Four Years of Treasury Data Show Washington Quietly Changing Who It Punishes
For three years after Russia invaded Ukraine, almost every big day at the Treasury Department sanctions office was about Russia. Hundreds of banks, arms suppliers, oil companies and tankers went onto the blacklist at a time, usually timed to an anniversary or a G7 summit.
Then it stopped. Since the start of April 2025, Treasury has added 51 names to the list under its Russia programs and taken 94 off. Over the same stretch it added 1,551 under its Iran programs.
I pulled every change file the Office of Foreign Assets Control has published since September 2022 for the new Sanctions Tracker on this site, and the switch is impossible to miss once you line the numbers up. Here is what changed, what is now being targeted, and what it has actually done.
How Iran Replaced Russia as the Top Target of American Sanctions
Every name the Treasury has added to or taken off its main sanctions list since 2022, sorted by program. The line where the Russia campaign ends and the Iran campaign takes over is about as sharp as these things get.
The SDN list, April 2025 through October 21, 2026| Program | Added | Removed | Net |
|---|---|---|---|
| Russia | 51 | 94 | −43 |
| Iran | 1,551 | 54 | +1,497 |
More Russia-program names came off the list than went on. Iran-program additions include more than 300 ships.
01 · The switchTwo Campaigns, One Hard Turn
Each pair of bars below is one quarter. The blue bar counts names added to the Specially Designated Nationals list under Russia-related programs, and the green bar counts names added under Iran-related programs. For ten straight quarters, from late 2022 through the first quarter of 2025, Russia led every one, usually by a wide margin. Iran has led every quarter since.
Names added per quarter. The fourth quarter of 2026 runs through October 21 only. A name listed under both a Russia and an Iran program counts in both. Source: OFAC change files, compiled by DaveManuel.com.
Add it up and the contrast is stark. From the fourth quarter of 2022 through the first quarter of 2025, Treasury added 4,706 names under Russia programs and 707 under Iran programs. Since then it is 51 and 1,551. The full day-by-day history is on the Sanctions Tracker.
02 · 2022 to 2025The Russia Years
The Russia campaign ran on big packages. Treasury and the State Department would hold a batch of targets, often hundreds, and release them together on a date that carried a message. The biggest days in the data all belong to Russia.
| Date | Names added | What it targeted |
|---|---|---|
| Feb 23, 2024 | 551 | Second anniversary of the invasion and the death of Alexei Navalny |
| Jan 10, 2025 | 406 | Gazprom Neft, Surgutneftegas and 183 vessels, ten days before the inauguration |
| Oct 30, 2024 | 397 | Third-country suppliers to Russia's military industry |
| Aug 23, 2024 | 391 | Evasion networks and suppliers in third countries |
| Jun 12, 2024 | 366 | G7 summit week package |
| May 19, 2023 | 322 | Hiroshima G7 summit package |
Names that went onto the SDN list that day under Russia programs. Counts include names designated by the State Department, which also appear on the SDN list.
The targets moved outward over time. The first waves in 2022 hit Russian banks, oligarchs and officials. By 2024 the packages increasingly went after companies in China, Turkey, the UAE and Central Asia that kept supplying Russia's military with chips, machine tools and parts. In December 2023 an executive order went further and threatened foreign banks themselves with sanctions if they did significant business with Russia's military-industrial base.
The last of the big packages came on January 10, 2025, ten days before the inauguration, when Treasury went after Russian oil directly: Gazprom Neft, Surgutneftegas, oilfield service firms, insurers and 183 vessels.
03 · 2025 to nowThen the Russia Packages Stopped
From January 20, 2025 to the end of September 2025, Treasury added seven names under Russia programs. In May 2025 President Trump explained the pause directly:
The one big exception came on October 22, 2025, when Treasury blocked Rosneft and Lukoil, Russia's two largest oil companies, along with dozens of their subsidiaries, and called on Moscow to agree to a ceasefire. Most of the 51 Russia-program names added since April 2025 came in that quarter. In 2026 so far, the list shows 7 Russia-program names added and 71 removed.
The Center for a New American Security, which counts designations every year, reached the same conclusion from a different angle. Its 2025 review found the administration added only 74 Russian persons to the SDN list that year, against a pace of roughly 1,500 a year under the Biden administration.
Congress tried to force the issue. In September 2026 the president signed a bill named for Senator Lindsey Graham that mandated new sanctions on major Russian banks and steep tariffs on Russian goods. On October 16, days before those provisions were due, he waived many of them. Everything already on the list stayed there, but nothing new was added.
04 · Maximum pressureIran Moves to the Front
The Iran campaign started on paper on February 4, 2025, when the president signed a national security memorandum restoring the maximum pressure policy of his first term. It directed a campaign aimed at driving Iran's oil exports to zero, and told Treasury to issue guidance to shipping, insurance and port operators.
What followed was a steady drumbeat rather than a few big packages. On March 20, 2025, Treasury sanctioned its first Chinese teapot refinery, the small independent plants that buy most of Iran's crude. On July 30, 2025, it added 147 names in a single day, built around the shipping network of Mohammad Hossein Shamkhani, the largest Iran action since 2018. By December 2025 Treasury said it had sanctioned more than 180 vessels for carrying Iranian oil since the inauguration.
The war that began on February 28, 2026 sped things up. On August 24, 2026 Treasury launched what it called Operation Economic Outcast, putting Iran's digital assets, technology, gold, aviation and shipping sectors in the line of fire, and added 71 names under Iran programs that day. Treasury Secretary Scott Bessent described the goal this way:
Measured by the year names were added, today's list already shows two record years for Iran. The previous high was 2018, the year the US left the nuclear deal and reimposed its sanctions.
* 2026 through October 21. Only names still on the list are counted, so earlier years are understated by later removals. Source: OFAC enhanced SDN file.
05 · Who gets namedWhat an Iran Designation Looks Like Now
Over the last 12 months, 935 names went onto the list under Iran programs. Most of them are not people at all. They are the businesses that keep Iranian oil and money moving: shell companies, ship managers, traders and the tankers themselves, registered everywhere from Hong Kong and Dubai to Panama and the Marshall Islands.
Iran-program additions, last 12 months, by typeA sample of recent Iran actions shows how wide the net has become:
A law firm in Panama and Greece accused of setting up shell companies for shadow-fleet tankers, plus a Dubai ship agent and nine vessels
Ship owners registered in the Marshall Islands and ship managers in China
Iran Khodro and other major Iranian carmakers, plus the national railway company
Iranian airlines and the foreign cargo and logistics firms that service them
A Turkish investment bank and two of its affiliates
Two Iranian crypto exchanges, one of them built around trading the dollar stablecoin Tether
Almost all of the shipping designations use Executive Order 13902. It started in 2020 as a sanctions order on Iran's construction, mining, manufacturing and textile sectors. In October 2024, after Iran's missile attack on Israel, Treasury added the petroleum and petrochemical sectors, which made anyone operating in Iran's oil trade fair game. That is the tag you will see on most of the tankers in the latest actions on the Sanctions Tracker.
Ships are a big part of the story. The list added 239 ships under Iran programs in 2025 and 162 more in 2026 so far. Sanctioned tankers rarely stay put: they change names, swap flags to registries like Cameroon, Sierra Leone or Panama, and often turn off the transponders that report their position. The Shipping Chokepoint Monitor tracks the traffic through Hormuz and the other straits these ships use.
06 · Did it work?The Blockade Did What the Blacklist Could Not
For all the names added in 2025, Iran's oil kept flowing. Ship-tracking firm TankerTrackers put September 2025 exports above 2.1 million barrels a day, the highest month of the year, with China buying close to nine barrels in ten. A year into maximum pressure, Iranian exports were largely intact.
What changed the numbers was the war. After the US naval blockade of Iranian ports began on April 13, 2026, exports fell from about 1.9 million barrels a day in March to about 209,000 in May, according to Vortexa data. Kpler, which measures it a little differently, put May at 260,000.
Iranian crude exports, million barrels a daySeptember 2025 from TankerTrackers; March to May 2026 from Vortexa; August 2026 loadings from Kpler. Estimates from different trackers are not strictly comparable.
That is the uncomfortable lesson in the data. Designations raise the cost of doing business with a target, and they can take years to bite. Physically stopping the ships works much faster. For how past supply shocks rippled through oil prices, see every oil crisis in history.
07 · The stock and the flowRussia Is Still the Biggest Name on the List
None of this means Russia has slipped off the list. The SDN list is a ledger of every past campaign, and far more goes onto it than ever comes off. Russia-related programs still account for 6,809 names on the current list, compared with 4,114 for Iran. What has changed is the flow, which is where policy actually shows up.
Removals are telling too. The biggest single clean-out in this period had nothing to do with either country: when the US lifted its Syria sanctions program on June 30, 2025, OFAC removed 518 names at once. Russia removals have been far smaller but steady, and in 2026 they have outnumbered Russia additions.
Every count here comes from the Treasury's own files. The Office of Foreign Assets Control has published a change file for every update to the SDN list since September 22, 2022. I read all of them, 527 files through October 21, 2026, and grouped each name by the sanctions program OFAC lists for it. The first file loaded the entire existing list and is left out of the comparisons. A name tied to both a Russia and an Iran program counts in both. Counts include people, companies, ships and aircraft, so they run higher than counts of people and companies alone.
For three years the sanctions office was a Russia operation. Since the spring of 2025 it has been an Iran operation, adding names at a pace the Iran program had never seen while new Russia designations all but stopped. The list itself still says Russia, because sanctions are easy to add and slow to remove. The direction of travel says Iran.
Follow every addition and removal as it happens on the DaveManuel.com Sanctions Tracker.
Filed under: General Knowledge
