On June 22, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License X (GL X), authorizing a broad range of transactions involving Iranian-origin crude oil and related products, following the June 17, 2026 signing of a 14-point Memorandum of Understanding (MOU) between the United States and Iran that established a framework for de-escalation and targeted sanctions relief.
The MOU provides for a 60-day (extendable) period during which both sides will implement initial steps while continuing negotiations. The agreement also provides for limited, targeted sanctions relief at the outset, with the possibility of additional relief depending on progress in discussions, particularly those related to Iran’s nuclear program.
Sanctions-related measures are expected to be implemented through executive action, including waivers and licenses issued by OFAC under existing authorities, including the International Emergency Economic Powers Act (IEEPA), 50 U.S.C. §§ 1701–1707. Initial steps in this direction are already reflected in measures such as OFAC’s issuance of GL X. The United States has also committed not to impose new sanctions during the negotiation period and to make certain Iranian funds available through appropriate licensing frameworks.
Implications for Sanctions Relief and Next Steps
The MOU points to the possibility of broader sanctions relief as part of a future comprehensive arrangement, including the potential lifting of U.S. primary and secondary sanctions and certain multilateral restrictions. Any such relief would depend on the outcome of negotiations, agreed timelines, and verification of Iran’s commitments.
While initial measures are already being implemented, the agreement leaves more complex issues, particularly nuclear constraints and longer-term sanctions relief, to ongoing discussions.
Any subsequent nuclear-related agreement may be subject to the Iran Nuclear Agreement Review Act of 2015 (INARA), 42 U.S.C. § 2160e. INARA requires submission of such agreements to Congress and establishes a defined review period during which certain sanctions relief cannot take effect. Congress may also consider a joint resolution of approval or disapproval, and INARA imposes ongoing reporting and certification requirements tied to Iranian compliance. In practice, the removal of certain sanctions might require congressional involvement.
Compliance Considerations
Despite these developments, Iran remains subject to comprehensive U.S. sanctions, and existing restrictions continue to apply except where OFAC authorizations have been issued. Recent OFAC enforcement activity targeting Iran-related conduct underscores that the compliance environment has not materially changed absent clear implementing measures.
Therefore, companies may wish to proceed with caution, ensuring that any Iran-related activity is clearly authorized, closely monitoring regulatory developments, and maintaining robust sanctions compliance controls. Businesses should also remain mindful of the potential for changes as negotiations continue.
General License X: Scope and Practical Effect
GL X authorizes a broad category of transactions involving Iranian-origin crude oil, petrochemical products, and petroleum products through Aug. 21, 2026.
The license authorizes transactions that are “ordinarily incident and necessary” to the production, sale, delivery, and offloading of Iranian-origin crude oil, petrochemical products, and petroleum products. This includes a broad range of related services, such as shipping, insurance, financing, vessel operations, and other maritime support services, and permits U.S. dollar payments (which had long been prohibited) involving Iran or blocked persons where tied to covered transactions. GL X-authorized transactions also include the importation into the United States of Iranian-origin crude oil, petrochemical products, and petroleum products, provided that such importation is ordinarily incident and necessary to the sale, delivery, or offloading of those products under the terms of the license.
The license is subject to important limitations. As noted above, it is time-limited and expires on August 21, 2026. It does not authorize transactions involving persons located in, or organized under the laws of, certain comprehensively sanctioned jurisdictions, including North Korea, Cuba, and specified regions of Ukraine, nor does it permit activities prohibited under other applicable authorities that are not listed in GL X.
GL X also does not authorize transactions with designated Foreign Terrorist Organizations (FTOs), including the Islamic Revolutionary Guard Corps (IRGC), which remains heavily involved in Iran’s energy sector. As a result, transactions that directly or indirectly involve such entities may present material legal risk, including potential exposure under statutes relating to the provision of support to designated terrorist organizations. This risk is heightened by the IRGC’s use of entities such as the Persian Gulf Strait Authority (PGSA), which has imposed tolls on vessels transiting the Strait of Hormuz; cooperating with or making payments to such entities may be viewed as providing support to the IRGC and may give rise to sanctions liability.
As with all OFAC general licenses, GL X may be amended, suspended, or withdrawn at any time. Accordingly, parties relying on the authorization may wish to enhance ongoing compliance monitoring, confirm that transactions remain within the scope of the license, and do not involve prohibited parties or activities outside its terms.