US: OFAC Blocks Golden Global Bank, Issues Iran General License CC

On September 4, 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) added three Türkiye-based financial entities to its Specially Designated Nationals (SDN) List under the Iran sanctions program and issued Iran General License CC, which authorizes the wind-down of transactions involving persons blocked that same day. The designations target the Golden Global group of Istanbul, led by Golden Global Investment Bank (SWIFT/BIC GOGYTRIS), alongside an asset-management and a leasing affiliate, severing what Treasury called Iranian regime financial lifelines in Türkiye. The package takes effect immediately and carries strict civil liability under 31 CFR Part 501, so any bank or screening system touching U.S. dollars must update its filters the same day.

The three entities are tagged IRAN-EO13902, meaning they were designated under Executive Order 13902, the Iran sanctions authority. Alongside the blocking, OFAC issued Iran General License CC, "Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on September 4, 2026." The full notice is in OFAC's September 4, 2026 release, and Treasury's policy framing is in its press release on the Türkiye-Iran nexus.

Which entities are now blocked, and what does the 50 Percent Rule add?

OFAC blocked three Golden Global entities on September 4, 2026, all registered in Istanbul and tagged IRAN-EO13902. The bank is the hub; the other two are designated as linked to it.

Once listed, these entities are blocked: U.S. persons and anyone in the United States must freeze any property or interest in property of the designees and report them to OFAC. The 50 Percent Rule extends the block beyond these names, because any company 50 percent or more owned, in the aggregate, by one or more blocked persons is itself blocked even when not separately listed. Compliance teams therefore cannot stop at three exact-name matches; they must map Golden Global's ownership graph and treat any majority-owned subsidiary or affiliate as blocked property.

Who must act, and how does U.S. jurisdiction reach non-U.S. banks?

Two audiences carry the heaviest exposure. First, any bank or payment institution that touches U.S. dollar clearing: under OFAC's extraterritorial reach, a transaction that transits the U.S. financial system or a U.S. person falls within U.S. jurisdiction regardless of where the parties sit. Correspondent banks that routed USD payments through Golden Global Investment Bank, or that hold its SWIFT GOGYTRIS as a counterparty, are directly in scope. Second, trade-finance teams and corporates with Türkiye counterparty exposure must screen incoming and outgoing payments against the updated SDN list and against any 50 Percent Rule extensions they have identified.

OFAC enforces a strict-liability regime, so civil penalties attach without proof of intent under 31 CFR Part 501. Treasury framed the action as cutting Iranian regime funding networks routed through Turkish finance, which signals continued scrutiny of the Türkiye-Iran corridor. Institutions that keep clearing, corresponding, or settling for the Golden Global group after September 4, 2026 face strict-liability exposure, with voluntary self-disclosure offering up to 50 percent penalty mitigation under Appendix A to 31 CFR Part 501.

What does Iran General License CC authorize, and for how long?

A general license is a standing authorization: eligible parties do not need to apply for a specific license, but they may rely on it only within the four corners of its text. Iran General License CC covers wind-down activity involving the persons blocked on September 4, 2026, and any transaction outside the license's defined scope, counterparties, and time window remains prohibited. Compliance teams should extract the license's effective dates and authorized parties, map them against outstanding positions and pending payments involving the Golden Global group, and execute the wind-down within the window. Transactions that cannot be completed under the license require a specific license application to OFAC.

Obsidian's continuous, per-jurisdiction real-time monitoring surfaces SDN list changes the moment OFAC publishes them, so screening teams act before a transaction clears rather than after.

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Push the three new identifiers, including SWIFT GOGYTRIS, into your screening systems today. Map Golden Global's ownership graph and apply the 50 Percent Rule to any majority-owned affiliate. Block and report any property or interests of the designees, and read Iran General License CC to calendar its wind-down window, applying for a specific license where the license does not reach. Brief your trade-finance and sanctions staff before the week closes, and weigh voluntary self-disclosure for any historical Golden Global exposure.