EXPORT CONTROLS | 2026-08-05

OFAC Delistings Accelerate: Fly Baghdad and SDN Removals

On August 5, 2026, OFAC published a Counter Terrorism Designations Removals and Update action removing Iraqi passenger carrier Fly Baghdad and two of its Boeing 737 aircraft from the SDN List after an administrative reconsideration under 31 CFR 501.807 — the latest and most consequential step in Treasury's sanctions modernization initiative, which has already stripped 160 outdated entries from the list in two rounds and launched an online Reconsideration Portal — and the accelerating pace of delistings creates a new category of compliance work for California exporters, banks, fintechs, remittance processors, and logistics companies at the Ports of Los Angeles and Long Beach, which must now manage removals, unblocking, reporting, and residual-risk analysis as rigorously as they manage new designations.

On August 5, 2026, the Treasury Department's Office of Foreign Assets Control published a Counter Terrorism Designations Removals and Update action removing Fly Baghdad Airlines Company — the Iraqi passenger carrier also known as Fly Baghdad and Iraq Express — from the Specially Designated Nationals

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