WASHINGTON, D.C. — The U.S. Treasury Department announced a series of actions last week that block targeted individuals and companies from accessing U.S.-linked money and, in one case, could cut a foreign bank off from the U.S. financial system, as the Trump Administration escalates pressure tied to cyber theft, Iran’s oil and weapons networks, and Nicaragua’s government.
What This Means for You
- U.S. individuals and businesses generally must freeze any assets they hold for newly sanctioned parties and avoid most transactions involving them.
- Banks and companies outside the United States can face increased sanctions exposure if they do significant business with designated parties.
- A separate proposal could bar U.S. banks from maintaining certain accounts for MBaer Merchant Bank AG, potentially limiting how it can move dollars.
Cyber Tools and Trade Secret Theft Case
On Tuesday, Treasury’s Office of Foreign Assets Control, known as OFAC, designated Russian national Sergey Sergeyevich Zelenyuk and his company Matrix LLC, doing business as Operation Zero, along with five associated individuals and entities, alleging they acquired and sold cyber tools that threatened U.S. national security.
OFAC is the Treasury office that administers economic sanctions, including placing individuals and companies on a sanctions list that blocks most dealings with U.S. persons. Treasury said Operation Zero operates as an “exploit” broker, meaning it deals in techniques or code that take advantage of software vulnerabilities to gain unauthorized access, steal information, or take control of devices.
Treasury said Operation Zero acquired at least eight proprietary cyber tools created for the exclusive use of the U.S. government and select allies that were stolen from a U.S. company, and later sold those tools to at least one unauthorized user.
“If you steal U.S. trade secrets, we will hold you accountable,” Treasury Secretary Scott Bessent said.
Treasury said the action coincides with a Justice Department and FBI investigation involving Peter Williams, an Australian national and former employee of the U.S. company, who pleaded guilty on October 29, 2025, to two counts of theft of trade secrets. Treasury said Williams stole proprietary cyber tools between 2022 and 2025 and sold them to Operation Zero for millions of dollars paid in cryptocurrency.
Treasury said the designations were issued under Executive Order 13694, as amended. Treasury also said the State Department imposed sanctions in parallel under the Protecting American Intellectual Property Act, which Treasury described as being used for the first time to sanction people tied to significant theft of U.S. trade secrets that could pose a national security, foreign policy, or economic threat.
Iran Oil “Shadow Fleet” and Weapons Procurement Networks
On Wednesday, OFAC sanctioned more than 30 individuals, entities, and vessels tied to illicit Iranian petroleum sales and Iran’s ballistic missile and advanced conventional weapons production, Treasury said.
Treasury described Iran’s “shadow fleet” as vessels that transport Iranian petroleum and petroleum products to foreign markets. Treasury said it targeted 12 vessels and their owners or operators, alleging the ships moved hundreds of millions of dollars’ worth of Iranian petroleum and petrochemical products.
Treasury cited Executive Orders 13902, 13382, and 13949 as authorities for the action, and said the sanctions support the Administration’s “maximum pressure” campaign on Iran.
Treasury’s statement listed specific ships by name and International Maritime Organization numbers, including HOOT, OCEAN KOI, NORTH STAR, FELICITA, ATEELA 1, ATEELA 2, NIBA, LUMA, REMIZ, DANUTA I, ALAA, and GAS FATE, and identified multiple companies alleged to operate in Iran’s petroleum, petrochemical, or related sectors.
Treasury also described networks in Iran, Türkiye, and the United Arab Emirates that it said helped procure chemicals and machinery supporting Iran’s missile and weapons programs and the proliferation of unmanned aerial vehicles, or UAVs, including companies it said served as financial intermediaries for UAV engine producer Oje Parvaz Mado Nafar Company.
Proposed Rule Targeting MBaer Merchant Bank AG
Also on Thursday, Treasury’s Financial Crimes Enforcement Network, known as FinCEN, proposed a rule that, if finalized, would prohibit covered U.S. financial institutions from opening or maintaining a “correspondent account” for, or on behalf of, MBaer Merchant Bank AG.
A correspondent account is a banking relationship that helps a foreign bank access U.S. financial services, including the ability to move transactions through the U.S. system and the U.S. dollar.
Treasury said MBaer “has funneled over a hundred million dollars through the U.S. financial system” for illicit actors tied to Iran and Russia, and said the bank and its employees enabled money laundering and illicit finance activities.
FinCEN said it is acting under Section 311 of the USA PATRIOT Act, which allows FinCEN to identify a foreign institution as a “primary money laundering concern” and impose “special measures.” FinCEN said it proposed “special measure five,” the most restrictive option, which would bar U.S. banks from maintaining correspondent accounts for the targeted institution.
FinCEN said written comments on the notice of proposed rulemaking may be submitted within 30 days of publication in the Federal Register.
FinCEN also pointed to its whistleblower incentive program for violations of the Bank Secrecy Act and certain sanctions and national security laws, stating that individuals who provide actionable information may be eligible for awards if a tip leads to a successful enforcement action. More information is available at https://www.fincen.gov/whistleblower-program.
Sanctions on Nicaraguan Officials
Separately on Thursday, OFAC sanctioned five Nicaraguan government officials Treasury said lead key financial, communications, and military agencies used by the Murillo-Ortega government to repress political opponents and civil society.
Treasury said the individuals include the Director and Deputy Director of Nicaragua’s Financial Analysis Unit, the Minister of Labor, the Deputy Director General of the Nicaraguan Institute of Telecommunications and Postal Services, and the head of the Nicaraguan Army’s Directorate of Military Intelligence and Counterintelligence.
Treasury said the sanctions were issued under Executive Order 13851, as amended, and described allegations that Nicaragua’s financial intelligence function was used to monitor foreign inflows and block funding to opposition organizations, including by liquidating assets of dissidents and nongovernmental organizations.
Treasury also cited a October 25, 2025 report by the Office of the U.S. Trade Representative on Nicaragua’s labor practices, and said Nicaragua’s telecommunications regulator has been used as part of a broader surveillance apparatus, including powers described in a 2024 telecommunications law to collect data, intercept communications, and geolocate individuals.
Sanctions Implications and Compliance Risks
Across the actions, Treasury said property and interests in property of designated persons that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Treasury also reiterated the “50 percent rule,” warning that entities owned 50 percent or more by blocked persons are also blocked, even if not named individually.
Treasury said violations can lead to civil or criminal penalties, and warned that some transactions can expose foreign financial institutions and other non-U.S. actors to secondary sanctions risk when doing significant business with designated parties.
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