The U.S. Treasury Department is likely to announce new secondary sanctions against Iran every week, beginning with banks and potentially cutting targeted institutions off entirely from the dollar-based financial system, Treasury Secretary Scott Bessent said Sunday. In an interview with Reuters, Bessent said the campaign would follow Friday’s action against the United Arab Emirates branches of Egypt’s Banque Misr. The announcement turns a sanctions operation unveiled only days earlier into a recurring policy rather than a single enforcement round.
Bessent separately told the AP that another, still-unidentified bank would face action this week. That detail matters because the first bank measure is narrower than some descriptions suggest: the Financial Crimes Enforcement Network proposed restricting the five UAE branches of Banque Misr from U.S. correspondent banking, while the Office of Foreign Assets Control sanctioned one Iranian banker and a Hong Kong company. The proposed bank rule is not yet final and will receive a 30-day public-comment period after Federal Register publication.
The weekly schedule raises the stakes for financial institutions far beyond Iran because secondary sanctions operate through access to the U.S. market rather than direct American jurisdiction over every foreign transaction. Banks must decide whether Iranian-linked business is worth the possibility of losing dollar clearing or correspondent relationships. The policy test is whether faster action deters evasion without pushing legitimate trade into less transparent channels.
A bank-cutoff tool with global reach
FinCEN is using Section 311 of the USA PATRIOT Act, codified at federal law, to identify a foreign institution as a primary money-laundering concern and impose what is known as special measure five. The authority can prohibit or condition U.S. correspondent and payable-through accounts for a foreign bank. It also requires consultation with other agencies and consideration of burdens on U.S. institutions, effects on international payment systems, legitimate business and national security.
The agency’s 38-page proposed rule would bar covered U.S. financial institutions from opening or maintaining accounts for Banque Misr UAE, require reasonable steps to avoid processing its transactions through other foreign correspondents and mandate enhanced due diligence. FinCEN said the five UAE branches have three direct U.S. correspondent relationships. The proposal expressly excludes Banque Misr’s operations in Egypt and every other country, a boundary that limits the legal action while still placing pressure on the larger banking group.
Correspondent banking is the plumbing that allows a bank without a U.S. presence to settle dollar transactions through an American institution. A formal cutoff therefore reaches beyond the named branches: foreign banks that continue moving Banque Misr UAE transactions could place their own U.S. relationships under scrutiny. At the same time, the rule does not itself freeze every asset of Banque Misr or ban all transactions with the Egyptian parent, and describing it as a completed exclusion would overstate what Treasury has done.
Treasury details the case against Banque Misr UAE
Treasury says Banque Misr UAE processed about $1.8 billion for 103 companies potentially connected to Iranian shadow-banking networks between January 2024 and June 2026, including $520 million during the most recent 12 months. The department’s release describes the branches as a critical point of access to U.S. dollars for Iranian entities. FinCEN estimates the UAE operation has roughly $6 billion in assets, making the suspected Iranian-linked activity material relative to the size of the institution, although the agency acknowledges that some of its business is legitimate.
The notice identifies accounts associated with several companies that the U.S. says moved money for Iran’s Ministry of Defense, the Islamic Revolutionary Guard Corps or sanctioned exchange houses. FinCEN reports that one front company processed more than $32 million through the branches and another processed more than $29 million. Those findings combine public records with nonpublic information available to Treasury; they are agency assessments supporting a proposed regulatory measure, not findings from a criminal trial. Banque Misr and affected parties can challenge the evidence and scope during rulemaking.
OFAC’s parallel action uses different authorities. It designated Reza Mohammad Taeedi, manager of Bank Melli’s Dubai branch, under a counterterrorism executive order and designated Hong Kong-based Kameng Trading Limited for operating in Iran’s financial sector. Those designations generally freeze property subject to U.S. jurisdiction and prohibit U.S. persons from dealing with the named parties. Keeping the two mechanisms separate is essential: one is an immediately effective sanctions designation, while the Banque Misr UAE correspondent-account restriction remains proposed.
Weekly announcements change the compliance burden
A predictable weekly tempo could alter bank behavior before any institution is formally named. Compliance departments must review customers, owners, trade documents and correspondent traffic for Iranian links across layers of companies. Because a missed connection can threaten dollar access, banks may end relationships that are lawful but difficult to verify, a practice known as de-risking. That can strengthen sanctions while affecting ordinary firms and remittances that were not intended targets.
FinCEN’s earlier analysis helps explain Treasury’s emphasis on transaction networks rather than only named Iranian institutions. The agency identified approximately $9 billion in potential Iranian shadow-banking activity through U.S. correspondent accounts during 2024, covering 2,027 transactions of at least $500,000. FinCEN cautioned that Bank Secrecy Act reports reflect suspicious activity identified and reported by financial institutions, not proof that every transaction was illegal. The data measure detected financial activity, not the total size of Iran’s network.
China and U.S. partners define the ceiling
China is the clearest test of whether secondary sanctions will be applied consistently. Treasury estimated in April that China bought about 90 percent of Iran’s oil exports, with independent refiners accounting for most purchases, according to department data. Bessent said Sunday that most Chinese purchases had already been curtailed by the blockade of Iranian ports, while also leaving open the possibility of sanctions involving Beijing. That assertion cannot yet be evaluated from comprehensive public trade data because Iranian oil frequently moves through relabeling, ship-to-ship transfers and opaque ownership structures.
The initial Banque Misr action shows the diplomatic calibration. An AP analysis noted that Treasury stopped short of sanctioning the Egyptian parent bank, which is state owned, and instead targeted its UAE branches and dollar transfers. Egypt’s central bank said the measure did not affect Banque Misr inside Egypt or its other overseas branches. Such precision may reduce collateral damage and preserve relations with Cairo and Abu Dhabi, but it also leaves pathways that enforcement officials will have to monitor for displacement.
What would demonstrate that the policy works
Past sanctions show that financial pressure can sharply reduce Iranian oil sales when major buyers cooperate. U.S. Energy Information Administration data indicate that Iran’s crude and condensate exports fell from about 2.6 million barrels a day in 2011 to roughly 1.3 million in 2013 after U.S. and European measures tightened. More recent EIA data also show that Iran increased shipments, primarily to China, in 2022 and 2023 despite sanctions. The record therefore supports neither the claim that sanctions are futile nor the assumption that initial declines will endure without sustained multinational enforcement.
Current wartime conditions make attribution harder. Port restrictions, military risk, tanker availability, insurance costs and the Strait of Hormuz disruption can suppress exports independently of bank sanctions. If Iranian revenues decline, analysts will need to separate those effects from financial enforcement before crediting Operation Economic Outcast. Treasury’s August 24 campaign launch included vessels, companies and individuals across several jurisdictions, so even within the sanctions program it may be difficult to identify which measure produced any observed change.
The next evidence will be concrete. Treasury can identify the next bank, specify the legal mechanism and disclose the conduct supporting its action. FinCEN can publish comments and explain revisions before finalizing the Banque Misr UAE measure. Regulators can then track correspondent relationships, oil flows and migration to new intermediaries. Weekly announcements establish speed; those outcomes will show whether the campaign creates durable isolation or merely a faster cycle of evasion and designation.