Audit log

Every state-changing event for OFAC Operation Economic Outcast — Iran Digital Assets Sectoral Sanctions August 2026: moderation decisions on community submissions, plus corrections and updates from the news pipeline. URL-based decisions are designed to carry three independent witnesses — the original source, an Internet Archive snapshot, and a Solana memo signed by our publicly-disclosed publisher key. Archive coverage is still being backfilled, so each decision below reports its own snapshot status rather than assuming one exists.

1. #1publishby system:backfill

   2026-08-26 12:09:55Z
   Score: ? → ? (no score change)
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   {"actor":"system:backfill","investigation_id":"10136f6a-2bee-480a-8bf6-009e08eb7474","kind":"publish","page_slug":"ofac-operation-economic-outcast-iran-digital-assets-sectoral-sanctions-august-2026","published_at":"2026-08-26T12:09:55.588Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"OFAC Operation Economic Outcast — Iran Digital Assets Sectoral Sanctions August 2026","sections":[{"content":"Operation Economic Outcast was announced on August 24, 2026 by U.S. Treasury Secretary Scott Bessent, who described it as a 'whole-of-government economic campaign' aimed at severing every financial lifeline sustaining the Iranian regime. The legal vehicle is Executive Order 13902, signed in January 2020, which authorizes the President to sanction any person operating in specified sectors of the Iranian economy. Under the August 24 action, OFAC issued five sectoral determinations covering digital assets, technology, gold, aviation, and shipping. The digital assets determination is described by legal analysts as unprecedented in scope: it authorizes OFAC to designate any foreign person, wherever located, that operates in or provides material support to Iran's digital asset sector — a reach OFAC previously held only over Iran's financial and petroleum industries. According to law firm Foley Hoag, the determination 'inverts the normal sequence' of sanctions enforcement: exposure now attaches to the activity rather than to a pre-existing named designation, meaning a foreign exchange or infrastructure provider with Iranian nexus can carry secondary sanctions risk before any designation naming it has been issued.","heading":"Overview and Legal Authority","severity":"critical","sources":[{"credibility":1,"name":"Treasury Launches Unprecedented Campaign Against Iranian Regime — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0613"},{"credibility":2,"name":"Trump Administration Increases Sanctions Pressure on Iran through 'Operation Economic Outcast' — Foley Hoag LLP","type":"research","url":"https://foleyhoag.com/news-and-insights/blogs/white-collar-law-and-investigations/2026/august/trump-administration-increases-sanctions-pressure-on-iran-through-operation-economic-outcast/"},{"credibility":2,"name":"US Can Now Sanction Anyone Operating in Iran's Crypto Sector — Decrypt","type":"news_article","url":"https://decrypt.co/376424/us-can-now-sanction-anyone-operating-in-irans-crypto-sector"}]},{"content":"The digital assets sectoral determination is the centerpiece of Operation Economic Outcast from a crypto-industry compliance standpoint. Prior to August 24, 2026, OFAC's Iran enforcement in the crypto sector proceeded entity-by-entity: a specific exchange (e.g., Nobitex, Shelbit, Aban Tether) or individual would be named to the SDN list, and counterparties were then required to screen against that list. The August 24 sectoral determination changes this model. Under E.O. 13902, 'any person anywhere in the world operating in, engaging in any significant transaction with, or providing any assistance to anyone operating in those sectors may be designated as a blocked party,' according to Foley Hoag's analysis. The phrase 'significant transaction' is not defined with numerical thresholds in the determination, creating deliberate compliance ambiguity. According to Decrypt's reporting, the determination mirrors authority OFAC already held over Iran's financial and petroleum sectors, and countries receive individual timelines to cease Iran-related activity before secondary sanctions are imposed. TRM Labs notes that the practical effect is to place the compliance burden on the counterparty: a non-U.S. exchange that processes a significant transaction for any Iranian digital asset business — whether or not that business is individually SDN-listed — now risks losing access to the U.S. financial system.","heading":"Sectoral Determination: Digital Assets","severity":"critical","sources":[{"credibility":2,"name":"Operation Economic Outcast: Treasury Sanctions Nearly 60 Iran-linked Targets and Names Digital Assets a Sanctionable Sector — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/operation-economic-outcast-treasury-sanctions-nearly-60-iran-linked-targets-and-names-digital-assets-a-sanctionable-sector"},{"credibility":2,"name":"US Can Now Sanction Anyone Operating in Iran's Crypto Sector — Decrypt","type":"news_article","url":"https://decrypt.co/376424/us-can-now-sanction-anyone-operating-in-irans-crypto-sector"},{"credibility":2,"name":"Trump Administration Increases Sanctions Pressure on Iran through 'Operation Economic Outcast' — Foley Hoag LLP","type":"research","url":"https://foleyhoag.com/news-and-insights/blogs/white-collar-law-and-investigations/2026/august/trump-administration-increases-sanctions-pressure-on-iran-through-operation-economic-outcast/"},{"credibility":2,"name":"US Treasury Makes Iran's Digital Asset Sector Sanctionable in 60-Target Action — CryptoTimes","type":"news_article","url":"https://www.cryptotimes.io/2026/08/25/us-treasury-names-digital-assets-a-sanctionable-sector-of-irans-economy/"}]},{"content":"The August 24 action designated nearly 60 entities, individuals, and vessels. Key designations with crypto relevance include the following. Ivan Obukhov, a Ukrainian national based in the UAE and owner of Foscom FZE, was designated for allegedly processing over $100 million in cryptocurrency payments on behalf of the IRGC-Qods Force's oil sales since 2023, according to CryptoTimes and Decrypt. Mohammad Ahmed Suhil Fattouh (also known as 'Captain Hamzah'), a Syrian national, was also designated in connection with the oil payment network. On the cyber operations side, OFAC designated five individuals tied to the Mabna Institute — Mojtaba Ghal'eh-Kuhi, Behzad Mesri, Keyvan Fayyaz Ghareh Blagh, Saber Shahbazi Balujeh, and Mohammad Reza Kadkhoda'i — for alleged cyber intrusion activity on behalf of the IRGC and other Iranian government clients. Arman Kahzadian was designated separately as a cyber actor who allegedly gained control of a Bitcoin wallet containing over $30,000 in the summer of 2023, according to the Treasury press release. Other non-crypto designations in the same action included Hong Kong-based Sweet Ocean Industrial Limited, China-based individual Li Na, Singapore-based Wellbred Capital PTE. LTD., and multiple shadow fleet vessels (SIFRA, G SILVER, QUANTUM HOPE, VOYAGE ELITE, TELA) used in Iranian oil transport.","heading":"Designated Individuals and Entities","severity":"critical","sources":[{"credibility":1,"name":"Treasury Launches Unprecedented Campaign Against Iranian Regime — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0613"},{"credibility":2,"name":"US Treasury Makes Iran's Digital Asset Sector Sanctionable in 60-Target Action — CryptoTimes","type":"news_article","url":"https://www.cryptotimes.io/2026/08/25/us-treasury-names-digital-assets-a-sanctionable-sector-of-irans-economy/"},{"credibility":2,"name":"US Can Now Sanction Anyone Operating in Iran's Crypto Sector — Decrypt","type":"news_article","url":"https://decrypt.co/376424/us-can-now-sanction-anyone-operating-in-irans-crypto-sector"},{"credibility":2,"name":"OFAC Expands Iran Sanctions to Crypto Sector Under New Campaign — Blockchain.News","type":"news_article","url":"https://blockchain.news/news/ofac-iran-crypto-sanctions-2026"}]},{"content":"OFAC listed 30 cryptocurrency addresses associated with four Mabna Institute defendants as part of the August 24 action. The addresses span Bitcoin, Ethereum, and TRON networks. TRM Labs analyzed the 30 addresses and found approximately $16.8 million in total funds received between January 2018 and August 20, 2026. Activity was heavily concentrated: defendant Keyvan Fayyaz Ghareh Blagh controlled 10 addresses that received approximately $15.5 million, representing 92% of the network's total volume. Approximately $202,662 remained across all addresses at the time of TRM's analysis, indicating the vast majority of funds had been moved or disbursed. The Mabna Institute is described by the DOJ as an Iran-based cyber-mercenary organization that has operated since at least 2013, compromising 144 U.S. universities, 178 foreign universities, at least 42 U.S.-based private companies, and at least five U.S. federal and state government agencies. The FBI unsealed a superseding indictment charging 17 Mabna members on August 18, 2026 — the original indictment named nine defendants in 2018. Five of the 17 indicted individuals are among those designated in the August 24 OFAC action.","heading":"Mabna Institute Crypto Wallet Designations","severity":"critical","sources":[{"credibility":2,"name":"Operation Economic Outcast: Treasury Sanctions Nearly 60 Iran-linked Targets and Names Digital Assets a Sanctionable Sector — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/operation-economic-outcast-treasury-sanctions-nearly-60-iran-linked-targets-and-names-digital-assets-a-sanctionable-sector"},{"credibility":2,"name":"Mabna Institute moved $16.8M through crypto addresses since 2018, TRM Labs finds — Crypto Briefing","type":"news_article","url":"https://cryptobriefing.com/mabna-institute-crypto-addresses-trm-labs/"},{"credibility":1,"name":"DOJ secures indictment of 17 Iranians accused of 'massive' cyber theft campaign — DataBreaches.Net","type":"court_filing","url":"https://databreaches.net/2026/08/19/doj-secures-indictment-of-17-iranians-accused-of-massive-cyber-theft-campaign/"},{"credibility":2,"name":"US Sanctions 30 Crypto Wallets Tied to Iran's Mabna Institute, Tracing $16.8 Million — BigGo Finance","type":"news_article","url":"https://finance.biggo.com/news/24e4dffd-59cb-45c2-8fd1-0bfe6ead746c"}]},{"content":"A distinct strand of the August 24 action targeted an alleged cryptocurrency-for-oil payment scheme operated on behalf of the IRGC-Qods Force. According to CryptoTimes and Blockchain.News, Ivan Obukhov and his UAE-based entity Foscom FZE are accused of processing over $100 million in cryptocurrency payments since 2023 to facilitate the sale of Iranian oil, acting as a broker between Iranian state entities and overseas buyers. Chainalysis, in analysis published August 25, 2026, described the enforcement action as directly targeting 'crypto-for-oil' payment mechanisms — the use of stablecoins and other digital assets to settle oil trades in a manner that circumvents the SWIFT-based correspondent banking system. These designations are separate from, though contemporaneous with, the Mabna Institute cyber actor designations and the broader sectoral determination.","heading":"IRGC-Qods Force Crypto-for-Oil Payment Network","severity":"critical","sources":[{"credibility":2,"name":"OFAC Targets Crypto-for-Oil Payments in Latest Iran Sanctions — Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/ofac-iran-oil-payments-august-2026/"},{"credibility":2,"name":"US Treasury Makes Iran's Digital Asset Sector Sanctionable in 60-Target Action — CryptoTimes","type":"news_article","url":"https://www.cryptotimes.io/2026/08/25/us-treasury-names-digital-assets-a-sanctionable-sector-of-irans-economy/"},{"credibility":2,"name":"OFAC Expands Iran Sanctions to Crypto Sector Under New Campaign — Blockchain.News","type":"news_article","url":"https://blockchain.news/news/ofac-iran-crypto-sanctions-2026"}]},{"content":"Operation Economic Outcast is distinct from several earlier 2026 OFAC actions targeting Iran-linked crypto activity. On August 7, 2026, OFAC designated two crypto exchanges — Shelbit Exchange and Aban Tether — for allegedly facilitating IRGC fund flows; that action was an entity-level SDN designation and did not include a sectoral determination. Earlier in 2026, OFAC also sanctioned Nobitex, Iran's largest domestic exchange, and separately froze approximately $131 million in USDT linked to Iran's central bank wallets. The August 24 sectoral determination represents a qualitative escalation beyond all prior actions: rather than targeting specific named entities, it creates category-level exposure affecting any global actor transacting materially with Iran's crypto sector. Legal commentators at Foley Hoag note the Administration 'preserved flexibility by not naming specific secondary targets,' signaling willingness to escalate enforcement over time.","heading":"Distinction from Prior Iran Crypto Enforcement Actions","severity":"high","sources":[{"credibility":1,"name":"U.S. sanctions Iran-linked crypto exchanges Shelbit and Aban Tether — CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2026/08/07/u-s-widens-iran-crypto-crackdown-with-sanctions-on-two-exchanges"},{"credibility":2,"name":"Trump Administration Increases Sanctions Pressure on Iran through 'Operation Economic Outcast' — Foley Hoag LLP","type":"research","url":"https://foleyhoag.com/news-and-insights/blogs/white-collar-law-and-investigations/2026/august/trump-administration-increases-sanctions-pressure-on-iran-through-operation-economic-outcast/"},{"credibility":2,"name":"Department of the Treasury Announces Further Sanctions on Iran — Thompson Hine SmarTrade","type":"news_article","url":"https://www.thompsonhinesmartrade.com/2026/08/department-of-the-treasury-announces-further-sanctions-on-iran/"}]},{"content":"The sectoral determination creates systemic compliance obligations for centralized exchanges (CeFi), decentralized protocol front-ends, OTC desks, custodians, and infrastructure providers globally. According to TRM Labs, 'any institution that processes a significant transaction for an Iranian exchange or digital assets business in turn risks its access to the U.S. financial system.' Because the 'significant transaction' standard carries no numerical floor in the determination, compliance teams face an undefined threshold. Foley Hoag advises companies to 'immediately engage with those parties to assess and mitigate the compliance risks presented.' Chainalysis, in its August 25 blog post, described the action as requiring compliance teams to urgently audit all Iran-nexus counterparty exposure across DeFi and CeFi. Practically, this means enhanced screening against not only the SDN list but also against any counterparty with operational connections to Iran's domestic crypto ecosystem — Nobitex, domestic Iranian OTC networks, and Iran-adjacent payment rails. The 30 newly listed crypto wallet addresses should be integrated into on-chain monitoring tools immediately.","heading":"Compliance Implications for Crypto Businesses","severity":"high","sources":[{"credibility":2,"name":"Operation Economic Outcast: Treasury Sanctions Nearly 60 Iran-linked Targets and Names Digital Assets a Sanctionable Sector — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/operation-economic-outcast-treasury-sanctions-nearly-60-iran-linked-targets-and-names-digital-assets-a-sanctionable-sector"},{"credibility":2,"name":"OFAC Targets Crypto-for-Oil Payments in Latest Iran Sanctions — Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/ofac-iran-oil-payments-august-2026/"},{"credibility":2,"name":"Trump Administration Increases Sanctions Pressure on Iran through 'Operation Economic Outcast' — Foley Hoag LLP","type":"research","url":"https://foleyhoag.com/news-and-insights/blogs/white-collar-law-and-investigations/2026/august/trump-administration-increases-sanctions-pressure-on-iran-through-operation-economic-outcast/"}]}],"sources_used":[{"credibility":1,"name":"Treasury Launches Unprecedented Campaign Against Iranian Regime — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0613"},{"credibility":1,"name":"Iran Sanctions — OFAC Program Page","type":"regulatory","url":"https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions"},{"credibility":1,"name":"DOJ secures indictment of 17 Iranians accused of 'massive' cyber theft campaign — DataBreaches.Net","type":"court_filing","url":"https://databreaches.net/2026/08/19/doj-secures-indictment-of-17-iranians-accused-of-massive-cyber-theft-campaign/"},{"credibility":1,"name":"U.S. sanctions Iran-linked crypto exchanges Shelbit and Aban Tether — CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2026/08/07/u-s-widens-iran-crypto-crackdown-with-sanctions-on-two-exchanges"},{"credibility":2,"name":"Operation Economic Outcast: Treasury Sanctions Nearly 60 Iran-linked Targets and Names Digital Assets a Sanctionable Sector — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/operation-economic-outcast-treasury-sanctions-nearly-60-iran-linked-targets-and-names-digital-assets-a-sanctionable-sector"},{"credibility":2,"name":"OFAC Targets Crypto-for-Oil Payments in Latest Iran Sanctions — Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/ofac-iran-oil-payments-august-2026/"},{"credibility":2,"name":"US Can Now Sanction Anyone Operating in Iran's Crypto Sector — Decrypt","type":"news_article","url":"https://decrypt.co/376424/us-can-now-sanction-anyone-operating-in-irans-crypto-sector"},{"credibility":2,"name":"US Treasury Makes Iran's Digital Asset Sector Sanctionable in 60-Target Action — CryptoTimes","type":"news_article","url":"https://www.cryptotimes.io/2026/08/25/us-treasury-names-digital-assets-a-sanctionable-sector-of-irans-economy/"},{"credibility":2,"name":"Trump Administration Increases Sanctions Pressure on Iran through 'Operation Economic Outcast' — Foley Hoag LLP","type":"research","url":"https://foleyhoag.com/news-and-insights/blogs/white-collar-law-and-investigations/2026/august/trump-administration-increases-sanctions-pressure-on-iran-through-operation-economic-outcast/"},{"credibility":2,"name":"Department of the Treasury Announces Further Sanctions on Iran — Thompson Hine SmarTrade","type":"news_article","url":"https://www.thompsonhinesmartrade.com/2026/08/department-of-the-treasury-announces-further-sanctions-on-iran/"},{"credibility":2,"name":"Mabna Institute moved $16.8M through crypto addresses since 2018, TRM Labs finds — Crypto Briefing","type":"news_article","url":"https://cryptobriefing.com/mabna-institute-crypto-addresses-trm-labs/"},{"credibility":2,"name":"OFAC Expands Iran Sanctions to Crypto Sector Under New Campaign — Blockchain.News","type":"news_article","url":"https://blockchain.news/news/ofac-iran-crypto-sanctions-2026"},{"credibility":2,"name":"US Sanctions 30 Crypto Wallets Tied to Iran's Mabna Institute, Tracing $16.8 Million — BigGo Finance","type":"news_article","url":"https://finance.biggo.com/news/24e4dffd-59cb-45c2-8fd1-0bfe6ead746c"},{"credibility":2,"name":"Operation Economic Outcast Targets Iran With New Sanctions — The Cyber Express","type":"news_article","url":"https://thecyberexpress.com/operation-economic-outcast-targets-iran/"},{"credibility":2,"name":"Operation Economic Outcast Exposes Iranian Spies Who Hacked U.S. Infrastructure for $16.8M — TechTimes","type":"news_article","url":"https://www.techtimes.com/articles/325427/20260825/operation-economic-outcast-exposes-iranian-spies-who-hack-us-infrastructure-168m.htm"},{"credibility":2,"name":"Treasury's Operation Economic Outcast Targets Iran's Digital-Asset Sector — TFTC","type":"news_article","url":"https://www.tftc.io/operation-economic-outcast-iran-digital-asset-sanctions-bitcoin"},{"credibility":2,"name":"Executive Order 13902 — Wikipedia","type":"other","url":"https://en.wikipedia.org/wiki/Executive_Order_13902"}],"summary":"On August 24, 2026, the U.S. Department of the Treasury launched Operation Economic Outcast, a sweeping sanctions campaign against Iran that, for the first time, designated Iran's entire digital assets sector as sanctionable under Executive Order 13902. The action named nearly 60 entities, individuals, and vessels and listed 30 crypto wallet addresses across Bitcoin, Ethereum, and TRON linked to the Mabna Institute and IRGC-Qods Force. The sectoral determination creates broad secondary sanctions exposure for any foreign crypto business — exchange, custodian, OTC desk, or DeFi protocol — that maintains material Iran-nexus counterparty relationships, regardless of whether those counterparties are individually listed.","timeline":[{"date":"2013-01-01","event":"Mabna Institute founded in Tehran; begins cyber-intrusion campaign on behalf of the IRGC and Iranian government clients, eventually compromising 144 U.S. universities, 178 foreign universities, private companies, and government agencies.","source":"Crypto Briefing / TRM Labs","source_url":"https://cryptobriefing.com/mabna-institute-crypto-addresses-trm-labs/"},{"date":"2018-03-01","event":"DOJ unseals original indictment charging nine Mabna Institute members with cyber intrusion and theft of academic and commercial intellectual property.","source":"DataBreaches.Net","source_url":"https://databreaches.net/2026/08/19/doj-secures-indictment-of-17-iranians-accused-of-massive-cyber-theft-campaign/"},{"date":"2020-01-10","event":"President Trump signs Executive Order 13902, authorizing sectoral sanctions against specified sectors of the Iranian economy — the legal foundation for the August 2026 digital assets determination.","source":"Wikipedia / Treasury","source_url":"https://en.wikipedia.org/wiki/Executive_Order_13902"},{"date":"2026-08-07","event":"OFAC designates Shelbit Exchange and Aban Tether under entity-level SDN listings for allegedly facilitating IRGC fund flows — a precursor action distinct from the subsequent sectoral determination.","source":"CoinDesk","source_url":"https://www.coindesk.com/policy/2026/08/07/u-s-widens-iran-crypto-crackdown-with-sanctions-on-two-exchanges"},{"date":"2026-08-18","event":"FBI unseals superseding indictment charging 17 Iranian nationals affiliated with the Mabna Institute, adding eight defendants to the 2018 indictment. Five of these individuals are subsequently designated in the August 24 OFAC action.","source":"DataBreaches.Net","source_url":"https://databreaches.net/2026/08/19/doj-secures-indictment-of-17-iranians-accused-of-massive-cyber-theft-campaign/"},{"date":"2026-08-24","event":"Treasury Secretary Scott Bessent announces Operation Economic Outcast. OFAC designates nearly 60 entities, individuals, and vessels and issues five sectoral determinations under E.O. 13902 covering digital assets, technology, gold, aviation, and shipping. Thirty crypto wallet addresses across Bitcoin, Ethereum, and TRON are added to the SDN list. This marks the first time Iran's digital assets sector has been designated as sanctionable at a sectoral level.","source":"U.S. Department of the Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0613"},{"date":"2026-08-25","event":"Chainalysis publishes compliance analysis of the action, highlighting the crypto-for-oil payment network targeted by the Obukhov/Foscom designations. TRM Labs publishes on-chain analysis finding $16.8 million in total flows through the 30 Mabna-linked wallet addresses.","source":"Chainalysis / TRM Labs","source_url":"https://www.chainalysis.com/blog/ofac-iran-oil-payments-august-2026/"}]},"v":1}

   Verify offline (run on your own machine)

   python -m src.verify_decision 98e0844f-e4db-4f59-be66-264ab29983cacopy
2. #2reviewby reviewerreviewer

   2026-08-27 03:17:30Z
   Score: 12 → 12 (no score change)
   The page's core facts — dates, designee names, dollar figures, wallet-address counts, and the existence of an unprecedented digital-assets sectoral determination under E.O. 13902 — are well-sourced and independently corroborated against the primary Treasury press release and multiple industry analyses (TRM Labs, Chainalysis, Decrypt, Foley Hoag). However, the page exhibits the sanctions-page defect pattern flagged for this corpus: it frames E.O. 13902 as the unified 'legal vehicle' for the action while omitting that several of its most prominent crypto-linked designees (Ivan Obukhov, Foscom FZE, Mohammad Ahmed Suhil Fattouh) were actually designated under the terrorism-financing authority of E.O. 13224, and the Mabna Institute cyber actors under the cyber-sanctions authority of E.O. 13694 — materially different and, in the terrorism case, more severe legal bases. The page also contains one quotation misattributed to Foley Hoag that does not appear in the cited source, and one instance where a specific detail (stablecoins/SWIFT circumvention) attributed to a Chainalysis post could not be found in that post.
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   {"actor":"reviewer","decided_at":"2026-08-27T03:17:30.077Z","decision":"review","investigation_id":"10136f6a-2bee-480a-8bf6-009e08eb7474","new_score":12,"page_slug":"ofac-operation-economic-outcast-iran-digital-assets-sectoral-sanctions-august-2026","prev_score":12,"reason":"The page's core facts — dates, designee names, dollar figures, wallet-address counts, and the existence of an unprecedented digital-assets sectoral determination under E.O. 13902 — are well-sourced and independently corroborated against the primary Treasury press release and multiple industry analyses (TRM Labs, Chainalysis, Decrypt, Foley Hoag). However, the page exhibits the sanctions-page defect pattern flagged for this corpus: it frames E.O. 13902 as the unified 'legal vehicle' for the action while omitting that several of its most prominent crypto-linked designees (Ivan Obukhov, Foscom FZE, Mohammad Ahmed Suhil Fattouh) were actually designated under the terrorism-financing authority of E.O. 13224, and the Mabna Institute cyber actors under the cyber-sanctions authority of E.O. 13694 — materially different and, in the terrorism case, more severe legal bases. The page also contains one quotation misattributed to Foley Hoag that does not appear in the cited source, and one instance where a specific detail (stablecoins/SWIFT circumvention) attributed to a Chainalysis post could not be found in that post.","score_delta":0,"sequence_num":2,"submission_content_hash":null,"submission_id":null,"submission_kind":null,"submission_valence":null,"v":1}

   Verify offline (run on your own machine)

   python -m src.verify_decision 74e71e9e-9305-42fd-bd11-e25af6605d0bcopy
3. #3review reviseby judgejudge

   2026-08-27 03:17:30Z
   Score: 12 → 0 (-15)
   I independently counted the review's claim_findings array and found 35 entries (29 confirmed, 5 partially_supported, 1 disputed, 0 unverifiable/stale/link_rot), not the 36 claims and 30 confirmed the summary block reports. One claim the summary counts is not present in the array and cannot be inspected, so a small piece of this review's coverage is simply missing rather than good or bad. Either way disputed_pct rounds to about 3% (1/35 or 1/36), which alone sits in the approve band. However, the review also logged a high-priority coverage gap: the page frames Executive Order 13902 as 'the legal vehicle' for the entire 24 August 2026 action, but the reviewer verified against the Treasury press release that Ivan Obukhov and Mohammad Ahmed Suhil Fattouh were actually designated under the terrorism-financing authority (E.O. 13224), and the Mabna Institute cyber actors plus Arman Kahzadian under the cyber-sanctions authority (E.O. 13694) (claim_findings[3], [14], [15], [16]). Because those findings were coded partially_supported rather than disputed, this material framing problem does not register in disputed_pct at all, even though it understates the legal severity attached to some of the page's most prominent crypto-linked designees. The review's decision rules direct that a high-priority coverage gap should push toward review_revise even where disputed_pct is low, and I've applied that instruction here rather than letting a technically-low disputed_pct default to approval of a page with this specific unaddressed defect. Compounding this, the review's lone disputed finding is a quotation attributed to law firm Foley Hoag ('inverts the normal sequence') that the reviewer confirmed, via direct fetch and targeted search of the cited post, does not appear anywhere in that source (claim_findings[7]) — a fabricated attribution rather than a wrong figure. A second, related problem was found in a partially_supported finding: a 'stablecoins... circumvents SWIFT' characterization attributed to a Chainalysis post that the reviewer could not find in that post (claim_findings[26]). Weighed against this, the review's core factual backbone — designee identities, roles and locations, the ~60-designee count, the 30 wallet addresses, $16.8M and $202,662 figures, the 92% concentration figure, DOJ-sourced Mabna Institute statistics, the 7 August Shelbit/Aban Tether action, and Nobitex background — was independently corroborated against Treasury and DOJ primary sources. Two citations returned 403/429 on automated fetch, but the reviewer corroborated the underlying claims through independent alternate sources rather than simply asserting they held up, which is the correct way to avoid over-penalizing likely bot-blocking as link rot. On balance, this is a page with a sound factual core undermined by an unaddressed legal-authority framing gap on its most serious designations and two separate instances of unsupported attributions to named professional sources — enough to require revision, not enough, at ~3% disputed content and 0.75 reviewer confidence, to escalate further.
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   verifying row…

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   {"actor":"judge","decided_at":"2026-08-27T03:17:30.077Z","decision":"review_revise","investigation_id":"10136f6a-2bee-480a-8bf6-009e08eb7474","new_score":0,"page_slug":"ofac-operation-economic-outcast-iran-digital-assets-sectoral-sanctions-august-2026","prev_score":12,"reason":"I independently counted the review's claim_findings array and found 35 entries (29 confirmed, 5 partially_supported, 1 disputed, 0 unverifiable/stale/link_rot), not the 36 claims and 30 confirmed the summary block reports. One claim the summary counts is not present in the array and cannot be inspected, so a small piece of this review's coverage is simply missing rather than good or bad. Either way disputed_pct rounds to about 3% (1/35 or 1/36), which alone sits in the approve band. However, the review also logged a high-priority coverage gap: the page frames Executive Order 13902 as 'the legal vehicle' for the entire 24 August 2026 action, but the reviewer verified against the Treasury press release that Ivan Obukhov and Mohammad Ahmed Suhil Fattouh were actually designated under the terrorism-financing authority (E.O. 13224), and the Mabna Institute cyber actors plus Arman Kahzadian under the cyber-sanctions authority (E.O. 13694) (claim_findings[3], [14], [15], [16]). Because those findings were coded partially_supported rather than disputed, this material framing problem does not register in disputed_pct at all, even though it understates the legal severity attached to some of the page's most prominent crypto-linked designees. The review's decision rules direct that a high-priority coverage gap should push toward review_revise even where disputed_pct is low, and I've applied that instruction here rather than letting a technically-low disputed_pct default to approval of a page with this specific unaddressed defect. Compounding this, the review's lone disputed finding is a quotation attributed to law firm Foley Hoag ('inverts the normal sequence') that the reviewer confirmed, via direct fetch and targeted search of the cited post, does not appear anywhere in that source (claim_findings[7]) — a fabricated attribution rather than a wrong figure. A second, related problem was found in a partially_supported finding: a 'stablecoins... circumvents SWIFT' characterization attributed to a Chainalysis post that the reviewer could not find in that post (claim_findings[26]). Weighed against this, the review's core factual backbone — designee identities, roles and locations, the ~60-designee count, the 30 wallet addresses, $16.8M and $202,662 figures, the 92% concentration figure, DOJ-sourced Mabna Institute statistics, the 7 August Shelbit/Aban Tether action, and Nobitex background — was independently corroborated against Treasury and DOJ primary sources. Two citations returned 403/429 on automated fetch, but the reviewer corroborated the underlying claims through independent alternate sources rather than simply asserting they held up, which is the correct way to avoid over-penalizing likely bot-blocking as link rot. On balance, this is a page with a sound factual core undermined by an unaddressed legal-authority framing gap on its most serious designations and two separate instances of unsupported attributions to named professional sources — enough to require revision, not enough, at ~3% disputed content and 0.75 reviewer confidence, to escalate further.","score_delta":-15,"sequence_num":3,"submission_content_hash":null,"submission_id":null,"submission_kind":null,"submission_valence":null,"v":1}

   Verify offline (run on your own machine)

   python -m src.verify_decision 817d03c2-3ccf-460b-9eae-0b3203347c09copy