US sanctions VTB (already sanctioned on US Russia sanctions) for Iran sanctions evasion

15 September 2026

US sanctions VTB (already sanctioned on US Russia sanctions) for Iran sanctions evasionFly of Swallow Studio/Shutterstock.com

The US has added VTB Bank PJSC to its EO 13902 Iran sanctions list – press release. VTB is already subject to sanctions in the US; it was designated under the EO 14024 Russia harmful foreign activities sanctions regime in 2022, and the EO 13662 Russia-related sanctions regime in 2025. See our US-Russia pages for more information on these sanctions regimes.

EO 13902 targets sectors of the Iranian economy. VTB has been added to the Iran sanctions list because the US said it is involved in Iranian sanctions evasion through:

  • Establishing correspondent banking relationships with sanctioned Iranian financial institutions;
  • Taking steps to increase its presence in Iran;
  • Taking steps to move billions of frozen Iranian assets; and
  • Creating a settlement system for national currencies through correspondent accounts in Iranian rials and Russian roubles with the goal of increasing bilateral trade.

As with its designation under the US Russia sanctions regimes, the US Office of Foreign Assets Control said that designation under EO 13902 carries secondary sanctions risks, meaning OFAC may designate parties that provide material assistance, goods or services to or in support of VTB. See our US-Iran pages for more information on the EO 13902 Iran sanctions regime.

Michael O'Kane

Michael is Senior Partner at Peters & Peters Solicitors LLP. He has acted in many of the most high profile and sensitive business crime cases of the last 25 years, at Peters & Peters and as a prosecutor. Michael was called…

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