Iran General License (No. K-1)​ - Authorizing Maintenance or Wind Down of Transactions Involving Cosco Shipping Tanker (Dalian) Co., Ltd. (Expired)

Date issued: Dec. 19 2019

TURBOFAC Commentary (323 words)


1) Broad GL authorizing transactions "ordinarily incident and necessary to the maintenance or wind down of transactions involving" Cosco Shipping Tanker (Dalian) Co., Ltd. See generally documents related to the scope of "wind down" and "maintenance" general licenses.

The GL appears to have the effect of unblocking all or virtually all funds and physical property of that entity, at least insofar as the only reason for their blocking was an interest in the property had by Cosco. Compare also Venezuela General License 11, where text similar to what is found in paragraph (a) here is acknowledged, in paragraph (c), as covering the unblocking of property.

Note the entity is Chinese, and was secondarily sanctioned for oil-related transactions involving Iran. Hence the caveat that the GL excludes any transaction that would implicate primary Iran-related sanctions, such as the ITSR.

2) The scope of the GL is further discussed in FAQ 804, FAQ 806, FAQ 807. FAQ 807 is particularly valuable as it specifies that U.S. person banks, and presumably all non-U.S. persons, may facilitate transactions not involving U.S. persons where the underlying transaction facilitated would be within the scope of the GL if they did involve U.S. persons.

3) GL Amended on Dec. 19, 2019 to extend the expiration date.

4) On Jan. 31, 2020, the entities within the scope of Iran GL K were removed from the SDN list. See

*For expired/superseded versions of this GL, see We note that while we have included some expired and/or revoked GLs in the research system as stand-alone searchable items, we avoid clutter by removing GLs once they have been superseded by amended versions.