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

Short summary

On July 7, 2026, OFAC revoked General License X — which had broadly authorized transactions involving Iranian crude oil and petrochemicals — replacing it with GL X1, a narrow ten-day wind-down authorization through July 17, 2026. The reversal follows IRGC attacks on commercial tankers and US retaliatory strikes, underscoring how quickly sanctions licenses can be withdrawn when tied to volatile diplomatic negotiations. Companies that relied on GL X must immediately assess pending transactions, contractual commitments, and payment obligations, and should not assume an OFAC authorization alone resolves all legal risk given overlapping criminal and civil statutes.

• •OFAC revoked GL X on July 7, 2026, replacing it with a narrow wind-down license (GL X1) expiring July 17, 2026
• •Companies must assess pending transactions, shipping logistics, and payment mechanisms for wind-down compliance
• •OFAC authorization alone does not resolve all legal risk — FTO designations and anti-terrorism statutes may still apply

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