OFAC Hits Iran Offshore Banks, a Cartel del Noreste Racetrack and Chinese Firms Tied to Google Trade Secret Theft in One Week

Treasury’s Office of Foreign Assets Control packed a wide spread of actions into 13 to 19 October: Iranian offshore banks, a Mexican cartel’s racetrack, a Bank of America settlement and a fresh use of a 2023 law against trade secret theft.

Together they show how many separate legal authorities Washington now runs at once. Every designation below rests on an executive order or an existing statute. None needed a vote.

Iran’s dollar channels

The biggest batch came on 15 October under Executive Order 13902, which targets Iran’s financial sector. OFAC listed 16 individuals and 10 Iran-related entities as part of what Treasury calls Operation Economic Outcast, launched on 24 August to cut off the regime’s remaining revenue.

Two of the entities are Iranian “offshore” banks set up in free trade zones: Jazireh International Bank Company on Kish, affiliated with Bank Mellat, and Chabahar International Bank Overseas Company, affiliated with Bank Shahr. Treasury says both were approved by Iran’s central bank and its Supreme National Security Council to use foreign currency for sanctions evasion.

The third bank sits outside Iran. The International Development Bank for Investment and Finance, also known as Iraq Development Bank, is based in Baghdad. Treasury says Iranian companies set it up to give Iran dollar access and that it sends its profits back to Iran in dollars each month. OFAC issued General License FF so counterparties can wind down dealings with it until 12:01 a.m. Eastern time on 30 October.

The rest of the list is the plumbing. Four exchange houses, in Tehran, Qom and Qeshm, were designated with their owners. Treasury says one, the Najafzadeh exchange in Tehran, processed hundreds of millions of dollars for Iranian banks. A Hong Kong trading company, seven employees of a Bank Shahr affiliate and a Dubai-based oil trustee with two of his companies were also listed.

The same day, the State Department designated a Cuban state bank, Banco Internacional de Comercio (BICSA), under the Cuba order of 1 May 2026, Executive Order 14404. State said BICSA has provided services to Iran’s Karafarin Bank, itself sanctioned since 2020, since at least 2022.

A racetrack in Nuevo Laredo

On 13 October OFAC designated four individuals and 11 entities tied to Cartel del Noreste, which the State Department listed as a Foreign Terrorist Organisation in February 2025. Treasury called it the most significant effort yet against the group’s finances. It’s the fourth CDN action under this administration, after May 2025, August 2025 and April 2026.

At the centre is Club La Molienda, a racetrack, restaurant and bar in Nuevo Laredo that earns entry fees from racers and spectators. Treasury says many of the horses raced there are bought in the United States. The cartel’s founders laundered drug money through horse racing in the United States before; in 2012 US authorities seized 455 horses.

The rest of the network looks like a regional business group. It includes three construction and materials firms, one of which Treasury says won public contracts from Nuevo Laredo and Tamaulipas, along with four gas distributors, a property developer and a trucking firm whose trailers carried cocaine hidden in brake drums. Mexico’s financial intelligence unit coordinated on the action. Most designations ran under both the drug and terrorism orders, which exposes foreign banks dealing with these names to secondary sanctions.

Bank of America and the cleanup

OFAC’s part of the 13 October Bank of America penalties, covered in our post on the full Treasury action, came to $11,662,930 for 475 apparent violations between September 2021 and April 2025, worth about $14.8 million. OFAC found them non-egregious and gave the bank no reduction from the base penalty. It cited prior cautionary letters about similar conduct and said the bank failed for a long time to prioritise alerts where both name and date of birth matched a blocked person.

The list also shrank. On 5 October OFAC removed 125 individuals and entities in the third round of what Treasury calls its sanctions modernisation initiative: dead people, defunct companies and entries too thin to screen against. On 14 October it removed Jorge Rodriguez, president of Venezuela’s National Assembly and brother of interim president Delcy Rodriguez, whose own sanctions were lifted earlier this year.

Trade secrets as a sanctions trigger

The week closed on 19 October with five Chinese entities designated under the Protecting American Intellectual Property Act. The State Department said they are connected to Linwei Ding, the former Google engineer convicted by a federal jury in January on seven counts of trade secret theft involving Google’s AI work. The names are a Beijing investment manager that trades as MiraclePlus, three of its venture partnerships and Shanghai Zhisuan Technology.

The law was first used in February, against a Russian exploit broker. The five went on OFAC’s menu-based list instead of the main SDN list, with blocking that carves out imports of goods. That leaves trade with the firms possible while restricting US loans, payments and investment. It turns a criminal conviction into a standing financial penalty on the companies around the defendant.

That pattern is the useful signal for Congress. The administration is using every authority it has, from a 2020 Iran order to a 2023 IP law, while the fight over the Russian diesel licence shows how little say lawmakers have when sanctions ease.