I. Iran: the US Treasury changes scale

On 24 August, OFAC launched what the Treasury presents as an unprecedented economic campaign against Tehran, under the name Operation Economic Outcast. Some sixty persons, entities and vessels were added to the SDN list on the same day, on the combined basis of Executive Orders 13382 (proliferation), 13224 (terrorism), 13694 (cyber activities) and 13902, together with five new sectoral determinations covering digital assets, technology, gold, aviation and shipping. Five tankers of the Iranian shadow fleet are among the targets, alongside intermediaries based in Hong Kong, the United Arab Emirates and Singapore. Several general licences were suspended, including those covering sporting and academic exchanges, with two new licences (AA and BB) partly replacing them. A second wave of Iran-related and counter-terrorism designations followed on 28 August.

One point will catch the attention of French practitioners: the designated entities include a refining company based in the Nièvre department, La Nivernaise de Raffinage SAS. This is not a minor entry on a list. The designation of a French SME under an Iran programme confirms that exposure to secondary sanctions is no longer confined to large groups involved in oil flows. It now reaches operators whose link with Iran runs through seemingly ordinary supplies, via two or three intermediaries that standard screening does not trace back.

Business implications. Rerun the screening of counterparties and vessels against the lists of 24 and 28 August, and review the sanctions clauses in contracts currently being performed.

II. Syria: removal of the state sponsor of terrorism designation

On the same day, the State Department rescinded Syria’s designation as a state sponsor of terrorism, a decision published in the Federal Register on 31 August. Syria thus falls outside the Terrorism List Governments Sanctions Regulations (31 CFR Part 596). Hay’at Tahrir al-Sham was then removed from the SDGT and SDN lists, and Syria General License 25, now redundant, was revoked. On export controls, the de minimis threshold for US content rises from 10 to 25%, which gives more room to European exporters whose products incorporate US components.

The opening is real, but it is not general. Individual designations remain in place, and nothing in this decision can be read as a normalisation of trade relations with Damascus. Calculating the threshold product by product remains the first precaution before any shipment.

III. Venezuela: a controlled reopening of oil, mining and telecommunications

On 27 August, OFAC reissued eight Venezuela general licences: GL 46D (oil and petrochemical products), 47B (diluents of US origin), 48C and 61A (goods and services, including telecommunications), 50C and 52B (transactions involving PDVSA), 51C (minerals including gold) and 54B (mining activities), with two new FAQs. The direction is clear: Washington is reopening by licence what it had closed by designation.

IV. Counter-terrorism: three European entities on the SDN list

On 26 August, OFAC designated Palestine Action, described as a transnational terrorist group, the Masar Badil network, active in Germany, Belgium, Spain, Brazil and Canada, and the Italian hosting provider Autistici Inventati, with General License 36 authorising the wind-down of ongoing transactions with the latter. On the same day, Russia General License 104B was issued for certain imports of diamonds prohibited by Executive Order 14068.

Business implications. The designation of a technical service provider established in the Union puts European banks and hosting providers in the now familiar position of a conflict of laws, between the US asset freeze obligation and the Blocking Regulation (EC) No 2271/96. The practical rule has not changed: document the decision, never improvise it.

V. North America: Section 338 revived, Ottawa retaliates

After US duties of 50% under Section 338 of the Tariff Act of 1930 came into force on 22 August, targeting in particular Canadian dairy products, alcoholic beverages and motor vehicles, Ottawa announced equivalent countermeasures on 25 August. The rates are 15, 25 or 50% depending on the product, on around 27.6 billion Canadian dollars of US imports: steel, dairy, household appliances, farm machinery, pulp and electronics. They take effect on 8 September.

Section 338, virtually a dead letter since 1930, has become the third pillar of US tariff policy since the Supreme Court struck down the IEEPA duties on 20 February: quicker than Section 232 and less procedural than Section 301. For that very reason, it is also the most fragile in law. It will be challenged.

VI. Imminent deadline: Section 232 duties on drones

The proclamation of 13 August targets unmanned aircraft systems and their components. From 3 September 2026, the rate is 100% for aircraft over 25 kg, thermal imaging drones, docking stations and Annex I components, and 25% for lighter aircraft. Products originating in the Union benefit from a 15% ceiling under the EU-US joint statement (10% for the United Kingdom), provided that almost all critical components, software and technologies come from eligible jurisdictions. A third wave, covering Annex III components, will take effect on 9 February 2027.

VII. Europe and France: a week without new texts

The summer lull held to the end. No significant act was found in the Official Journal of the Union on trade policy or restrictive measures between 24 and 30 August, and the Court of Justice, in judicial vacation until 1 September, delivered no judgments. The files therefore stand as they were. The EU-Mercosur interim agreement continues to apply provisionally, its ratification still awaiting the opinion of the Court of Justice, to which the European Parliament referred it in January. The reform of the Union Customs Code, on which political agreement was reached on 26 March, awaits formal adoption and the setting up of the EU customs authority. The reinforced steel safeguard in force since 1 July, with reduced quotas and a 50% out-of-quota duty, is producing its first effects.

In France, the customs code recodified by Ordinance No. 2026-265 and Decree No. 2026-266 of 8 April has been in force since 1 May, and the ratification bill is continuing its passage following the opinion of the Conseil d’État. Nothing new on ICS2 and ANTES, NCTS phase 5 or the DELTA switchover. The coming week will move at a different pace: the Court of Justice returns, work resumes in Brussels, and the US duties on drones apply from 3 September.

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