Iran General License X Revoked and Superseded With Ten-Day Wind Down Authorization Subject to Payment of Funds in Blocked U.S. Accounts
The United States on July 7, 2026 revoked General License X, “Authorizing the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian-Origin Through August 21, 2026.”
What General License X Previously Authorized
Issued on June 21, 2026 in tandem with U.S.-Iran ceasefire negotiations, General License X authorized certain transactions that were otherwise prohibited by specific U.S. sanctions programs and Executive orders issued during the first Trump Administration. Specifically, General License X authorized “all transactions ordinarily incident and necessary to the production, sale, delivery, or offloading of crude oil, petrochemical products, or petroleum products of Iranian origin,” including transactions involving blocked vessels. General License X further expressly authorized USD payments of funds to Iran, the Iranian Government, or to any blocked person where such payments were attendant to generally licensed transactions.
General License X1 Revokes and Supersedes General License X
Following reports on July 7 that Iran had fired missiles at ships in the Strait of Hormuz, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License X1, revoking General License X in its entirety and superseding it with General License X1 (paragraph (b)), which authorizes “all transactions prohibited by” applicable sanctions authorities and “ordinarily incident and necessary to” the wind down of transactions previously authorized by General License X. Wind down transactions are authorized for just under ten days, through 12:01 a.m. eastern daylight time (EDT) on July 17, 2026.
Wind Down Authorization Subject to Requirement of Payment to Blocked U.S. Accounts
Importantly, any payments to a blocked person must be made to a blocked, interest-bearing account in the United States, and may not without specific or further authorization from OFAC be paid into an unblocked, non-U.S. account or paid to a blocked person through other channels. This payment condition brings under U.S. control monies owing to blocked persons as a result of General License X transactions.
Bottom Line for U.S. Persons and Specific Licenses
As of July 7, 2026 at 1:55 p.m. EDT (the time stamp on the license), U.S. persons were prohibited from engaging in or continuing transactions previously authorized by General License X. Such persons intending to avail of General License X1’s wind down authorization must take care to complete any authorized wind down transactions by 12:01 a.m. EDT on July 17, 2026, and ensure that any monies payable to blocked persons are paid into a blocked, interest-bearing account in the United States.
U.S. persons requiring additional time or scope to wind down, engage in, or continue transactions authorized by General License X should apply for one or more OFAC specific licenses.
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MassPoint PLLC works with U.S. and foreign clients to navigate U.S. sanctions, including compliance, OFAC license applications, and voluntary self-disclosures (VSDs) to OFAC. For guidance on navigating this development, contact MassPoint’s Principal, Hdeel Abdelhady.