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ARTICLE · 09 JULY 2026

OFAC Revokes Iran General License X: A Stark Reminder That Evolving Sanctions Require Continuous Vigilance

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On July 7, 2026, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License X1 (GL X1), immediately revoking General License X (GL X), which had, for the first time since the 1970’s...

GlobalGovernment, Public Sector
Margaret B. Beasley
Margaret B. Beasley
Bryan W. McCracken
Bryan W. McCracken

What to Know

  • On July 7, 2026, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License X1 (GL X1), immediately revoking General License X (GL X), which had, for the first time since the 1970’s, broadly authorized transactions involving Iranian crude oil, petroleum products and petrochemical products.
  • GL X1 replaced GL X with a narrow wind-down authorization through July 17, 2026.
  • GL X1 prohibits all new transactions involving Iranian crude oil, petroleum products or petrochemical products after July 7, 2026, absent a specific license from OFAC, except as “ordinarily incident and necessary” to effectuate wind down.
  • Companies that relied on GL X should immediately assess any pending transactions, contractual commitments, cargoes in transit and payment obligations to determine whether they qualify for the wind-down authorization.

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