Recent Sanctions and Export Controls Updates for Sudan, Syria, and Iran

In July and August 2026, the United States government issued significant updates to sanctions and export controls for Sudan, Syria, and Iran. While the latest updates continue to loosen restrictions on Syria, Sudan and Iran are facing heightened restrictions and scrutiny. The actions are a reminder that sanctions and export control programs can quickly shift with foreign policy. Companies should be mindful that:

• Prior loosening of restrictions may not be permanent, as seen with proposed restrictions on Sudan nearly a decade after comprehensive sanctions were lifted.
• Syria’s removal from the State Sponsor of Terrorism list opens the door to further dealings in Syria, but caution and diligence are still warranted.
• Iran remains the Trump Administration’s primary focus for new sanctions, and any transactions related to Iran will pose high risks for both U.S. and non-U.S. companies.

Below we summarize the recent developments related to each country.

Sudan: Additional Export Restrictions are Forthcoming

On July 20, 2026, the U.S. Department of State published a notice of a decision to impose additional sanctions on Sudan pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. The notice directs the responsible authorities, namely the Commerce Department’s Bureau of Industry and Security (BIS), to implement a prohibition on all exports to Sudan of goods and technology on the Commerce Control List. The notice provides for limited exceptions for exports of food and agricultural products and exports under certain license exceptions (e.g., License Exceptions CCD, GOV, ENC, BAG, TMP, RPL, TSU and ACE). 

The notice directs the adoption of a presumption of denial for export licenses except for: 

• Exports or reexports related to flight safety  
• Deemed exports or reexports for Sudanese nationals
• Exports or reexports to wholly owned subsidiaries of U.S. or foreign parent companies 

Although the notice takes immediate effect, the export controls themselves must first be implemented by BIS as the responsible agency. Companies should plan now for the new export controls to be issued in the near future.

Syria: Removal of State Sponsor of Terrorism Designation

On August 24, 2026, the U.S. Department of State rescinded Syria's designation as a State Sponsor of Terrorism (SST), a status the country had held for more than four decades. The removal of Syria’s SST designation is the latest step in loosening sanctions on Syria that began in June 2025 with an executive order ordering the termination of the Syria Sanctions Program. In parallel, the State Department revoked the Specially Designated Global Terrorist designation of al-Nusrah Front (Hay'at Tahrir al-Sham, or HTS), and OFAC removed HTS and dozens of related aliases from the SDN List.

Removal of the SST designation eliminates remaining restrictions on Syria under the Terrorism List Governments Sanctions Regulations, 31 CFR part 596 (TLGSR) that had been subject to General License 25. The Departments of Commerce, State, and Treasury also issued an updated tri-seal advisory describing the current landscape of sanctions and export control relief available for Syria. Although the latest action continues the trend of reducing sanctions on Syria, there are still specific entities and individuals targeted by sanctions, and export controls that apply to a wide range of items.

Iran: Significant New Sanctions under 'Operation Economic Outcast'

Also on August 24, 2026, the Treasury Department announced the start of what it is calling Operation Economic Outcast, a sweeping set of sanctions on Iran and third-country entities and individuals that have supported Iran.

The actions include:

• New sectoral determinations under Executive Order 13902 covering Iran's digital asset, technology, gold, aviation, and shipping sectors, expanding the range of conduct that can trigger secondary sanctions against non-U.S. persons dealing with Iran in those sectors
• SDN List designations of nearly 60 individuals, entities, and vessels tied to Iranian nuclear- and missile-procurement networks, and shadow-fleet oil shipping and bunkering operations spanning the UAE, Hong Kong, China, Singapore, Switzerland, and elsewhere
• Suspension of multiple Iran General Licenses, including those authorizing personal remittances, educational activities, export and import of services related to conferences in the U.S. and third countries, and sports and academic exchanges
• Updated guidance on the sanctions risks of complying with Iranian demands regarding passage through the Strait of Hormuz

Additional sanctions designations are likely as the Treasury Department continues to roll out Operation Economic Outcast. In particular, we expect Treasury will broaden the reach of its sanctions designations to expand into the sectors covered by the five new sectoral sanctions determinations.

Key Takeaways

• There is risk in pursuing opportunities in countries that have been subject to recent loosening of sanctions or export controls, like Sudan and Syria. Restrictions can snap back into place, and companies should be mindful of the potential need to terminate dealings as restrictions change.
• Sanctions and export controls can change quickly, through new executive orders, determinations, and implementing regulations. Companies must carefully watch this space and have procedures designed to flag and respond to new restrictions.
• Any U.S. companies relying on general licenses to continue dealings in Iran should closely review the suspensions and wind down activity during the authorized winddown period.
• Non-U.S. companies engaging in transactions with Iran face heightened secondary sanctions risks. The newly flagged sectors will present particular risk for future transactions.