Weekly Trade Update: August 24-28, 2026

OFAC Makes Iran-related Updates to SDN List

The Office of Foreign Assets Control (“OFAC”) took additional actions as part of “Operation Economic Outcast”, the Administration’s sanctions campaign against Iran.  OFAC announced the addition of an Iranian national (Reza Mohammad Taeedi) and a Hong Kong based company (Kameng Trading Limited) to the Specifically Designated Nationals and Blocked Persons List (“SDN List”).  A press release issued by the Department of Treasury (“Treasury”) explained that the additions to the SDN List target Iran’s access to financial institutions that have assisted the Iranian government in laundering funds. 

OFAC Issues Amended Venezuela-related General Licenses

OFAC continues to expand the scope of authorized transactions involving the Government of Venezuela and state-owned companies in the oil and gas, petrochemicals, mining, and telecommunications industries.  On August 27, 2026, OFAC issued 8 amended Venezuela-related general licenses:

• General License No. 46D authorizes transactions that are related to refining and exporting Venezuelan-origin oil and petrochemicals for importation into the United States

• General License No. 47B authorizes the sale or U.S. origin diluents to Venezuela

• General License No. 48C authorizes transactions that provide goods or services for oil, gas, and petrochemicals exploration, development, or production as well as electricity distribution

• General License No. 50C authorizes transactions related to the oil or gas sector operations of several companies operating in Venezuela

• General License No. 51C authorizes transactions that provide goods or services related to exporting Venezuelan-origin minerals

• General License No. 52B authorizes transactions involving Petróleos de Venezuela, S.A.

• General License No. 54B authorizes transactions that provide goods or services for mining operations in Venezuela

• General License No. 61A authorizes transactions that provide goods or services for operational support of telecommunications in Venezuela

CBP Issues Update On IEEPA Refunds To The CIT

On August 25, 2026, U.S. Customs and Border Protection (“CBP”) provided an update to Judge Eaton on the ongoing status of IEEPA refunds administered through the Consolidated Administration and Processing of Entries (“CAPE”) system.  Executive Director of the Trade Programs Directorate, Brandon Lord stated that as of August 21, 2026, almost 200,000 declarations have passed validation, covering 26.4 million entries, and approximately $106.6 billion of refunds have been sent to the Treasury for disbursement.  He cautioned that many declarations have failed to pass validation because filers are submitting mismatching importer of record numbers, incorrect entry numbers, or non-aligning refund templates.  He also informed Judge Eaton that $1.7 billion has not been transmitted to Treasury because Automated Clearing House account information has not been provided. 

Executive Director Lord also stated that CAPE Phase 3 has been temporarily delayed so that CBP can “build new validations that ensure no other duty adjustments are made to finally liquidated entries outside of the IEEPA duty refunds.”  He noted, however, that “{e}xisting CAPE functionality for Phases 1 and 2 remains fully operational and is not affected by” the temporary delay to Phase 3. 

Judge Eaton ordered CBP to provide another report on the progress of the CAPE system on September 15, 2026, and scheduled a closed conference to be held the following day.