On October 8, 2026, OFAC issued Iran-related General License EE, Russia-related General License 13S, and changes to the SDN List. Businesses should review the original licenses and current list before winding down Samudra-related transactions or processing administrative transactions connected to Directive 4.
Key developments
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced Iran- and Russia-related actions on October 8, 2026. The announcement covers the issuance of Iran-related General License EE, the issuance of Russia-related General License 13S, and changes to the Specially Designated Nationals and Blocked Persons (SDN) List. [S1]
Iran-related General License EE
General License EE is titled “Authorizing the Wind Down of Transactions Involving Samudra Marine Services Private Limited.” The license is therefore presented as authorizing the wind-down of transactions involving Samudra Marine Services Private Limited. [S1]
Businesses should check whether the company appears as a counterparty, marine service provider, or named party in contracts and transaction documents. The supplied announcement summary does not state the wind-down period, permitted transaction types, or conditions for payments, transport, or contract handling. Those details should not be assumed; they must be checked in the license text.
Russia-related General License 13S
OFAC also issued Russia-related General License 13S. Its title is “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024.” The authorization concerns certain administrative transactions. [S1]
Companies should determine whether the administrative transaction they plan to conduct is connected to Directive 4 and Executive Order 14024, and whether it falls within the authorization provided by General License 13S. The supplied material does not describe the covered transaction categories or other conditions in enough detail to determine applicability.
SDN List changes and operational checks
The announcement also states that OFAC made changes to the SDN List. The supplied material does not identify the entities added, removed, or otherwise changed. [S1]
Trade, logistics, and compliance teams should consider the following checks:
- Re-screen new and existing counterparties against the current OFAC SDN List.
- Check contracts, invoices, transport documents, and payment instructions for references to Samudra Marine Services Private Limited.
- If winding down an Iran-related transaction, review the scope and conditions stated in the full text of General License EE.
- For Russia-related administrative transactions, assess the relationship among Directive 4, Executive Order 14024, and General License 13S.
- Confirm from the license text whether recordkeeping, counterparty verification, or other procedures apply.
The actions were announced on October 8, 2026. The supplied material does not provide the detailed effective dates, expiration dates, or transaction-specific conditions for either general license. Before proceeding with or winding down a transaction, businesses should review the full OFAC licenses and the current SDN List.