On June 22, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a broad general license authorizing the production, delivery, and sale of Iranian-origin crude oil, petrochemical, and petroleum (“oil”) products through 12:01 a.m. eastern standard daylight time, August 21, 2026.

General License X (“GL X”) was issued in connection with the U.S.-Iran Memorandum of Understanding signed on June 17, 2026. GL X authorizes transactions otherwise prohibited under one or more of eleven authorities listed in the license, including under several Iran, Russia-related and counter-terrorism sanctions programs and other recent executive orders.

At a high-level, takeaways from GL X include the following:

• GL X seeks to authorize a broad range of activities related to the sale and transport of Iranian-origin oil
  • Transactions involving the production, sale, delivery, or offloading of Iranian-origin oil that would be prohibited are authorized under GL X, which includes importing Iranian oil into the U.S., and payments for authorized Iranian oil made to Iran, the Government of Iran, or any blocked person may be made in U.S. dollars.
  • Companies involved in plant engineering or the extraction of Iranian-origin oil, including suppliers to midstream and upstream facilities, may benefit from the exemption if their activities are “ordinarily incident and necessary to the production, sale, delivery, or offloading” of Iranian oil.

• Maintenance License Included for Ancillary Vessel and Crew-Related Services
  • Transactions for the safe docking, anchoring, and preservation of the health or safety of the crew of vessels carrying or storing Iranian oil are authorized under GL X, including services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage. As a result, maritime insurers, ship managers, flag registries, classification societies, and others in the maritime transport chain may face incrementally reduced risk.

• Exclusions for Other Comprehensively Sanctioned Jurisdictions and Specially Designated Nationals Are Maintained and International Sanctions Remain in Place
  • GL X excludes any transaction involving a person located in or organized under the laws of the Democratic People’s Republic of Korea, the Republic of Cuba, the Covered Regions of Ukraine, the Crimea Region of Ukraine, or any entity that is owned or controlled by, or in a joint venture with, such persons.
  • Although GL X authorizes certain transactions related to OFAC’s Russia sanctions programs, it does not authorize Russian-origin oil products.
  • Companies dealing with Iranian-origin oil sold by Russian companies should conduct appropriate due diligence.
  • Likewise, a waiver allowing the sale and transport of Iranian-origin oil does not affect other transactions or activities prohibited by OFAC sanctions, including any transactions or dealings involving other blocked persons that fall outside the scope of GL X.
  • GL X naturally also does not affect EU or UK sanctions frameworks, which, in 2025, underwent substantial expansions in scope and restrictive measures.

Ultimately, although General License X seeks to offer a temporary waiver of sanctions prohibitions around the Iranian oil trade, in conjunction with ongoing US-Iran negotiations arising from their June 17 MOU, the complex legal risks and practical difficulties arising from any dealings with Iran and its affiliated entities in the oil trade counsel significant caution.

If you have any questions regarding the matters covered in this email or other risks associated with General License X, please contact Bruce Paulsen (212) 574-1533, Brian Maloney (212) 574-1448, or your primary Seward & Kissel attorney.