US extends Iran sanctions authority to VTB Bank, heightening secondary sanctions risk

WASHINGTON, September 14, 2026 — The US Treasury Department’s Office of Foreign Assets Control designated Russia’s VTB Bank under Executive Order 13902 for operating in Iran’s financial sector, adding another sanctions authority to a bank already subject to comprehensive US restrictions.

The significance of the action is primarily the increased risk for non-US financial institutions dealing with VTB. The bank has already been subject to full US blocking sanctions under Executive Order 14024 since February 2022, meaning the new designation does not materially change the prohibition facing US persons.

Treasury said foreign financial institutions that continue to deal with VTB following its designation under Iran sanctions authorities face greater sanctions exposure and should terminate those relationships. Such institutions could face restrictions on their access to US correspondent or payable-through accounts if they knowingly facilitate significant transactions for a sanctioned person.

Treasury said VTB established correspondent relationships with sanctioned Iranian financial institutions, expanded its presence in Tehran and developed mechanisms to settle transactions in Russian rubles and Iranian rials. The bank also took steps to move billions of dollars in frozen Iranian assets, according to Treasury.

OFAC also updated VTB’s entry on the Sectoral Sanctions Identifications List, or SSI List, rather than removing it. VTB therefore remains subject to Directive 1 under Executive Order 13662, which restricts certain dealings involving its debt and equity.

The updated SSI entry now also carries the Iran-EO13902 sanctions tag, identifies a Tehran location and states that VTB is subject to secondary sanctions. Its existing Russia-related authorities under Executive Orders 13662 and 14024 remain in place.

For US persons, VTB’s SDN designation already imposes broader blocking restrictions than its sectoral sanctions status. The continued SSI listing nevertheless preserves the historical Directive 1 restrictions, while the addition of the Iran authority further increases the compliance and secondary sanctions risks for foreign banks and other non-US counterparties.