Part 1 of this deep dive covered the two developments inside Operation Economic Outcast that hit compliance functions first: the sectoral expansion of Executive Order 13902 into aviation, digital assets, gold, shipping, and technology, and the sweeping suspension of general licenses that had authorized narrow, often noncommercial Iran-related activity. Part 2 turns to the other half of the campaign, and arguably the part that shows Treasury’s strategy most clearly: new guidance on Strait of Hormuz transit risk that breaks from how sanctions exposure normally works, and an escalating, coordinated set of actions against the specific banks that have kept Iran connected to the global financial system.

The Strait of Hormuz: A Genuinely Different Kind of Risk

Roughly a fifth of the world’s oil and a substantial share of global LNG moves through the Strait of Hormuz, and Iran has spent the past several months building what amounts to a toll-and-clearance regime for vessels transiting it, administered through a network of entities OFAC has been designating over recent months. In connection with Operation Economic Outcast, OFAC issued updated guidance on this regime that maritime, shipping, and marine insurance compliance teams need to internalize carefully, because it departs from the framework most sanctions professionals are used to.

Ordinarily, sanctions risk analysis starts with a transaction: did money, goods, or services change hands with a designated party. The Hormuz guidance breaks that assumption. OFAC has made clear that sanctions exposure can arise from engagement with these designated toll-collecting entities even where no payment or exchange of value actually occurs. Simply interacting with a designated entity, accepting insurance or other services connected to it, or responding to its demands for safe-passage information or guarantees, can itself create exposure. This is risk triggered by the interaction itself, not by a completed financial transaction.

Compounding this, OFAC flagged that the regime’s toll structure doesn’t rely exclusively on conventional payment rails that would be easy to screen for. Tolls may be extracted through digital asset transfers, informal barter or swap arrangements, government-to-government accommodations, or payments disguised as charitable donations routed through specific organizations. Each of those channels is specifically designed to be harder to catch through standard transaction-monitoring screens built around wire transfers and correspondent banking.

Given all of this, OFAC’s guidance directs maritime service providers, shipowners, charterers, and marine insurers to build a specific, affirmative question into standard voyage due diligence: did this vessel, or any party connected to this voyage, pay a safe-passage fee to Iran, or accept any service from an Iranian-connected entity in connection with Hormuz transit. That’s a meaningfully different due diligence posture than most maritime compliance programs have historically maintained, and it needs to be built into pre-fixture and post-fixture questionnaires now, not treated as an occasional spot-check.

Squeezing the Banks: Three Actions, One Strategy

The most aggressive dimension of Operation Economic Outcast has been Treasury’s direct campaign against the specific financial institutions that have functioned as Iran’s remaining access points to the global financial system. Three actions in particular illustrate both the breadth of the strategy and its increasing willingness to reach into major, systemically significant institutions.

FinCEN issued a proposed rule identifying a UAE-based bank as a financial institution of primary money laundering concern under Section 311 authority, citing an estimated $1.8 billion processed on behalf of more than a hundred companies with potential ties to Iranian shadow banking networks. This is a targeted, evidence-based finding rather than a blanket regional action, and once finalized it will functionally sever the bank’s access to U.S. correspondent banking. For any institution maintaining relationships with UAE-based banks handling Iran-adjacent trade finance, this is the clearest possible signal that Treasury is willing to use Section 311 authority against individual institutions with real, ongoing transaction volume, not just shell entities.

Separately, OFAC designated a Turkish bank for allegedly transferring funds from China to Turkey for the benefit of the IRGC, tied to Iranian oil sales. The sanctions took effect immediately upon announcement, with no wind-down period, and Turkey’s own banking regulator subsequently stepped in and took control of the institution. The speed of the regulatory response, a foreign government effectively confirming Treasury’s underlying findings by seizing control of the bank itself, is notable and suggests foreign regulators are increasingly unwilling to contest OFAC’s factual findings in these cases.

The most significant of the three actions, by a wide margin, is OFAC’s re-designation of Russia’s second-largest bank, this time under the Iran-related sectoral authority discussed in Part 1, rather than under existing Russia sanctions. OFAC alleges the bank opened offices inside Iran and built correspondent banking relationships with sanctioned Iranian institutions, including Iran’s central bank, to move billions of dollars in assets and support bilateral trade through a direct ruble-to-rial settlement channel that bypasses dollar clearing entirely. That bank was already under blocking sanctions from the U.S., UK, and EU for Russia-related conduct; layering Iran sanctions authority on top of that existing designation is a deliberate signal, not a technicality. It tells every major financial institution doing business with sanctioned Russian banks, particularly institutions in China and India that have continued processing Russia-related trade finance, that Treasury will use whatever authority is available, Iran or Russia, to reach conduct connected to either sanctions program, and that the two programs are increasingly being treated as a single, overlapping enforcement effort rather than separate silos.

Reading the Three Actions Together

Individually, these are three enforcement actions against three banks in three different countries. Together, they describe a coordinated strategy: identify the specific financial choke points Iran depends on, whether in the Gulf, in Turkey, or through Russia’s financial system, and eliminate them one at a time using whatever authority best fits the facts, Section 311, direct OFAC designation, or sectoral re-designation under Executive Order 13902. None of these three institutions is a small or obscure player; all three had real, substantial transaction volume before Treasury acted.

For compliance teams at any financial institution with correspondent relationships touching the UAE, Turkey, or Russia, the practical takeaway is that historical relationship longevity is not protection. Institutions that had operated for years without triggering an OFAC action have now been designated based on specific transaction evidence Treasury has clearly been building for some time. Enhanced due diligence on correspondent relationships in these geographies, with particular attention to Iran-adjacent trade finance and any ruble-denominated settlement activity, needs to move from periodic review to active monitoring.

Bringing Both Parts Together

Taken as a whole, Operation Economic Outcast is not a single announcement but a sustained, multi-front campaign: sectoral sanctions that reach non-U.S. companies with no U.S. nexus at all, general license suspensions that hit organizations with little sanctions infrastructure, a licensing policy shift that closes off the traditional fallback of requesting a specific license, a Strait of Hormuz framework that creates risk without any payment changing hands, and an escalating, coordinated campaign against the specific banks keeping Iran connected to the global financial system. Treasury has been explicit that this is ongoing, not a single wave. Compliance functions across aviation, digital assets, gold, shipping, technology, maritime services, and correspondent banking should treat this as an active, evolving risk category requiring continuous monitoring, not a one-time update to a sanctions matrix.