On June 22, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), which authorizes a broad range of transactions in Iranian-origin crude oil, petrochemical products, and petroleum products through 12:01 AM EDT on August 21, 2026.
OFAC issued GL X in furtherance of the U.S.-Iran Memorandum of Understanding of June 17, 2026, and it forms part of the initial phase of a broader framework aimed at resolving military conflict, restoring commercial navigation through the Strait of Hormuz, and advancing toward a comprehensive agreement on Iran’s nuclear program.
Authorized Activity
The license authorizes all transactions “ordinarily incident and necessary to the production, sale, delivery, or offloading of crude oil, petrochemical products, or petroleum products of Iranian origin.”
In practical terms, this extends to contracting, payment processing (including in U.S. dollars), insurance and reinsurance arrangements, brokerage, surveying and inspection, shipping and terminal operations, port services, customs facilitation, and other ancillary value-chain activities.
Both U.S. and non-U.S. persons may avail themselves of GL X. The authorization encompasses transactions that would otherwise be prohibited under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560; the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. Part 587; the Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. Part 589; the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part 544; the Iranian Financial Sanctions Regulations, 31 C.F.R. Part 561; the Iranian Sector and Human Rights Abuses Sanctions Regulations, 31 C.F.R. Part 562; the Global Terrorism Sanctions Regulations, 31 C.F.R. Part 594; and Executive Orders 13846, 13876, 13902, and 13949.
Furthermore, the license specifically states that it authorizes imports of Iranian oil into the United States (which has mostly been prohibited since 1987), as well as payment in U.S. dollars to Iran, the Government of Iran, or blocked persons.
GL X expires at 12:01 a.m. EDT on August 21, 2026, with no automatic renewal mechanism and the possibility of early termination if U.S.-Iran negotiations deteriorate. Any extension presumably will hinge on progress toward a final U.S.-Iran agreement.
Limitations
GL X does not authorize transactions involving persons located in or organized under the laws of Cuba, North Korea, or the Crimea, so-called Donetsk People’s Republic, or so-called Luhansk People’s Republic regions of Ukraine, as well as entities they own or control or with which they are in a joint venture.
Notably, GL X does not identify the Foreign Terrorist Organizations (“FTO”) Sanctions Regulations (31 C.F.R. Part 597) as a regulatory regime for which it provides relief. This is significant because Iran’s Islamic Revolutionary Guard Corps (“IRGC”) is a designated FTO and operates at the commanding heights of Iran’s economy, which could present significant compliance challenges.
Furthermore, GL X does not expressly provide relief from any statutory sanctions, including those imposed under the Iran Threat Reduction and Syria Human Rights Act and the Iran Freedom and Counter-Proliferation Act.
Multi-Jurisdictional Considerations
GL X does not relieve compliance obligations under non-U.S. sanctions regimes that may be relevant to transactions involving crude oil, petrochemical products, and petroleum products, including those of the United Kingdom, the European Union, and Switzerland. In particular, these regimes may be particularly impactful with regard to the availability of insurance for Iran shipments.
Compliance Considerations
GL X provides authorization for a broad range of transactions on its face, but companies seeking to carry out authorized activity will need to navigate various challenges, including:
- Due diligence concerns involving the role of the IRGC in a transaction
- Non-U.S. sanctions laws
- Possible revocation or non-renewal of GL X based on geopolitical developments
- Restrictions on transactions imposed by banks, insurers, and other operators
- Limitations on Iran-related transactions imposed by internal compliance policies, company investors, stock exchanges, and other stakeholders
For more information or assistance, please contact Anthony Rapa, Kenneth J. Nunnenkamp, Matthew J. Thomas, Ekinsu Cebi Elkei or another member of Blank Rome’s International Trade, Maritime, or White Collar Defense & Investigations groups.