On July 7, 2026, OFAC revoked Iran General License X (GL X) and replaced it with General License X1 (GL X1). The waiver, which had been due to run until August 21, lasted barely two weeks. GL X1 is not a continuation; it is a narrow wind-down authorization that expires on July 17, 2026.
OFAC General Licence — Iranian-origin petroleum products
On 21 June 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), authorising certain transactions relating to the production, sale, delivery and offloading of Iranian-origin crude oil, petrochemical products and petroleum products. This represents a remarkable — if temporary — departure from the comprehensive United
Extended 10-year statute of limitations for sanctions enforcement
Although aid to Israel, Ukraine, and Taiwan made headlines last month when President Biden signed H.R. 815, the law also significantly expanded the scope of agencies’ enforcement authority under two key national security laws: the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA). Both now have 10-year civil
U.S. target Iran’s oil trade and China’s involvement in the Middle East
Although 2021 has predominantly been referred to as the “year of Russia” in terms of sanctions, the collapse of nuclear talks (JCPOA) as well as the social repression in the country have also shifted the focus to Iran, to some degree.
While designating members of the Islamic Revolutionary Guards Forces (IRGF) as Specially Designated Nationals
OFAC reaches a settlement with crypto platform following an investigation into sanctions violations
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) recently reached a settlement with a multi-asset trading platform where, to settle its potential civil liability for violations of sanctions against Iran, Cuba, and Venezuela, the crypto platform agreed to pay $72,230.
In a recent post, our team outlines the alleged sanctions violations and