WarBrief Live | November 10, 2026 | Sanctions
Since April 2025, the US Treasury has added 1,574 names to its sanctions list under Iran programmes and just 51 under Russia programmes, according to a count of every OFAC change file published in that period. Russia still holds more names in total, but the flow of new designations has reversed completely.
Key Takeaways
- From April 2025 to November 6, 2026, OFAC added 1,574 names under Iran programmes and 51 under Russia programmes; Russia saw 94 names removed against 54 for Iran.
- Russia still holds more names on the SDN list overall — 6,809 against 4,114 for Iran — so the change is in the flow of new policy, not the stock of past designations.
- Designations alone did not stop Iranian oil exports; the US naval blockade that began on April 13, 2026 did, cutting loadings from about 1.9 million barrels a day in March to about 209,000 in May, according to Vortexa data.
What the OFAC data actually shows
The figures come from a compilation of the change files OFAC publishes with every update to its Specially Designated Nationals (SDN) list — 527 files through October 21, 2026, plus the files published through November 6. The count groups each name by the sanctions programme OFAC lists for it; a name listed under both a Russia and an Iran programme counts in both. The method is transparent and the underlying files are OFAC’s own, which is why the numbers are worth reporting — with the caveat that they are one tracker’s compilation, not a Treasury press release.
From the fourth quarter of 2022 through the first quarter of 2025, Treasury added 4,706 names under Russia programmes and 707 under Iran programmes. Since the start of April 2025, the figures are 51 and 1,574 — Iran has led every quarter since. In 2026 so far, the list shows seven Russia-programme names added and 71 removed.
| Programme | Added (Apr 2025 – Nov 6, 2026) | Removed | Net | Names on the list now |
|---|---|---|---|---|
| Russia | 51 | 94 | -43 | 6,809 |
| Iran | 1,574 | 54 | +1,520 | 4,114 |
Source: OFAC change files, compiled by DaveManuel.com; figures updated November 7, 2026. Totals on the list are the count of names currently designated under each programme.
WarBrief tracks every US sanctions package on the Sanctions Tracker hub.
Why did new Russia designations stop?
The Russia campaign ran on big packages: Treasury and the State Department would hold a batch of targets, often hundreds, and release them together on a date that carried a message — 551 names on February 23, 2024, the second anniversary of the invasion and the death of Alexei Navalny, and 406 on January 10, 2025, covering Gazprom Neft, Surgutneftegas and 183 vessels. That January day was the last of the big packages: from January 20 to the end of September 2025, Treasury added seven names under Russia programmes. In May 2025, President Trump explained the pause directly, saying that if he thought he was close to a deal, he did not want to jeopardise it with new sanctions. The one big exception came on October 22, 2025, when Treasury blocked Rosneft and Lukoil, Russia’s two largest oil companies, along with dozens of their subsidiaries. An independent count points the same way: the Center for a New American Security found in its 2025 review that the administration added only 74 Russian persons to the SDN list that year, against a pace of roughly 1,500 a year under the previous administration. WarBrief covered the subsequent waiver of the Graham Act sanctions bill in our earlier reporting.
What does an Iran designation look like now?
The Iran campaign began on paper on February 4, 2025, when the president signed a national security memorandum restoring the maximum pressure policy of his first term, directing a campaign aimed at driving Iran’s oil exports to zero. What followed was a steady drumbeat rather than a few big packages.
Over the last 12 months, 935 names went onto the list under Iran programmes — 512 companies and groups, 214 people, 200 ships and 9 aircraft. Most of them are not people at all: the targets are the businesses that keep Iranian oil and money moving — shell companies, ship managers, traders and the tankers themselves, registered from Hong Kong and Dubai to Panama and the Marshall Islands. Ships are a large part of the story: the list added 239 ships under Iran programmes in 2025 and 162 more in 2026 so far.
Recent actions show how wide the net has become. On March 20, 2025, Treasury sanctioned its first Chinese “teapot” refinery, the small independent plants that buy most of Iran’s crude. On July 30, 2025, it added 147 names in a single day, built around the shipping network of Mohammad Hossein Shamkhani, the largest Iran action since 2018. On August 24, 2026, Treasury launched Operation Economic Outcast, putting Iran’s digital assets, technology, gold, aviation and shipping sectors in the line of fire and adding 71 names that day; the campaign’s earlier weapons-network designations are covered in our report on the operation’s opening tranche. Treasury Secretary Scott Bessent said the objective was to “sever every economic lifeline that sustains this tyrannical regime until Tehran stands alone”. On October 21, OFAC designated the Karnakis shipping network and issued wind-down general licences GG and HH for the blocked persons and vessels.
Almost all of the shipping designations use Executive Order 13902, which began in 2020 covering Iran’s construction, mining, manufacturing and textile sectors; in October 2024 Treasury added the petroleum and petrochemical sectors, bringing Iran’s oil trade within its scope. The most recent OFAC list change, on November 9, 2026, added nothing at all: SDN list version 13 amended a single entry, adding an alias for Dubai-based Volta Shipping Services, a company sanctioned in July for links to Iran-related trade.
Did the designations work?
For all the names added in 2025, Iran’s oil kept flowing. Ship-tracking firm TankerTrackers put September 2025 exports above 2.1 million barrels a day, the highest month of the year, with China buying close to nine barrels in ten. What changed the numbers was the war: after the US naval blockade of Iranian ports began on April 13, 2026, exports fell from about 1.9 million barrels a day in March to about 209,000 in May, according to Vortexa data. Kpler, which measures it a little differently, put May at 260,000 barrels a day, and August loadings at about 250,000 after the blockade was reinstated on July 14 following a pause in June. Estimates from different trackers are not strictly comparable, but the direction is the same across all three.
That is the uncomfortable lesson in the data. Designations raise the cost of doing business with a target, and they can take years to bite. Physically stopping the ships works much faster. The designations still matter for compliance: banks, insurers, ports and shippers must screen against a list that now grows by hundreds of Iran-programme names a year, and sanctioned tankers rarely stay put — they change names, swap flags and often switch off the transponders that report their position.
What this means for US, UK and EU readers
For businesses, the practical effect is a heavier screening burden and higher shipping and insurance costs on any trade touching Iranian oil, even indirectly. For energy markets, the blockade, not the designations, is what removed Iranian barrels from the market, and its future is tied to the war’s status quo that President Trump described on November 9. Readers should treat this as educational background on how sanctions work, not legal advice: anyone with a transaction that could touch a designated person, vessel or sector should seek professional sanctions counsel.
Frequently asked questions
Which country faces the most US sanctions?
It depends on how you count. Russia still has the most names on the SDN list — 6,809 against 4,114 for Iran — because sanctions are easy to add and slow to remove. But since April 2025, Iran has led every quarter in new additions, 1,574 to 51.
What is the SDN list?
OFAC’s main sanctions list. Anyone on it has their property and interests in property subject to US jurisdiction blocked, and US persons are generally prohibited from dealing with them.
Did sanctions stop Iran’s oil exports?
Designations alone did not. Iranian exports were above 2.1 million barrels a day in September 2025. The US naval blockade that began on April 13, 2026 cut loadings to about 209,000 barrels a day by May, according to Vortexa data.
What is Executive Order 13902?
The 2020 order under which most Iran shipping designations are made. In October 2024 Treasury added the petroleum and petrochemical sectors, bringing Iran’s oil trade within its scope.
Sources
- DaveManuel.com: How Iran Replaced Russia as the Top Target of American Sanctions
- OFAC: Iran-related Designations; Issuance of Iran-related and Russia-related General Licenses (October 21, 2026)
- Expodite: OFAC SDN list version 13, November 9, 2026
- Foley & Lardner (via JD Supra): September 2026 US Sanctions Roundup — Operation Economic Outcast Intensifies
- Balance of Power: Entries added to the US sanctions list each year
This entry is educational content about sanctions regimes and enforcement. It is not legal advice.
