Iran General License U - Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

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TURBOFAC Commentary (293 words)

Notes: .

1) Compare Russia-related 134. This is the Iran equivalent of the extraordinarily rare Russia-related GL that, in an effort to keep oil prices down in the midst of the U.S./Israel-Iran war, effectively “unsactions” all Iranian origin oil that was “loaded on any vessel” prior to the issuance of the GL. Broad as the GL is, there is one crucially important implicit limitation to the GL. More specifically, and unlike the case in the Russia program, there is a broad prohibition on all dealings in or related to goods of Iranian origin, including oil (560.206), and there is nothing in this GL that ensures that persons acting under the authority of this time-limited GL will be able to continue dealing in the oil they purchase after the GL expires. Moreover, any “trailing transaction” (e.g. an insurance-related payment) will be prohibited after the GL expires to the extent that it related to goods of “Iranian origin”. Such problem does not exist in the same way where only blocking prohibition are at issue, because the purchase of the oil pursuant to the license can extinguish all blocked person interest in the oil, thereby enabling transactions related to the oil to occur after the expiration of the license. This lack of an ongoing authorization for dealings in “Iranian origin” oil purchased pursuant to the GL appears to render the GL virtually useless in practice for U.S. persons, except insofar as (i) oil is imported into the United States prior to the expiration of the GL, such that 560.518(a) authorizes dealings therein, or (ii) the oil is “substantially transformed” prior to the expiration of the GL, such that it would not longer be consider a good of Iranian origin (560.407).

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Iran General License U - Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026

TURBOFAC Commentary (293 words)