Iran-related and counter-terrorism designations; licensing policy update; settlement

What's on the official record

10 September — Iran-related licensing policy update under Operation Economic Outcast. OFAC stated it modified its Iran-related specific licensing policy, effective immediately, to consider Iran-related specific license applications with a presumption of denial except as required by law or in certain circumstances such as risk to life, limb, or environmental safety. The page cites no Executive Order for this action.

10 September — Iran sanctions enforcement settlement. OFAC announced that an individual agreed to pay $1,427,230 to settle potential civil liability for providing management consulting and advisory services to one of Iran's leading software solutions companies, receiving Iranian-origin dividends to U.S. bank accounts, and acquiring real property in Iran. OFAC stated the apparent violations were egregious and not voluntarily self-disclosed and that the matter was resolved in cooperation with the Federal Bureau of Investigation, Los Angeles Field Office, Orange County Resident Agency. The page cites no Executive Order for this action.

10 September — SDN List additions. OFAC added 14 individuals and 5 entities to the Specially Designated Nationals and Blocked Persons List. The recent-actions path for all of the following is https://ofac.treasury.gov/recent-actions/20260910.

Counter-terrorism (SDGT) additions, cited under section 1(b) of Executive Order 13224, as amended by Executive Order 13886:

AL ABADA, Khaldoon Naser Maryoosh (Iraq; Linked To: Ain Al Iraq For Protection Systems Technology And Audio, Visual, And Communications Solutions Company Ltd)
AL AMERI, Abdullah Nadhim Luaibi (Iraq)
AL-DHUHAIBAWI, Hussein Ahmed Hussein (Iraq; Linked To: Kata'ib Hizballah)
AL-HRAISHAWI, Karrar Mohammed Qasim (Iraq; Linked To: Kata'ib Hizballah)
AL-LAMI, Ali Hasan Farhan (Iraq; Linked To: Kata'ib Hizballah)
AL-MAKANSI, Amir (Turkey; Syria)
AL-SHAIKHLI, Mohamed Ameen Fadhil Ali (Iraq; Linked To: Kata'ib Hizballah)
AL-TAMEEMI, Abbas Jawad Kadhim (Iraq)
HAMIEH, Abdallah (Lebanon; Linked To: Hizballah)
IBRAHIM, Hussein (Lebanon; Linked To: Hizballah)
WEHBE, Ghaith Hussein (Lebanon; Linked To: Hizballah)
ZAHRELDINE, Mervat Jamil (Lebanon)

Iran-related additions, tagged [IRAN-EO13902] under Executive Order 13902:

AL-MANDALAWI, Abdulhasan Ali Akbar Namdar (Dubai, United Arab Emirates; Linked To: Shams And Bahr Trading Company L.L.C.)
AL-MANDALAWI, Majid Ali Akbar Namdar (Dubai, United Arab Emirates; Linked To: Shams And Bahr Trading Company L.L.C.)

Entities added to the SDN List:

AIN AL IRAQ FOR PROTECTION SYSTEMS TECHNOLOGY AND AUDIO, VISUAL, AND COMMUNICATIONS SOLUTIONS COMPANY LTD (Baghdad, Iraq) [SDGT] — section 1(b) of Executive Order 13224, as amended by Executive Order 13886
AL BROUJ FOR GENERAL CONTRACTING COMPANY (Baghdad, Iraq) [SDGT]
GOLD PRO SARL (Beirut, Lebanon) [SDGT]
SHAMS AND BAHR TRADING COMPANY L.L.C. (Dubai, United Arab Emirates) [IRAN-EO13902]
YOUSEF IBRAHIM MANSOUR AND PARTNER FOR EXCHANGE (Lebanon) [SDGT]

The page lists no unrelated administrative list changes.

Assessment

For a sanctions or trade-finance committee, the record gives a dated list of 14 individuals and 5 entities OFAC added to the SDN List across Iraq, Lebanon, Syria, Turkey, and the United Arab Emirates, each with the Executive Order OFAC cited. The committee can screen the named individuals and entities against account, transaction, and counterparty records and enhance diligence on the Lebanon-, Iraq-, and Dubai-linked names. The same page changes the Iran-related specific licensing posture to a presumption of denial except as required by law or in certain circumstances such as risk to life, limb, or environmental safety, which the committee can use to hold license-reliant flows pending review.

For an owner or operating executive, the record names a Dubai-registered network that includes Shams And Bahr Trading Company L.L.C. and a Lebanon-based exchange house, alongside individuals OFAC added under Iran-related and counter-terrorism authority. The executive can check the page's names and registration data against suppliers, intermediaries, and counterparties to decide whether to delay or fix a relationship before a buyer or lender checks. The effective-immediately licensing change is a separate cue to review any Iran-related specific license the business holds or is seeking.

What would change this call

A later OFAC list action, license modification, or amended FAQ naming different entities would change this reading. New identifiers linking the named Dubai entities to additional counterparties would expand the diligence scope. A removal-petition outcome for any named individual would narrow it.

What to check next

Check	Where
Screen the 14 named individuals and 5 named entities against account, transaction, and counterparty records	https://ofac.treasury.gov/recent-actions/20260910
Apply the modified Iran-related specific licensing posture (presumption of denial) to any pending or planned specific license request	https://ofac.treasury.gov/recent-actions/20260910
Confirm the named enforcement individual, the $1,427,230 amount, and the egregious-and-not-voluntarily-self-disclosed finding	https://ofac.treasury.gov/recent-actions/20260910

Confidence

Confidence in the official record is high: every name, amount, program label, and Executive Order citation above is drawn verbatim from the single OFAC recent-actions page dated 10 September 2026. Filed 25 October 2026 from the record dated 10 September 2026.

Sources

[1] OFAC Recent Actions, "Iran-related and Counter Terrorism Designations; Licensing Policy Update under Operation Economic Outcast; Settlement Agreement between OFAC and an Individual", 10 September 2026 — https://ofac.treasury.gov/recent-actions/20260910