Iran 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 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.

Sanctions

Hdeel Abdelhady Talked to NPR About Iran and North Korea Sanctions

Hdeel Abdelhady talked to NPR about intensified Iran sanctions and North Korea sanctions, and the United States’ ability to impose strong sanctions owing to U.S. dollar dominance.

Sanctions

Hdeel Abdelhady-Accuity Q&A: COVID, Supply Chains & Sanctions

In the second part of her Q&A with Accuity, Hdeel Abdelhady shared her thoughts on the current and potential impacts of the COVID-19 pandemic on global supply chains, sanctions, and financial crime

Sanctions

Iran Sanctions: OFAC Exempts Medicine, PPE Manufacturers (EO 13902)

In guidance issued on June 5, 2020, OFAC explained that manufacturers in Iran of medicine, PPE, childcare items, and other essential supplies will be exempt from sanctions targeting Iran’s manufacturing sector pursuant to EO 13902.

Iran Sanctions

OFAC Cosco Shipping Tanker (Dalian) Co., Ltd. General License K: Analysis

General License K authorizes, until 12:01 eastern time on December 20, 2019 (essentially, through the end of December 19 eastern time), the above-listed prohibited transactions where they directly or indirectly involve Cosco or entities owned 50% by Cosco and are “ordinarily incident and necessary to the maintenance or wind down of transactions.”

Iran Sanctions

U.S. Sanctions Chinese Shipping Companies: Legal and Practical Points

The imposition of sanctions on the Chinese companies and executives—particularly on units of the high-profile, state-owned COSCO at a critical juncture in the U.S.-China trade war and shortly after both countries took conciliatory steps—reinforces the Trump Administration’s stated posture of aggressively enforcing Iran secondary sanctions in furtherance of its policy objectives.

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