Sanctions Archives - MassPoint Legal PLLC

United States Revokes Iran General License X, Wind-Down Deadline July 17

OFAC revoked General License X on July 7, 2026, cutting off previously authorized Iranian-origin crude oil and petroleum transactions following missile strikes on ships in the Strait of Hormuz. In its place, General License X1(b) offers a ten-day wind-down window — through July 17 — with a strict requirement that payments to blocked persons land in blocked, interest-bearing U.S. accounts. Here’s what changed, and what U.S. persons need to do before the deadline.

MassPoint Legal and Strategy Advisory PLLC

Derisking the Dollar: From the Belt and Road to the Strait of Hormuz

Iran’s ability to sell oil and collect tolls in the Strait of Hormuz highlights some of the U.S. dollar derisking architecture erected by states and blocs seeking independence from U.S. sanctions jurisdiction.

Hdeel Abdelhady Articles

Hdeel Abdelhady on Global Trade, Sanctions Policy, and Iraq’s Economic Future: An Interview with Gulan

An in-depth interview with Hdeel Abdelhady on sanctions policy, export controls, financial regulation, and Iraq’s economic future, with analysis of global trade fragmentation and technology governance.

Export Controls

BIS Affiliates Rule Suspended for One Year

The White House has announced a one-year suspension of the Commerce Department Bureau of Industry and Security’s (BIS) new Affiliates Rule, but its scope remains unclear. As of November 3, 2025, BIS has not issued a rule or guidance formalizing the suspension. Exporters should continue preparing for compliance while monitoring forthcoming BIS action expected by November 10, 2025.

Export Controls

New BIS “Affiliates Rule”: What Exporters Need to Know About Ownership, Due Diligence, and Red Flags

BIS’s new “Affiliates Rule” marks a major expansion of the Export Administration Regulations (EAR), extending export restrictions to entities owned 50% or more by those on the Entity List, MEU List, or certain SDNs—even if not listed themselves. The rule also introduces a new diversion-risk Red Flag, imposes strict-liability exposure, and creates enhanced ownership and due-diligence obligations for exporters and related parties.

Export Controls

Hdeel Abdelhady discussed export controls at ACAMS

Hdeel Abdelhady discussed at ACAMS U.S. export controls on semiconductors and other technology and items to Russia, and U.S. and foreign financial institutions’ compliance obligations.

MassPoint Legal and Strategy Advisory PLLC

What Exporters Should Know About Financial Institution Export Compliance

Although the BIS Guidance is a directive to FIs, it very much affects exporter customers of FIs. Here’s what exporters should know.

International Trade

Weaponized Law as a Trade Tool

The ZTE case illuminates a potentially transformative shift in how the United States deploys its legal and regulatory authority in the international economic arena—a development with profound implications for global commerce, compliance practices, and the rule of law.

Export Controls

BIS Guidance to Financial Institutions on Export Administration Regulations Compliance

BIS advises financial institutions to guard against EAR violations through: (1) screening against export lists, (2) enhanced due diligence for high-risk transactions, (3) derisking, and (4) reporting and self-disclosing EAR violations. The BIS guidance reiterates FIs’ obligation to file suspicious activity reports (SARs) as directed in three prior FinCEN-BIS alerts.

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