Nothing on this page asks for a signature, a donation or an email address. Every ask below is a case-file item: it copies as a formatted, sourced paragraph with the address of this page appended, ready to paste into a letter, a memo or a screening note. The Gap Map sets out eight asks addressed to governments; several of them recur here, regrouped by audience.
Legislators and Their Staff
Members, committee staff and parliamentary researchers in the five tracked jurisdictions.- Mirror-List the Post-MOU 170
Twelve US actions in the post-MOU window produced 170 new designees. Allied governments added 13 more in total, and exactly one of the 170 (Ali Ansari) has any allied counterpart. Canada and Australia made no Iran-related designation of any kind in the ten weeks after June 1, 2026. Ask your government to designate the window’s US targets by network rather than one name at a time.
In this record: Gap map totals · Designation events
THE ASK (1 of 4): Mirror-list the post-MOU 170. Twelve US actions in the post-MOU window produced 170 new designees. Allied governments added 13 more in total, and exactly one of the 170 (Ali Ansari) has any allied counterpart. Canada and Australia made no Iran-related designation of any kind in the ten weeks after June 1, 2026. Ask your government to designate the window’s US targets by network rather than one name at a time. Evidence in this record: Gap map totals; Designation events. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026. - Send OFAC the 25-Party BIS List
Twenty-five parties sit on the Commerce Department’s Entity List, each with a Federal Register citation, for conduct that would support an OFAC designation, and none has been matched onto the SDN list. An Entity List action restricts future exports; it does not freeze an asset. Ask Treasury to open an SDN review on all twenty-five.
In this record: Do Not Touch, Register A
THE ASK (2 of 4): Send OFAC the 25-party BIS list. Twenty-five parties sit on the Commerce Department’s Entity List, each with a Federal Register citation, for conduct that would support an OFAC designation, and none has been matched onto the SDN list. An Entity List action restricts future exports; it does not freeze an asset. Ask Treasury to open an SDN review on all twenty-five. Evidence in this record: Do Not Touch, Register A. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026. - Apply Magnitsky-Style Measures to the EU-Only Judges
Four of the five judges the EU sanctioned on July 24, 2026 have no US, UK, Canadian or Australian counterpart. Priority goes to Abolfazl Ameri Shahrabi, the only judge anywhere tied by name to sentencing Nobel laureate Narges Mohammadi.
In this record: Designation events
THE ASK (3 of 4): Apply Magnitsky-style measures to the EU-only judges. Four of the five judges the EU sanctioned on July 24, 2026 have no US, UK, Canadian or Australian counterpart. Priority goes to Abolfazl Ameri Shahrabi, the only judge anywhere tied by name to sentencing Nobel laureate Narges Mohammadi. Evidence in this record: Designation events. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026. - Ask Why No US Action in This Window Cites IRAN-HR
Across all 503 US designation events between February 1 and August 10, 2026, none cites the IRAN-HR human-rights sanctions authority. Every action proceeded on financial, counterterrorism, non-proliferation or shipping authorities; not on the statute built for the conduct this record documents. That is a question for an oversight letter.
In this record: The Gap · The Evidence
THE ASK (4 of 4): Ask why no US action in this window cites IRAN-HR. Across all 503 US designation events between February 1 and August 10, 2026, none cites the IRAN-HR human-rights sanctions authority. Every action proceeded on financial, counterterrorism, non-proliferation or shipping authorities; not on the statute built for the conduct this record documents. That is a question for an oversight letter. Evidence in this record: The Gap; The Evidence. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026.
Compliance and Correspondent Banking
Sanctions officers, financial-crime teams and correspondent-banking desks.- Import the 68-Name Screen
The Do Not Touch screen names parties no government has designated but that pass both of this project’s evidentiary gates: a five-list re-screen confirming no existing designation under any name variant, and evidence resting on a Tier 1 to 4 source. It is a scrutinized-companies screen on the CISADA model, not a sanctions list, and it can be applied today.
In this record: Do Not Touch · Both-gates doctrine
THE ASK (1 of 3): Import the 68-name screen. The Do Not Touch screen names parties no government has designated but that pass both of this project’s evidentiary gates: a five-list re-screen confirming no existing designation under any name variant, and evidence resting on a Tier 1 to 4 source. It is a scrutinized-companies screen on the CISADA model, not a sanctions list, and it can be applied today. Evidence in this record: Do Not Touch; Both-gates doctrine. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026. - Treat a Row of Open Gaps as a Trigger, Not a Clearance
58 profiles in this register carry at least one open gap, and 42 of them are open in all five jurisdictions at once. A party that appears on no sanctions list has not been cleared by anyone; in these cases it has been screened and documented, and not designated. Absence of a listing is not absence of exposure.
In this record: The widest gaps · The Ledger
THE ASK (2 of 3): Treat a row of open gaps as a trigger, not a clearance. 58 profiles in this register carry at least one open gap, and 42 of them are open in all five jurisdictions at once. A party that appears on no sanctions list has not been cleared by anyone; in these cases it has been screened and documented, and not designated. Absence of a listing is not absence of exposure. Evidence in this record: The widest gaps; The Ledger. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026. - Build the FinCEN Typologies into the Programme
FinCEN Alert FIN-2026-Alert002’s red flags for Iran-linked crypto and shadow-banking rails already produced one enforcement result, in the August 7, 2026 action against Shelbit and Aban Tether. The exchange and corridor structures those flags describe are mapped in the network exhibits.
In this record: Nobitex exhibit · Shadow FX corridors
THE ASK (3 of 3): Build the FinCEN typologies into the programme. FinCEN Alert FIN-2026-Alert002’s red flags for Iran-linked crypto and shadow-banking rails already produced one enforcement result, in the August 7, 2026 action against Shelbit and Aban Tether. The exchange and corridor structures those flags describe are mapped in the network exhibits. Evidence in this record: Nobitex exhibit; Shadow FX corridors. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026.
Institutional Investors
Asset owners, managers and stewardship teams with emerging-market or shipping exposure.- Screen the 85 Critical-Priority Profiles First
Every profile in this register carries a divestment priority set by this project’s own assessment of the documented conduct and the exposure it creates. Start with the critical tier, then work down. Each profile page carries its evidence and its sources so a stewardship team can check the work.
In this record: Entity register · The Ledger
THE ASK (1 of 3): Screen the 85 critical-priority profiles first. Every profile in this register carries a divestment priority set by this project’s own assessment of the documented conduct and the exposure it creates. Start with the critical tier, then work down. Each profile page carries its evidence and its sources so a stewardship team can check the work. Evidence in this record: Entity register; The Ledger. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026. - Ask Managers to Report Exposure to the Screen by Name
A manager who cannot say whether a portfolio touches the 68 names on the Do Not Touch screen cannot say whether it touches the apparatus this record documents. The screen is published by name precisely so that question has a checkable answer.
In this record: Do Not Touch
THE ASK (2 of 3): Ask managers to report exposure to the screen by name. A manager who cannot say whether a portfolio touches the 68 names on the Do Not Touch screen cannot say whether it touches the apparatus this record documents. The screen is published by name precisely so that question has a checkable answer. Evidence in this record: Do Not Touch. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026. - Read the Shipping and Exchange Networks as Structures, Not as Names
The shadow fleet, the Shamkhani cluster and the exchange corridors are documented here as networks with their members listed. Screening a single designated name out of a network whose other members are undesignated does not remove the exposure.
In this record: Network exhibits
THE ASK (3 of 3): Read the shipping and exchange networks as structures, not as names. The shadow fleet, the Shamkhani cluster and the exchange corridors are documented here as networks with their members listed. Screening a single designated name out of a network whose other members are undesignated does not remove the exposure. Evidence in this record: Network exhibits. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026.
Universities and Pension Boards
Endowment committees, public pension trustees and procurement offices.- Use the Divestment Statutes Already on the Books
The scrutinized-companies mechanism created by Section 202 of CISADA, and the state-level pension and procurement statutes built on it, trigger on documented conduct rather than on a Treasury listing; because the two move at different speeds. The 68 names on this screen are documented conduct.
In this record: Do Not Touch · Both-gates doctrine
THE ASK (1 of 2): Use the divestment statutes already on the books. The scrutinized-companies mechanism created by Section 202 of CISADA, and the state-level pension and procurement statutes built on it, trigger on documented conduct rather than on a Treasury listing; because the two move at different speeds. The 68 names on this screen are documented conduct. Evidence in this record: Do Not Touch; Both-gates doctrine. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026. - Publish the Exposure Review, Not Just the Decision
A review that names what was checked, against which list, on what date, is a review another institution can build on. This record is published in that form for the same reason: every figure carries its source and its as-of date.
In this record: Method · Source register
THE ASK (2 of 2): Publish the exposure review, not just the decision. A review that names what was checked, against which list, on what date, is a review another institution can build on. This record is published in that form for the same reason: every figure carries its source and its as-of date. Evidence in this record: Method; Source register. Source: Middle East Forum, Iran Accountability Project, The Iran Ledger · A public accountability record of the Islamic Republic of Iran. Data as of October 6, 2026.
Corrections and Updates
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