Over the past month, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated 93 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 November 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 October.
New Designations Per Month — Jan 2025 to Oct 2026
October's volume (93) was almost identical to September's (94), but it was more concentrated. Iran programs accounted for 69 of the 93 entities (74%), delivered in four separate rounds on 1, 8, 15 and 21 October. The remaining designations included a Mexican cartel-linked business network, five Chinese companies under the Protecting American Intellectual Property Act (PAIPA), and a handful of one-off actions.
Country Breakdown — October 2026
Iran and China tied for the largest share of October's designations, with 21 entities each, followed by Mexico with 11, the Marshall Islands with 10, and the United Arab Emirates with 7. The remaining 23 designations are spread across 15 jurisdictions, including Turkey, Panama, France, India, Rwanda, the United Kingdom, Singapore, the Netherlands, Germany, the British Virgin Islands, Iraq, Russia, North Korea, Cuba, and Indonesia.
Analysis of Network Designations
Of the 69 Iran-related entities designated in October, only 21 (30%) are located in Iran. The other 48 sit in third countries, led by China (16), the Marshall Islands (10), the UAE (7) and Turkey (4). This is a different approach from September, when OFAC designated 27 Iranian airlines in a single action against one sector. October's actions instead reached across several parts of Iran's economy at once, together with the foreign companies that service them.
Shipping shells and their managers. Ten shipping companies are registered as Marshall Islands entities and share the same registered address: the Trust Company Complex on Ajeltake Road in Majuro. This is the standard registered-agent address for Marshall Islands companies. The OFAC record itself lists no relationships for these shells.
Iran's automotive and rail industry. OFAC designated Iran's major vehicle manufacturers: Iran Khodro, Iran Khodro Diesel, SAIPA, Pars Khodro and Zamyad, along with motorcycle maker Niroo Motor, Iran's largest motorcycle manufacturer, designated here through its two companies, Niroo Motor Damavand and Niroo Motor Shiraz. Foreign companies designated under the same program include Iran’s Heavy Equipment Production Company’s (HEPCO) Shanghai subsidiary, an Indonesian motorcycle company, a Turkish vehicle-parts trader and a Dubai auto-parts company.
Steel and metals. Six designations fell under IRAN-EO13871, the metals-sector order. Three of them, two in China and one in Iran, are owned or controlled by Ramin Keshvardoust. Germany's Tech-Trade International Impex GmbH was designated for providing support to Mobarakeh Steel Company, Iran's largest steel producer. Two UAE metal traders complete the group.
Money movement. The Iran actions also covered Iranian exchange and trading partnerships, Chabahar International Bank Overseas, Jazireh International Bank on Kish Island, and Iraq's International Development Bank for Investment and Finance in Baghdad.
Mexico. On 13 October, OFAC designated 11 Mexican entities under its counter-narcotics and SDGT authorities. Eight are owned or controlled by Gamaliel Garza Garcia and one by Cartel del Noreste. Their registered activities are ordinary local businesses: fuel wholesale (4), building and road construction (4), transportation, horse breeding, and a sports and restaurant venue.
Europe. Six European entities were designated this month. In addition to the German steel supplier and the two UK shipping-linked companies, OFAC designated two French associations, Association Baraka and Ensemble C Mieux. Most notably, it designated the International Criminal Court in The Hague, with US Secretary of State Marco Rubio calling it a “rogue court”.
What this means
Most of October's designations sit one or more steps away from Iran: a Marshall Islands shell with a Hong Kong manager, a German supplier to an Iranian steelmaker, an Indonesian motorcycle company designated under the same program as Iran's carmakers. Many of these shell companies share registered addresses, managers and owners, and most have no relationships listed in the OFAC record itself. Search any entity today to investigate its connections.