Treasury Publishes Now-Expired Iran Sanctions Get-Out-of-Jail-Free Licenses
Published Date: 9/23/2026
Rule
Summary
The Treasury’s Office of Foreign Assets Control (OFAC) published two special Iran-related licenses called GL Y and GL Z. These licenses let certain transactions happen that were otherwise blocked by sanctions, but both expired recently—GL Y on August 9, 2026, and GL Z on September 12, 2026. If you were dealing with Smart Global Limited or related entities, these licenses gave you a limited time to wrap up business without penalties.
Analyzed Economic Effects
3 provisions identified: 2 benefits, 1 costs, 0 mixed.
Temporary authorizations for listed vessels and persons
General License Z (issued July 14, 2026) allowed, through 12:01 a.m. Eastern daylight time on September 12, 2026, transactions ordinarily incident and necessary to wind down financial transactions, to safely dock/anchor and depart ports (excluding ports in or under control of Iran or the Russian Federation), to preserve crew health or safety, to make emergency repairs or environmental mitigation, and to deliver/offload cargo that was loaded on or before July 14, 2026, for the blocked persons and blocked vessels listed in the annex. Any payment to a blocked person under this license had to be made into a blocked interest-bearing account located in the United States; authorized services explicitly include vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage.
Limits on new contracts and Iran-related transactions
General License Z does not authorize entry into any new commercial contracts involving the property or interests of any blocked persons, and it does not authorize transactions or activities prohibited by E.O. 13902 or by other Executive Orders or parts of 31 CFR chapter V, including transactions involving Iran, the Government of Iran, or Iranian-origin goods or services prohibited by the Iranian Transactions and Sanctions Regulations (31 CFR part 560).
Wind-down authorization for Smart Global
If you did business with Smart Global Limited, General License Y (issued July 10, 2026) allowed transactions ordinarily incident and necessary to wind down those dealings through 12:01 a.m. Eastern daylight time on August 9, 2026. Any payment to a blocked person under this license had to be deposited into a blocked account in accordance with the Global Terrorism Sanctions Regulations (31 CFR part 594).
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Key Dates
Department and Agencies
Related Federal Register Documents
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