Iran-related General License X1, for the "Revocation and Wind Down of June 21, 2026 Authorization for the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian Origin." [Prior versions in PDF]

Date issued: Jul. 07 2026

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TURBOFAC Commentary (695 words)

Notes:

[7-7-26 Update – the comments below are comments to Iran GL X. On 7-7-26, OFAC revoked GL X and issued GL X-1, authorizing transactions “ordinarily incident and necessary to the wind down of transactions previously authorized by General License X,” with the proviso that “any payment to a blocked person must be made into a blocked, interest-bearing account located in the United States”. Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs]

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1) This GL, issued in connection with article 10 of the June 2026 “Islamabad Memorandum of Understanding between the United States of America and the Islamic Republic of Iran,” is uniquely broad as it relates to dealings in or related to Iranian energy. (The relevant portion of the MOU is...