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OFAC Reinstates Iran Oil Sanctions — General License X1 Terminates Relief

On 7 July 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License X1, superseding the previously issued General License X and effectively terminating the sanctions relief framework that had been applied to Iranian crude oil, petroleum products, and petrochemical products.

Background

General License X had provided temporary sanctions relief following diplomatic developments and the June ceasefire. The issuance of GL X1 signals a return to maximum pressure enforcement on Iranian energy exports, consistent with the broader U.S. strategy of restricting revenue flows to Iran.

Key Provisions

  • GL X1 supersedes GL X: All previously authorized transactions under GL X are no longer permitted under the new license framework.
  • Wind-down period: A wind-down period was permitted through 12:01 AM EST on 17 July 2026, allowing parties to orderly conclude existing transactions.
  • Scope: The restrictions apply to Iranian crude oil, petroleum products, and petrochemical products — covering the full spectrum of Iran's energy export sector.

Compliance Impact

Companies involved in Iranian oil trade must immediately wind down any remaining transactions that were previously authorized under GL X. After the 17 July deadline, any such transactions will be in violation of OFAC sanctions and may result in significant civil and criminal penalties.

Screening against the OFAC Specially Designated Nationals and Blocked Persons List (SDN List) is critical for all parties in the energy supply chain. This includes vessel operators, commodity traders, financial institutions facilitating payments, and logistics providers.

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Primary Source

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) — General License X1, dated 7 July 2026.

Disclaimer: This content is for informational purposes only and does not constitute legal, financial, or trade compliance advice.

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