian economy covered by a new sanctions determination, widening the range of foreign parties that the Office of Foreign Assets Control can target.
OFAC said the determination, issued under Executive Order 13902 on August 24, allows it to sanction people and companies operating in or providing services in support of Iran’s digital asset sector, regardless of where they are located. The measure does not automatically designate every participant in the sector; it creates authority for OFAC to make sanctions determinations against particular parties.
Digital assets were one of five sectors included in the action, alongside technology, gold, aviation and shipping. Treasury alleged that the Iranian government increasingly uses cryptocurrency for sanctions evasion and for transactions linked to the Islamic Revolutionary Guard Corps and government insiders.
A broader screening perimeter
For exchanges, custodians, stablecoin issuers, wallet providers and payment processors, the operational significance lies in the wider basis for future designations. A compliance program focused only on names already on sanctions lists may not capture exposure created by counterparties that provide services to a covered Iranian sector.
That does not mean providers should treat all Iranian-linked digital asset activity as identical. The determination is an authority for targeted action, while separate OFAC rules, licenses and exemptions govern what is prohibited or permitted. Firms still need to identify the parties, ownership, geography and transaction purpose involved in a payment before deciding how US sanctions apply.
The announcement also increases the importance of ownership screening. Treasury said property of designated or blocked people in the United States, or controlled by US persons, must be blocked and reported. Entities owned 50% or more, directly or indirectly and in aggregate, by blocked persons are also blocked under OFAC’s rules.
Oil-linked crypto allegation accompanies the policy change
Alongside the sectoral determinations, OFAC designated nearly 60 entities, individuals and vessels across several networks. Treasury alleged that UAE-based Ukrainian broker Ivan Obukhov processed more than $100 million in cryptocurrency payments since 2023 to facilitate Iranian oil sales for the IRGC-Quds Force.
OFAC designated Obukhov under Executive Order 13224 for allegedly assisting or supporting the IRGC-Quds Force. It also designated Foscom FZE, a UAE company that Treasury said Obukhov owns and manages. The amount is a US government allegation tied to the sanctions action, not an independently audited measure of crypto payment volume.
The designations and the digital asset sector determination are related parts of the same enforcement campaign but perform different legal functions. Obukhov and Foscom are named targets whose property interests are subject to blocking rules. The sectoral determination provides a basis for possible future sanctions against other foreign parties found to operate in or support the covered sector.
What payment firms should review
Crypto payment companies may need to revisit customer and counterparty risk models that depend heavily on wallet-address screening. Treasury’s account describes a broker, a corporate entity, oil shipments and cryptocurrency payments spanning multiple jurisdictions. That combination illustrates why blockchain analytics alone may not resolve sanctions exposure when corporate ownership, trade activity and beneficial control sit outside the transaction record.
Providers should also distinguish a technical touchpoint from a sanctions conclusion. A wallet’s indirect connection to an Iranian service can be a risk signal, but the legal assessment may depend on the named parties, ownership chain, services provided and any applicable authorization. Escalation and recordkeeping controls are therefore as important as automated alerts.
Treasury said US sanctions violations can carry civil or criminal penalties and that OFAC may impose civil penalties on a strict-liability basis. It also warned that financial institutions and other parties may face sanctions exposure for certain dealings with designated or blocked persons, including potential secondary-sanctions risk for foreign financial institutions involved in specified transactions.
The immediate takeaway for the payments industry is not that every Iran-related crypto transfer has the same status. It is that OFAC now has an explicit sector-based route to designate foreign digital asset businesses and service providers, making entity resolution, ownership data and transaction context more consequential in sanctions controls.