On August 24, 2026, the Office of Foreign Assets Control (OFAC) indefinitely suspended five Iran-related general licenses under its Iranian Transactions and Sanctions Regulations. If your fintech processes remittances, educational payments, or conference-related transactions, you must update your sanctions policy documentation immediately. The wind-down period ended on September 8, 2026, meaning any transaction relying on those licenses is now prohibited unless you've secured a specific license from OFAC.
This template helps you document the policy change, communicate it to your team, and create an audit trail showing you responded appropriately.
Purpose of the Template
Use this template to:
- Update your written sanctions compliance policy to reflect the suspended licenses.
- Document your operational response to OFAC's action.
- Create a record that your compliance program adapted to regulatory changes.
- Brief your transaction monitoring, customer service, and operations teams on what changed and why.
The template covers three documents: a policy amendment, an internal operational memo, and a customer communication script. Customize each based on which suspended licenses affect your business.
Prerequisites
Before using this template, confirm:
Which licenses matter to you. The five suspended licenses are 31 CFR 560.544 (educational activities in third countries), 31 CFR 560.550 (noncommercial personal remittances), 31 CFR 560.554 (conference services), Iran GL-F (sports activities), and Iran GL-G (academic exchanges). If you don't process any of these transaction types, document that determination.
Your current Iran exposure. Run a query for all transactions in the past 12 months involving Iran as an originator or beneficiary country. Segment by transaction type (personal remittance, tuition payment, conference fee, etc.).
Your sanctions policy version control. Know your current policy version number and amendment process. If you don't have formal version control, start now.
The Template
Document 1: Sanctions Policy Amendment
[Company Name] Sanctions Compliance Policy
Amendment [X]: OFAC Iran General License Suspension
Effective Date: August 24, 2026
Policy Owner: [MLRO/Compliance Officer Name]
Summary of Change:
OFAC indefinitely suspended five Iran-related general licenses effective August 24, 2026, as part of Operation Economic Outcast. This amendment prohibits transaction types previously authorized under those licenses.
Affected General Licenses:
- 31 CFR 560.550 (noncommercial personal remittances to/from Iran)
- 31 CFR 560.544 (educational activities in third countries)
- 31 CFR 560.554 (conference-related services)
- Iran GL-F (sports activities and exchanges)
- Iran GL-G (academic exchanges and educational services)
Policy Update:
Section [X.X] of the Sanctions Compliance Policy is amended to read:
"[Company Name] does not process transactions to, from, or involving Iran, except where specifically authorized by a valid OFAC license. The following transaction types are prohibited as of August 24, 2026:
- Personal remittances to or from Iranian individuals or entities
- Payments related to educational activities involving Iran (including tuition, fees, or conference costs)
- Services supporting sports or academic exchanges with Iranian counterparties
Previously, certain of these transactions were authorized under OFAC general licenses. Those licenses are suspended indefinitely. Any customer requesting such a transaction must be informed that it requires a specific license from OFAC, which [Company Name] does not possess."
Implementation Requirements:
- Transaction monitoring rules updated to block Iran-related transactions (completed by: [date])
- Customer-facing teams briefed on suspension (completed by: [date])
- Sanctions screening configuration reviewed for Iran-related entities (completed by: [date])
Approval:
[MLRO Signature] [Date]
[Chief Compliance Officer Signature] [Date]
Document 2: Internal Operational Memo
TO: Customer Operations, Transaction Monitoring, Sanctions Screening Team
FROM: [MLRO/Compliance Officer]
DATE: [Date]
RE: OFAC Iran General License Suspension, Operational Impact
Background:
OFAC suspended five Iran-related general licenses on August 24, 2026. The wind-down period ended September 8, 2026. Any transaction that relied on these licenses is now prohibited unless the customer holds a specific OFAC license.
What Changed:
We can no longer process:
- Personal remittances to/from Iran (previously authorized under 31 CFR 560.550)
- Educational payments involving Iran (previously authorized under 31 CFR 560.544 and Iran GL-G)
- Conference-related payments involving Iran (previously authorized under 31 CFR 560.554)
- Sports or academic exchange payments involving Iran (previously authorized under Iran GL-F)
Immediate Actions:
- Transaction Monitoring: All Iran-related transactions flagged for manual review. Do not release any payment to/from Iran without MLRO approval.
- Customer Service: If a customer requests an Iran-related transaction, use the script in Section 3 below. Do not attempt to process the transaction.
- Sanctions Screening: Iran remains a comprehensively sanctioned jurisdiction. Screening logic unchanged, but additional manual review required for any Iran match.
Escalation:
Any customer claiming they have a specific OFAC license must provide the license number and a copy of the license document. Escalate immediately to [MLRO email/phone].
Document 3: Customer Communication Script
Scenario: Customer attempts to send a personal remittance to Iran or requests a payment related to Iranian educational/conference activities.
Script:
"I understand you'd like to send this payment to Iran. Unfortunately, as of August 24, 2026, OFAC suspended the general license that previously allowed certain personal remittances and other transactions involving Iran. We're no longer able to process this type of transaction unless you hold a specific license from OFAC.
If you believe you qualify for a specific license, you can apply directly to OFAC through their online portal. You'll need to provide details about the transaction and the reason for the payment. If OFAC grants you a license, please provide us with the license number and a copy of the approval, and we'll be able to assist.
I can provide you with OFAC's contact information if that would be helpful. Is there anything else I can help you with today?"
Do NOT:
- Suggest workarounds or alternative payment routes
- Process the transaction "just this once"
- Advise the customer on their likelihood of receiving a specific license
Do:
- Document the customer's request in [CRM/ticketing system]
- Note that you provided this script and the customer's response
- Escalate to [MLRO] if the customer becomes hostile or claims urgency
How to Customize It
For Document 1 (Policy Amendment):
- Replace bracketed placeholders with your company name, policy section numbers, MLRO name, and implementation dates.
- If you don't process certain transaction types (e.g., you're not in the remittance business), delete those bullet points but keep the overall prohibition language.
- Adjust the "Implementation Requirements" section to match your actual control updates. If you don't have transaction monitoring rules, replace that line with "Manual review process implemented for all Iran-related inquiries."
For Document 2 (Internal Memo):
- Tailor the "Immediate Actions" section to your operational structure. If you don't have a transaction monitoring team, address the memo to whoever reviews transactions manually.
- Add specific system names (e.g., "Flag all Iran transactions in [Sanctions Screening System Name] for manual review").
For Document 3 (Customer Script):
- Adjust tone to match your brand voice, but don't soften the core message: you can't process the transaction.
- If your customer service team uses a different documentation system, replace "[CRM/ticketing system]" with the actual tool name.
Validation Steps
After you implement this template:
Spot-check your transaction monitoring. Simulate an Iran-related transaction in your test environment. Confirm it's blocked or flagged for manual review. If it processes automatically, your rule logic isn't working.
Audit your policy repository. Verify that the amended policy is the current version in your document management system. Old versions should be archived, not deleted.
Test your team's knowledge. Within two weeks of issuing the memo, ask three random customer service reps: "A customer wants to send $500 to their cousin in Tehran. What do you tell them?" If they don't reference the license suspension or use language close to the script, you need additional training.
Review your audit trail. If an examiner asks, "How did you respond to the August 2026 OFAC Iran license suspension?", you should be able to produce: (a) the dated policy amendment, (b) the internal memo with a distribution list, (c) evidence of transaction monitoring rule updates, and (d) documentation of any customer inquiries you declined.
If you can't produce all four, your compliance program has a documentation gap. Fix it before your next exam.
