On July 7, U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)  issued General License X1 (“GL X1”) which immediately revokes and supersedes the 60-day sanctions waiver over Iranian-origin crude oil, petrochemical, and petroleum (“oil”) products under General License X (“GL X”) effective July 7, 2026, as detailed in our prior alert. This removes sanctions relief to transactions involving the production, sale, delivery or offloading of Iranian-origin crude oil or concerning any blocked vessels under the authorities covered by the GL X, which was originally scheduled to extend until August 21, 2026. 

With the exception of a wind-down period for previously authorized transactions, GL X1 does not permit any new transactions, including purchases or loading of crude oil, petrochemical products, or petroleum products of Iranian origin on or after July 7.

The wind down period for transactions previously authorized by GL X is authorized through 12:01 a.m. eastern daylight time on July 17, 2026.

Public reports suggest that the revocation is related to indications that three tankers were attacked in the Strait of Hormuz in recent days, highlighting the unpredictability of ongoing US-Iran negotiations, and the fragility of the original sanctions waiver relief.

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