Overview
US Developments
OFAC Publishes Cuba Sanctions Regulations, CACR Amendments, FAQs, and Compliance Alert
On September 29, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the publication of the Cuba Sanctions Regulations, which implement the authorities established under Executive Order (“E.O.”) 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.” The Cuba Sanctions Regulations, 31 C.F.R. Part 516, authorize blocking sanctions against persons who operate in key sectors of the Cuban economy, support the Cuban government or sanctioned persons, engage in corruption or human rights abuses, or serve as senior officials of the Cuban government or associated blocked entities. The regulations also authorize secondary sanctions against foreign financial institutions that facilitate significant transactions for sanctioned persons and provide for related visa restrictions.
Additionally, OFAC amended the Cuban Assets Control Regulations (“CACR”), 31 C.F.R. Part 515, to implement portions of the Trump Administration’s Cuba policy. In particular, OFAC expanded restrictions on entities on the State Department’s Cuba Restricted List (“CRL”) by prohibiting both direct and indirect transactions with listed entities. OFAC also broadened the criteria for adding entities and subentities to the CRL and eliminated or amended several authorizations under the CACR, including:
- OFAC eliminated the general license authorizing Cuba-related “U-turn” transactions, meaning US financial institutions may no longer process certain Cuba-related transfers that originate and terminate outside the US;
- OFAC removed the authorization allowing US financial institutions to maintain accounts for Cuban independent private-sector entrepreneurs and now requires a specific authorization to unblock related funds; and
- OFAC narrowed general licenses (“GLs”) for educational travel and travel related to professional meetings and conferences in Cuba, subject to limited grandfathering and wind-down provisions.
OFAC issued new and amended Frequently Asked Questions to reflect the regulatory changes. OFAC also published an alert highlighting increased sanctions risks associated with Cuba-related transactions, particularly those involving CRL entities and indirect financial dealings that may implicate the amended regulations. We provide further analysis of these changes to the Cuba sanctions program in a recent blog post.
OFAC Targets Iran’s Industrial Sectors
On October 1, OFAC issued a sectoral sanctions determination covering Iran’s automotive and rail sectors, enabling action against persons determined to operate in either of those sectors. The determination was issued pursuant to E.O. 13902, which enables sanctions on entities or individuals operating in certain sectors of the Iranian economy.
On the same day, OFAC sanctioned 30 parties linked to Iran’s automotive, rail, manufacturing, financial, or metals sectors, including companies based in Hong Kong, China, the UAE, Indonesia, Türkiye, and Germany. The designations were taken pursuant to E.O. 13902, which targets several sectors of the Iranian economy, and E.O. 13871, which targets Iran’s iron, steel, aluminum, and copper sectors.
Notably, Hong Kong- and China-based actors accounted for 12 of the 30 designated parties. OFAC’s latest Iran-related designations were announced approximately one week after the US and China agreed to extend the so-called Busan Agreement. As discussed in our previous update, US Ambassador to China David Perdue stated that the US “made it very clear” to China that any direct or indirect assistance to Iran, including intelligence, parts, or military equipment, was “totally unacceptable.” The latest action suggests that the Trump Administration is likely to continue to sanction Chinese persons allegedly involved in sensitive sectors of the Iranian economy.
Treasury Takes Action Against Russian Banking Network
On October 1, the Treasury Department targeted A7 Network. The Treasury Department alleges that the A7 Network, a Russian shadow banking network, is used by the Iranian regime to evade sanctions and was created and backed by US-sanctioned persons. The A7 Network has purportedly developed a global web of “Sub-Agents,” companies that are structured to disguise payments linked to sanctioned sectors and persons as ordinary commercial activity.
Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed a rule that would prohibit transmittals of funds regarding transactions involving the A7 Network’s Sub-Agents. FinCEN also issued an alert to assist financial institutions in detecting, identifying, and reporting suspicious activity related to the A7 Network.
OFAC also sanctioned the A7 Network as a significant transnational criminal organization. OFAC had previously sanctioned entities that were allegedly part of the A7 Network on August 14, 2025.
OFAC Targets Iranian Military Procurement Networks Under Operation Economic Outcast
On September 29, OFAC designated ten individuals and entities as part of Operation Economic Outcast. The designations target procurement networks allegedly supporting Iran’s Ministry of Defense and Armed Forces Logistics (“MODAFL”). OFAC alleges that the designated parties facilitated the acquisition of weapons systems, dual-use components, and other military goods for MODAFL and its affiliates involved in Iran’s missile and UAV programs. This action was taken pursuant to E.O. 13382, which targets proliferators of weapons of mass destruction.
OFAC Amends the Iranian Transactions and Sanctions Regulations to Incorporate E.O. 13902
On September 29, OFAC issued a final rule amending the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 C.F.R. Part 560, to implement provisions of E.O. 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran.” The incorporated authorities authorize the blocking of persons who operate in specified Iranian economic sectors, engage in certain significant sector-related transactions, support persons blocked under the order, or are owned or controlled by, or act for or on behalf of, such persons.
OFAC Sanctions Network of Tren de Aragua
On September 30, OFAC designated nine individuals and two entities allegedly involved in a fraud scheme linked to Tren de Aragua (“TdA”), a Venezuelan transnational criminal organization. According to OFAC, the network targeted US-based automated teller machines (“ATMs”) and used malware to force ATMs to dispense millions of dollars from US financial institutions.
TdA was designated as a Foreign Terrorist Organization by the Department of State on February 20, 2025, for alleged criminal activity including drug trafficking, human trafficking, extortion, and murder-for-hire. OFAC says the latest action is part of a larger campaign that has resulted in over 30 actions against more than 300 targets linked to transnational criminal organizations since 2025.
The action was taken pursuant to E.O. 13581, which blocks the property of transnational criminal organizations, and E.O. 13224, which blocks the property of those who commit or support terrorism.
OFAC Sanctions Sinaloa Cartel Leadership and Networks
On September 29, OFAC designated 25 entities and 21 individuals allegedly linked to the Sinaloa Cartel. The action targeted alleged cartel leadership, financial facilitators, money laundering networks, and corrupt public officials in Mexico’s Baja California region. The action was taken pursuant to E.O. 14059 and E.O. 13224.
OFAC’s designations included Ismael Zambada Sicairos, the alleged current leader of Los Mayos, as well as several of his close associates allegedly involved in drug trafficking, money laundering, extortion, and violence on behalf of the cartel.
OFAC also targeted the cartel’s alleged money laundering and corruption networks, including operators of currency exchanges, real estate ventures, security companies, and entertainment businesses allegedly used to launder money. OFAC also designated several current and former Mexican officials and political figures accused of facilitating cartel activities through bribery, influence, and corruption, including individuals allegedly connected to the cartel-controlled Mexicali trafficking corridor.
OFAC Sanctions Hamas Financing Network
On October 2, OFAC designated three individuals and two entities as part of efforts to target Hamas’s financial network. Specifically, OFAC sanctioned a Gaza-based member of the Hamas military wing and two France-based individuals and their affiliated charities for allegedly supporting Hamas’s fundraising activities. OFAC alleges that the two charities were part of a network that raised over $2 million in funds for Hamas through “deceptive charitable fronts and cryptocurrency channels.” This action was taken pursuant to E.O. 13224, as amended.
OFAC Expands Scope of Three Venezuela-Related GLs to Include Methanol
On September 28, OFAC issued three amended Venezuela-related GLs in order to add methanol to the list of Venezuelan petrochemical products subject to various authorizations under GL 46E, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;” GL 48D, “Authorizing the Supply of Certain Items and Services to Venezuela;” and GL 49B, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela.” We previously covered the scope of these licenses in our February 2 and February 18 updates.
UK Developments
UK Amends Shah Deniz General Licence Following Introduction of New Iran Sanctions
The UK has amended General Licence INT/2025/7363752, which permits certain activities necessary for the continued operation of the Shah Deniz gas project, to reflect the new Iran sanctions that entered into force on September 29, 2026. The amendment brings within the licence the newly introduced prohibitions under regulations 17A (investments in relation to Iran) and 17C (insurance and reinsurance services) of the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019. These restrictions were introduced by the Iran (Sanctions) (Amendment) Regulations 2026 as part of the UK’s wider reintroduction of sectoral sanctions on Iran. In parallel, the Office of Trade Sanctions Implementation (OTSI) has issued a new General Trade Licence for services necessary for the continued operation of the Shah Deniz project, also effective from September 29, 2026. Together, the licences provide targeted authorisations intended to enable the Shah Deniz project to continue operating notwithstanding the expanded financial and trade restrictions applicable to Iran. Businesses involved in the project should consider the application of the licences to their activities and familiarise themselves with the conditions associated with use of the licences.
OFSI Clarifies Application of New Licensing Approach for Designated Iranian Banks
OFSI has updated FAQ 204 to clarify the scope of the new licensing approach for designated Iranian banks. As previously reported, applications involving these banks will generally be refused unless required by law or there are exceptional and urgent circumstances justifying an exception, such as risks to life or environmental safety, essential regulatory payments, asset preservation or the wind-down of operations. OFSI has now confirmed, for the avoidance of doubt, that this approach will apply not only to new applications but also to all licence applications that remain open. Applicants with pending applications involving any of the five banks should therefore reassess them against the more restrictive criteria and consider whether additional information is required to demonstrate that their circumstances justify an exception to the presumption of denial.
OFSI Launches 2026 Frozen Asset Review
OFSI has published its updated notice for the 2026 Frozen Asset Review, requiring all persons holding funds or economic resources owned, held or controlled by a designated person to submit a report to OFSI by November 30, 2026. Reports must capture the value of relevant assets as at close of business on September 30, 2026, and cover assets frozen in the UK as well as assets held overseas where they are subject to UK financial sanctions legislation. For shares, securities and other debt or payment instruments, the value must be reported in GBP. Importantly, the obligation applies even where the relevant frozen assets have previously been reported to OFSI, meaning firms must make a fresh return for the 2026 review. Returns must be submitted using OFSI’s updated 2026 reporting template, which has changed since last year, and should not be submitted before the September 30 valuation date. Firms holding or administering frozen assets should therefore ensure that they identify all reportable assets, apply the required valuation date and use the latest template ahead of the November deadline.
OTSI Publishes General Trade Licences for Russian LNG Supplies to Japan and South Korea
OTSI has published two new General Trade Licences providing targeted, time-limited authorisations for UK involvement in the maritime transportation of Russian LNG to Japan and South Korea under specified pre-existing contractual arrangements. The licences follow the UK’s introduction in May 2026 of restrictions on UK involvement in the maritime transportation of Russian LNG, which from January 1, 2027, will extend to trade conducted under long-term contracts concluded before June 17, 2025. The licences permit UK involvement in Japanese and South Korean imports of LNG from the Sakhalin-2 Project where the supply contract was concluded before June 17, 2025, and the imports take place between January 1, 2027, and March 31, 2028, provided all applicable conditions are satisfied. They do not authorise trade under new contracts or transactions involving UK designated persons. The UK Government describes the measures as temporary support for the energy security of Japan and South Korea while those countries reduce their reliance on Russian energy, and businesses seeking to rely on the licences should carefully assess the applicable conditions and relevant contractual arrangements before doing so.
UK Announces New Russia Sanctions Targeting Energy Revenues, Disinformation and Human Rights Abuses
The UK Government has announced a further package of 31 sanctions measures against Russia, comprising the designation of 22 individuals and one entity and the specification of eight vessels under the Russia (Sanctions) (EU Exit) Regulations 2019. According to a UK Government press release, the package targets a range of actors and activities supporting Russia’s war against Ukraine, including LNG shadow fleet vessels, Kremlin-linked disinformation networks and individuals accused of involvement in the torture of Ukrainian civilians and the deportation and indoctrination of Ukrainian children. The 23 designated individuals and entities are subject to asset freezes, trust services sanctions and director disqualification sanctions, with the individuals additionally subject to travel bans, while the eight vessels face shipping and trade sanctions. The measures reflect the UK’s continued focus on restricting Russian energy revenues and the infrastructure supporting sanctions circumvention, while increasingly using the Russia sanctions regime to target disinformation activities and individuals associated with alleged abuses in occupied Ukrainian territory. A further two vessels also have been specified for their involvement in supporting the Government of Russia.
OFSI Extends Sakhalin-2 Permissions under Two Russia General Licences
OFSI has amended two General Licences relating to Russian oil and the Sakhalin-2 Project, extending the relevant Sakhalin-2 expiry dates to December 31, 2026. The amendments apply to the Oil Price Cap: Exempt Projects and Countries General Licence (INT/2022/2470156) and the Russian Oil Exempt Projects General Licence (INT/2025/5635700). The former provides targeted exemptions from aspects of the UK’s Russian oil services restrictions for specified projects and countries, while the latter permits certain business operations and transactions that would otherwise be prohibited under the Russia sanctions regime where they relate to specified exempt energy projects. The extension maintains the existing authorisations relating to Sakhalin-2 for a further limited period and follows other recent UK measures providing targeted exemptions for activities connected with the project. Persons seeking to rely on either General Licence should review the amended terms carefully to confirm the applicable permissions, conditions and reporting or record-keeping requirements.
EU Developments
EU Council Adopts New Listings Targeting the Unlawful Deportation of Ukrainian Children
The EU Council designated an additional 10 individuals and 17 entities under the EU sanctions regime in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The new listings target those responsible for the systematic unlawful deportation, forcible transfer, and forced assimilation of Ukrainian children to the Russian Federation and within temporarily occupied territories of Ukraine.
Among the individuals listed are Rustam Minnikhanov, President of the Republic of Tatarstan, for facilitating the illegal deportation of Ukrainian children to camps in the Tatarstan region, as well as education ministers and deputy ministers from Russian-occupied territories of Ukraine, the Minister of Sports and Tourism of the self-proclaimed Donetsk People’s Republic, and directors of children’s camps and schools involved in programs contributing to the ideological indoctrination and militarized education of Ukrainian children.
The entities listed include the Songdowon International Children’s Camp, a state-operated institution in the Democratic People’s Republic of Korea, which participates in organized programs involving the transfer of Ukrainian children from temporarily occupied territories of Ukraine in coordination with the Russian Federation. The listings also include a federal educational institution operating under Russia’s Ministry of Education, as well as children’s camps, sports centers, recreation, and tourism companies involved in cultural reorientation, propaganda-based education, and military-patriotic activities aimed at integrating children into Russian identity frameworks.
EU Council Adds Ten Individuals to Russia Human Rights Sanctions List
The EU Council amended Council Decision (CFSP) 2024/1484, adding ten individuals to the sanctions list for their responsibility in serious human rights violations, the repression of civil society and democratic opposition, and activities undermining democracy and the rule of law in Russia.
The newly listed individuals include three judges of the Supreme Court of the Russian Federation, an official in the Prosecutor General’s Office, and an official of the Central Election Commission of Russia involved in proceedings that resulted in the Yabloko political party being barred from participating in the September 2026 elections to the State Duma. Yabloko was the only political party that openly opposed Russia’s war of aggression against Ukraine. The listings also target a judge and a state prosecutor involved in the prosecution of Lev Shlosberg, a Yabloko opposition politician who was sentenced to 11 years and one month of imprisonment on charges linked to his public criticism of Russia’s war of aggression against Ukraine, as well as prosecutors and judges involved in proceedings against Yabloko leaders Maxim Kruglov and Nikolai Rybakov.
Following the latest listings, the EU’s Russia human rights sanctions regime now applies to 108 individuals and seven entities.
European Commission Publishes Updates to its FAQs on Sanctions Against Russia
The European Commission recently published a series of updates to its FAQs on sanctions against Russia. The revisions concern the sections on the movements of Russian diplomats, asset freezes and the prohibition to provide funds or economic resources, as well as export-related restrictions on dual-use goods and advanced technologies. The revised FAQs now include clarifications on whether travel plans are affected by events of force majeure under Articles 5v and 5w of Council Regulation (EU) 833/2014 and on the scope of the exemption for JSC Russian Railways introduced by Article 6g of Council Regulation (EU) 269/2014. In addition, the Commission updated its Correlation Table, which includes references correlating the goods in Annex VII to Council Regulation 833/2014 with the corresponding commodity codes as defined under the rules of the Common Customs Tariff and Combined Nomenclature (CN).
Lastly, the Commission updated its guidance on the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts under Council Regulation (EU) 2022/263, clarifying whether grain originating in non-government-controlled areas of Ukraine in those oblasts may transit through the EU.
EU Council Renews Burundi Sanctions Regime
On September 28, the EU Council renewed the restrictive measures in view of the situation in Burundi for another year, until October 31, 2027. The sanctions regime, originally established in 2015, targets individuals and entities responsible for undermining democracy or obstructing the search for a political solution in Burundi, as well as those involved in serious human rights violations and abuses.
EU Council Amends Sanctions Regime Targeting the Democratic Republic of Congo
The EU Council amended the sanctions regime in view of the situation in the Democratic Republic of the Congo (DRC), following an update at the UN level. Changes to Council Decision 2010/788/CFSP follow a July 14 decision of the UN Security Council Sanctions Committee to add six individuals and two entities to the sanctions list. As a result, four individuals and one entity already designated under the sanctions regime were transferred from Annex II to Annex I of Council Decision 2010/788/CFSP. The Alliance Fleuve Congo (AFC), a politico-military movement operating in eastern DRC, was also transferred to Annex I of Council Decision 2010/788/CFSP.
Asia-Pacific Developments
Cambodia Pledges Stronger Anti-Scam Cooperation Amid US Sanctions Scrutiny
Cambodia concluded an international conference on combating online scams with participating countries agreeing to strengthen cross-border cooperation against cyber fraud, human trafficking, and transnational criminal networks. During the event, Deputy Prime Minister Neth Savoeun emphasized that no country can effectively tackle technology-enabled scams on its own and stressed the importance of international collaboration. The conference took place against the backdrop of calls from US congressional leaders for an investigation into whether certain senior Cambodian officials should face sanctions over alleged links to scam operations, allegations that Cambodian officials have denied. Discussions focused on emerging fraud trends, cybersecurity, artificial intelligence, financial investigations, and trafficking networks, while participating countries endorsed a voluntary declaration encouraging information sharing, confiscation of criminal proceeds, and stronger protection for trafficking victims.
EU Sanctions Disrupt Money Transfers Between Russia, Kazakhstan and Georgia
Cross-border money transfers between Russia and neighboring countries, particularly Kazakhstan and Georgia, fell dramatically after the EU sanctioned the operator of the Zolotaya Korona payment system in July 2026. According to regulatory data, transfers from Russia to Kazakhstan dropped nearly twelvefold in August, while flows in the opposite direction declined even more sharply; transfers between Russia and Georgia also plunged to historically low levels, with transfers from Georgia to Russia reportedly falling to zero for the first time on record. The decline has been attributed to the sanctions’ impact on Zolotaya Korona, which had become one of the primary channels for international money transfers involving Russians after the withdrawal of major Western payment providers following Russia’s invasion of Ukraine. Once among the few large Russian payment systems still operating without sanctions restrictions, Zolotaya Korona has since suspended transfer services to several countries, significantly disrupting a key financial link used by Russian citizens, including those living abroad.
Japan Considers Expanded Sanctions on Russia
Japan is exploring additional sanctions against Russia as part of its response to Moscow’s continued war in Ukraine and Russian President Vladimir Putin’s recent visit to Etorofu Island, one of the disputed Northern Territories claimed by Japan. The measures under consideration would primarily target Russia’s “shadow fleet” of vessels used to evade existing sanctions and transport Russian energy exports, a critical source of revenue for the Russian economy. Japanese authorities are also evaluating tighter export controls and expanding the range of goods subject to export restrictions. The move would align Japan more closely with European countries that have recently stepped up economic pressure on Russia and reinforce Tokyo’s position that Russia’s actions violate international law.
Japan Further Eases Syria Sanctions
Japan has approved the removal of sanctions on 16 organizations linked to Syria, citing their potential role in supporting the country’s reconstruction and long-term stability. The decision forms part of Tokyo’s gradual relaxation of Syria-related restrictions following the collapse of the regime of former President Bashar al-Assad in 2024 and reflects Japan’s assessment of developments under Syria’s new government. Chief Cabinet Secretary Minoru Kihara stated that Syria’s stability is closely connected to broader stability in the Middle East and emphasized Japan’s commitment to supporting reconstruction efforts. Despite the latest easing measures, Japan continues to maintain sanctions on 59 individuals and 15 entities. The move builds on earlier steps, including the lifting of sanctions on four Syrian entities in 2025, while preserving restrictions originally imposed in response to the Assad government’s crackdown on anti-government demonstrations beginning in 2011.
India Presses US Lawmakers on Sanctions Concerns
India has expressed its concerns to the US regarding the recently enacted Sanctioning Russia and Iran Act (SRIA), arguing that the legislation could have significant consequences for both bilateral relations and the stability of global energy markets. During discussions in New Delhi with a bipartisan US congressional delegation led by Brian Mast, Chairman of the House Foreign Affairs Committee, Foreign Secretary Vikram Misri emphasized that the law’s provisions, which allow the US President to impose tariffs of up to 100% on countries purchasing Russian oil and gas, could disrupt established trade and energy arrangements and create broader economic uncertainty. Indian officials stressed that the country’s concerns extend beyond the direct impact on India, encompassing potential repercussions for international energy security and global market dynamics.
New Zealand Expands Enforcement of North Korea Sanctions
New Zealand has stepped up its role in enforcing UN sanctions on North Korea by deploying a Royal New Zealand Navy task group to conduct maritime surveillance operations in the Yellow Sea and East China Sea. As part of the multinational Pacific Security Maritime Exchange, the deployment aims to identify and report activities designed to evade sanctions targeting North Korea’s nuclear and ballistic missile programs. For the first time, the frigate Te Mana participated in sanctions-monitoring operations, tracking vessels suspected of transporting prohibited cargoes or engaging in illicit ship-to-ship transfers. The mission also focused on detecting common sanctions-evasion techniques, including AIS manipulation, vessel identity concealment, position spoofing, and the use of “shadow fleet” vessels.
Australia Targets Kadyrov-Linked Foundation Over Ukraine War
Australia has imposed sanctions on the Akhmat Kadyrov Foundation as part of a broader package targeting individuals, organizations, and vessels linked to Russia’s war in Ukraine. The foundation, headed by Aimani Kadyrova, mother of Chechen leader Ramzan Kadyrov, was added to Australia’s sanctions list alongside dozens of other entities associated with Russia’s military, financial, and administrative apparatus. Although Canberra did not provide a detailed justification specific to the foundation, it stated that the measures are intended to address activities undermining Ukraine’s sovereignty and territorial integrity. While the foundation presents itself as a charitable organization, reports indicate that since the start of the war it has directed substantial resources toward supporting Russian military operations and related projects in Ukraine. The move aligns Australia with several Western governments, including the US, EU, UK, and Canada, which have previously sanctioned the foundation over its alleged involvement in activities connected to the war and the treatment of Ukrainian children.
Iran Signals Nuclear Inspections-for-Sanctions Deal
Iran has reportedly indicated a willingness to restore access for international nuclear inspectors to facilities damaged during recent military strikes if it receives meaningful sanctions relief in return, suggesting a possible path to revive stalled negotiations with the US. During discussions on the sidelines of the UN General Assembly, Iranian Foreign Minister Abbas Araghchi raised the proposal with European and Middle Eastern counterparts, reflecting mounting economic pressure on Iran from sanctions and restrictions on its oil exports. The initiative would represent a significant concession, as international monitoring of Iran’s nuclear program has been severely curtailed in recent years. However, major obstacles remain, including Iran’s demand that broader international sanctions be eased and continued reluctance from Western governments to make such commitments.
Pakistan Balances Iran Ties and US Sanctions Pressure
Pakistan has signaled a more cautious stance toward new US sanctions on Iran, with its Foreign Office stating that the country will comply with all sanctions regimes applicable under international and domestic law. While Islamabad has not adopted US sanctions or suspended trade with Iran, the shift reflects growing concern over the financial and regulatory risks associated with dealings involving sanctioned Iranian entities, particularly for banks and cross-border transactions. At the same time, Pakistan continues to emphasize its strategic relationship with the US, maintain ties with Iran, and support diplomatic dialogue between Washington and Tehran, seeking to balance its competing foreign policy and economic interests.
