IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS
STATEMENT OF LICENSING POLICY ON IRAN-RELATED REQUESTS
Consistent with current U.S. foreign policy, the following Statement of Licensing Policy establishes a presumed denial for licensing requests to engage in activities which are prohibited by the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560, and other Iran-related authorities.
On August 24, 2026, the United States Department of the Treasury announced Operation Economic Outcast against Iran, an unprecedented, whole-of-government, economic campaign against the Islamic Republic of Iran and its enablers until Iran ceases to pursue nuclear and conventional weapons capabilities and stops actively obstructing the Strait of Hormuz.
As part of this action, OFAC is establishing a licensing policy of presumed denial and suspending the application of previously issued Statements of Licensing Policy that had provided a favorable licensing posture for certain activities.
Under this Statement of Licensing Policy, Iran-related specific licenses may only be issued as required by law or in exceptional and urgent circumstances, such as risk to life, limb, or environmental safety. Persons applying for a specific license through the OFAC Licensing Portal should provide written attestation demonstrating these circumstances. OFAC will review such applications on a case-by-case basis, in consultation with the Department of State, in determining whether to grant any requested authorization.
Applicants are encouraged to subscribe to OFAC’s Recent Actions Notices to receive notification if this Statement of Licensing Policy is amended or rescinded in the future. If you have any additional questions, you may refer to the OFAC website at https://ofac.treasury.gov or submit your inquiries through the OFAC Compliance Hotline.
Issued on behalf of the Secretary of the Treasury:
______________________
Date: September 10, 2026
Bradley T. Smith
Director
Office of Foreign Assets Control
1) As of the date of issuance of this new SLP, it is highly unclear what, other than “risk to life, limb, or environmental safety,” would qualify as “exceptional and urgent circumstances.” In any event, the policy is notable for the suggestion to “provide written attestation demonstrating these circumstances” when applying for a license. Presumably, the new policy of denial applies to SLPs in the ITSR such as 560.523, 560.527, 560.545 and 560.549. While this can be discerned somewhat by reviewing the Iran-related licenses in the Research System, there has never been a formal accounting of transactions for which there had been a favorable specific licensing policy. How, for example, would SLs for the receipt of funds from newly designated entities be treated? Not “exceptional and urgent circumstances,” but also not something the denial of which would make much sense given the policy underlying the issuance of this document.