US: OFAC Designates 5 SDGT Targets, Issues GL 36 and Diamond GL 104B

On August 26, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated five targets as Specially Designated Global Terrorists (SDGT) under Executive Order 13224, as amended, and issued two general licenses: Counter Terrorism General License 36, authorizing the wind-down of transactions involving the Italian hosting provider Autistici Inventati, and Russia-related General License 104B, authorizing certain diamond imports otherwise prohibited by Executive Order 14068. The action adds two individuals and three entities to the Specially Designated Nationals (SDN) List, and every new listing carries secondary sanctions risk under section 1(b) of EO 13224 as amended by EO 13886.

The package targets what Treasury describes as violent far-left networks. US and dollar-clearing bank sanctions teams, exporters, and diamond importers must screen the new SDNs without delay, freeze any blocked assets, and apply the two licenses to relevant transactions under OFAC's strict-liability civil-penalty regime, where intent is not required for a violation to attach.

Who are the five new SDGT designations?

Five targets were added to the SDN List as SDGT, all under EO 13224. Two are individuals linked to Masar Badil: Zaid Abdulnasser (a.k.a. Zid Tamim), a Palestinian national born in 1995, located in Germany; and Rawa Alsagheer (a.k.a. Ruwaa Al-Saghir), a Palestinian national born in 1997, located in Brazil. Three are entities: Autistici Inventati, a data-processing and hosting organization established in 2001 in San Giuliano Terme, Pisa, Italy; Masar Badil (Palestinian Alternative Revolutionary Path Movement), an advocacy organization established in October 2021 with presence in Brazil, Germany, Canada, Belgium and Spain, linked to Samidoun Palestinian Prisoner Solidarity Network; and Palestine Action (Palestine Action Group), a transnational group established in the United Kingdom in July 2020.

Compliance teams must add all five to screening filters immediately, flag any existing relationships, and freeze the assets and economic resources of these parties. The 50 Percent Rule applies: any entity 50 percent or more owned, individually or in the aggregate, by one or more blocked persons is itself blocked even if not separately listed, so ownership structures around Autistici Inventati and Masar Badil warrant mapping before the next transaction is cleared.

What does Counter Terrorism General License 36 authorize?

General License 36, "Authorizing the Wind Down of Transactions Involving Autistici Inventati," permits a time-limited wind-down of dealings with the now-designated Italian hosting provider. Counterparties with existing transactions involving Autistici Inventati should consult the license text on OFAC's recent actions page to confirm the authorized scope, the applicable wind-down deadline, and any reporting requirements. Transactions outside the license's authorizations remain prohibited, and the SDGT designation is not lifted by the license: it only narrows what may be done during the wind-down window.

What does Russia General License 104B authorize for diamond imports?

General License 104B, "Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068," carves specific diamond-import transactions out of the Russia sanctions imposed under EO 14068. Diamond importers, customs brokers, and trade-finance banks should review the license to determine whether a given shipment falls within the authorized categories, capture the scope conditions in their compliance files, and retain documentation proving the license basis. Where a transaction does not meet the license's terms, the underlying EO 14068 prohibition continues to apply and a specific license would be required to proceed.

What secondary sanctions exposure do non-US persons face?

All five designations carry secondary sanctions risk under section 1(b) of EO 13224, as amended by EO 13886. Foreign financial institutions and other non-US persons that knowingly facilitate significant transactions for these SDGTs can lose access to the US financial system or be designated themselves. Correspondent and dollar-clearing banks should refresh their sanctions filters, cascade the new SDNs and their aliases to transaction-monitoring and name-screening systems, and review recent activity for the listed parties and their 50-percent-owned affiliates before the next settlement cycle.

Real-time, per-jurisdiction monitoring surfaces SDN List updates the moment OFAC publishes them, so screening teams act before the next transaction clears.

Take advantage of this real-time watch

Compliance teams should now confirm that all five SDNs and their aliases are live in screening and transaction-monitoring systems, trace ownership around Autistici Inventati and Masar Badil for 50 Percent Rule exposure, apply GL 36 to any Autistici Inventati wind-down and GL 104B to qualifying diamond imports with documented license bases, and brief front-office, trade-finance, and correspondent-banking colleagues on the secondary sanctions risk. The full designations, license texts, and SDN List updates are published on OFAC's recent actions page; Obsidian's sanctions desk will publish follow-up analysis as the wind-down deadlines approach.