OFAC designates VTB Bank under Iran authority; issues Venezuela GL 52C and FAQ 1245

What's on the official record

On 14 September 2026, OFAC published an Iran-related designation and two Venezuela-related actions on its Recent Actions page.

14 September — Iran-related designation of VTB Bank. OFAC updated the Specially Designated Nationals and Blocked Persons List and the Sectoral Sanctions Identifications List to add VTB BANK PUBLIC JOINT STOCK COMPANY under the [IRAN-EO13902] program tag. The updated entry adds a Tehran, Iran address and an "Additional Sanctions Information - Subject to Secondary Sanctions" tag. The page cites no Executive Order for this action. The action appears at https://ofac.treasury.gov/recent-actions/20260914.

14 September — Venezuela-related General License 52C. OFAC issued Venezuela-related General License 52C, "Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A." The page cites no Executive Order for this action. The action appears at https://ofac.treasury.gov/recent-actions/20260914.

14 September — Amended Venezuela-related FAQ 1245. OFAC issued one amended Venezuela-related Frequently Asked Question, FAQ 1245 (/faqs/1245).

Assessment

For a sanctions or trade-finance committee, the record lets you check whether any payment, correspondent, or counterparty matches VTB BANK PUBLIC JOINT STOCK COMPANY, which now carries the [IRAN-EO13902] program tag, a Tehran, Iran address, and a secondary-sanctions tag on both the SDN List and the SSI List. The record also lets you check whether Venezuela-related General License 52C or amended FAQ 1245 changes the scope of authorized transactions involving Petróleos de Venezuela, S.A. Hold or enhance diligence on any exposure that matches these entries.

For an owner or operating executive, the record lets you check whether your entity or any counterparty appears in the updated SDN List or SSI List entries for VTB Bank, and whether your Venezuela-related activity falls within General License 52C as amended by FAQ 1245. Fix any exposure before a buyer or lender checks, because the record adds an Iran authority and a secondary-sanctions tag to the VTB Bank entry.

What would change this call

The call holds unless OFAC issues a further amendment to General License 52C or FAQ 1245, or further updates the VTB Bank SDN and SSI entries. A new OFAC action on the same entities or programs would change the diligence posture.

What to check next

Check	Why	Where
VTB Bank SDN and SSI entries	Confirm the [IRAN-EO13902] tag, Tehran address, and secondary-sanctions tag	https://ofac.treasury.gov/recent-actions/20260914
General License 52C	Confirm authorized transactions involving Petróleos de Venezuela, S.A.	https://ofac.treasury.gov/recent-actions/20260914
FAQ 1245	Confirm the amended Venezuela-related guidance	https://ofac.treasury.gov/faqs/1245

Confidence

Filed 25 October 2026 from the record dated 14 September 2026.

The note reports only what OFAC published on the 14 September 2026 Recent Actions page.

Sources

[1] OFAC Recent Actions, "Iran-related Designation; Issuance of Amended Venezuela-related General License and Frequently Asked Question", 14 September 2026, https://ofac.treasury.gov/recent-actions/20260914

[2] OFAC FAQ 1245, https://ofac.treasury.gov/faqs/1245