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National Law Review
National Law Review
7/2/2026
US–Iran Sanctions Update: OFAC Issues General License X Following Signing of Memorandum of Understanding

US–Iran Sanctions Update: OFAC Issues General License X Following Signing of Memorandum of Understanding

Short summary

OFAC issued General License X authorizing broad transactions in Iranian-origin crude oil and petroleum products through August 21, 2026, following a US-Iran MOU on de-escalation. The license permits shipping, insurance, financing, and U.S. dollar payments for covered transactions, but explicitly excludes transactions with designated terrorist organizations including the IRGC. Companies must maintain strict compliance monitoring as the license is time-limited and subject to amendment or withdrawal.

  • OFAC GL X authorizes Iranian oil and petroleum transactions through Aug 21, 2026
  • Includes shipping, insurance, financing, and U.S. dollar payments for covered transactions
  • Excludes IRGC and designated FTOs; requires ongoing compliance monitoring

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