Over the past month, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated 94 legal entities. As with previous months, this review excludes individuals and maritime vessels to focus on corporate enforcement trends.

The two charts below draw on OFAC data as of 01 October 2026. The first tracks the number of legal entities designated per month since January 2025. The second shows the country distribution of entities added during September.

New Designations Per Month — Jan 2025 to Sep 2026

September's activity was concentrated on Iran-related sanctions, with OFAC designating 27 Iranian airlines on September 8th, as well as narcotics networks in Mexico, with 27 newly added entities. The action also included companies in several third countries that provided aviation and related services.

Country Breakdown — September 2026

Iran accounts for the largest group of the September designations, with 30 entities, followed by Mexico with 27 and Cuba with 13. The remaining designations are distributed across several countries, including Turkey, the United Arab Emirates, Iraq, Lebanon, Singapore, the United Kingdom, Malaysia, Burma, Cambodia, Ecuador, and Kazakhstan.

Analysis of Network Designations

September's designations illustrate how the US uses of sector-wide restrictions to target companies that provide services and infrastructure to sanctioned entities.

Iranian aviation. On 8 September, OFAC designated 27 Iranian airlines under the aviation-sector regulations. Several of the airlines were established relatively recently, including Ava Airlines, Fly Kish Airlines, Lad Airways, Mehr Airways, Raimon Airways, and Soroush Air. The action brought this broad group of passenger carriers into the sanctions framework at the same time, rather than adding them through separate individual designations.

Third-country service providers. The September action also designated aviation and logistics companies outside Iran. These entities include cargo and ground-support businesses, aviation-service providers, and other companies involved in aircraft-related activities. Their jurisdictions span at least two continents, illustrating how sanctions exposure can extend to companies providing services within aviation networks.

Mexico SDGT/counter-narcotics network. 27 companies owned or controlled by figures like Marco Antonio Moreno Gomez Santelices, Luis Alfonso Torres Torres, and Jeronimo Javier Vera Ayala were sanctioned.

What this means

September's designations focused on airlines, cargo and aviation-service companies, logistics providers, and financial institutions in multiple countries. Many of these companies had broad, legitimate networks alongside their Iranian partnerships, and it is these firms who are now responsible for avoiding sanctions-related penalties. Lazlo Intelligence traces these company-to-company links from public sources, allowing you to assess the network around a counterparty before those connections become a regulatory problem. Search any entity today to investigate its connections.

Previous Reports