OFAC extends E.O. 13902 sanctions authority to Iran's digital-asset sector

On 24 August 2026 OFAC issued a determination under section 1(a)(i) of Executive Order 13902 applying the order to five sectors of the Iranian economy: aviation, digital assets, gold, shipping and technology. The one-page instrument, signed by OFAC director Bradley T. Smith and effective the same day, names the sectors and states that any person determined to operate in them is subject to sanctions. It defines none of them and carves out nothing. Treasury announced it inside "Operation Economic Outcast," the same action under which OFAC designated nearly 60 entities, individuals and vessels — but the determination is a separate, prospective instrument, not a designation.

For the digital-asset sector the change is structural rather than incremental. Treasury's release states that OFAC "can now sanction any person, regardless of where they are located, that operates in" the sector, and frames the reach as covering those "operating in or providing services in support of" it — though the determination's own text says only "operate in." The effect it describes is an inversion of how sanctions exposure is assessed: for a crypto exchange, custodian, OTC desk or stablecoin issuer with any Iran nexus, the question stops being whether a counterparty is on the SDN List and becomes whether the activity itself falls inside a named sector. What that sector includes OFAC has not defined; its implementing regulations at 31 CFR part 560 and any later guidance will delimit it.

No one has yet been designated under the digital-asset determination, and how OFAC will apply it is the open question. The crypto-linked names in the same action were reached by pre-existing authorities, not the new one: the broker OFAC describes as having processed over $100 million in cryptocurrency payments for the IRGC-QF since 2023, Ivan Obukhov, was designated under the counterterrorism order E.O. 13224; the Hong Kong "shadow banking" payment fronts Feili, Minvur, Feisu and Guska under the pre-existing financial-sector determination; and the Iranian cyber actors carrying crypto wallets under the cyber order E.O. 13694. Treasury calls the five-sector package "unprecedented." Whether the digital-asset determination shifts enforcement in practice, or mainly enlarges the authority OFAC can invoke later, is not yet established.