OFAC revokes Iran General License X and gives firms ten days to wind down

What happened

On 7 July 2026, OFAC (the US Office of Foreign Assets Control) issued Iran-related General License X1, known as GL X1. A general license, or GL, is a standing authorization that permits transactions otherwise prohibited by a sanctions programme. GL X1 revoked General License X, known as GL X, in its entirety, effective 7 July 2026. GL X had broadly authorized transactions involving Iranian crude oil, petroleum products, and petrochemical products. That authorization is gone.

GL X1 leaves one narrow path open. Parties are authorized through 12:01 am EDT on 17 July 2026 to engage in activities ordinarily incident and necessary to the wind down of transactions previously authorized by GL X. GL X1 does not authorize any new transactions, including purchases or loading of products, on or after 7 July 2026. It also requires that any payments to blocked persons be deposited into an interest-bearing account in the United States.

OFAC’s action followed reported attacks by Iran’s Islamic Revolutionary Guard Corps, the IRGC, on commercial tankers in the Strait of Hormuz, and subsequent US retaliatory strikes. Those events are the reported trigger for the revocation. Before it was revoked, GL X had been valid through 21 August 2026.

Why it matters

Read that last fact again. GL X had weeks left to run, and OFAC pulled it anyway. The analysis point is simple and uncomfortable: a general license is a permission with an expiry, not a standing right, and the issuer can withdraw it before the stated date. Any position built on the assumption that GL X would survive to 21 August has now collapsed into a ten-day wind-down.

The wind-down clause is the part that will decide who ends up in trouble. It authorizes unwinding what already existed. It does not authorize continuing the business. Booking a new cargo, loading product, or renewing a contract on or after 7 July sits outside GL X1 entirely, no matter how routine the transaction looked on 6 July. The interest-bearing account requirement matters for the same reason: money owed to a blocked person cannot simply be paid away, and a firm that settles the ordinary way turns a wind-down into a potential violation.

The wider signal is that sanctions authorizations tied to a geopolitical bargain move with the geopolitics. Firms that treat a general license as a stable commercial input, rather than as a revocable policy instrument, are carrying a risk they have not priced.

Practitioner angle

• Run an immediate reliance sweep. Identify every transaction, contract, counterparty, vessel, and payment instruction that relied on GL X. If your sanctions screening cannot answer “which exposures sat under this license” from a data field, that is the gap to fix after the deadline.
• Confirm nothing new was booked. Check that no purchase, loading, or new obligation was created on or after 7 July 2026. Anything booked in that window needs escalation to your sanctions officer today, not at the next committee.
• Complete wind-down activity before 12:01 am EDT on 17 July 2026. Anything that cannot be completed by then should stop, not be pushed through. Document the decision either way.
• Route payments correctly. Any payment to a blocked person arising from the wind-down goes into an interest-bearing account in the United States, as GL X1 requires. Brief treasury and payment operations directly, because this is where a well-intentioned settlement becomes a breach.
• Put general licenses under version control. Track each license your business relies on, its stated expiry, and the exposures underneath it, and monitor OFAC’s recent actions page so a revocation is caught the day it lands rather than the week after.

The single most important action: identify every open GL X exposure and shut it down before 12:01 am EDT on 17 July 2026.