Iran's Mystery GL X Lives (and Dies) in Weeks
Published Date: 9/30/2026
Rule
Summary
The Treasury’s Office of Foreign Assets Control (OFAC) published two special Iran-related licenses called GL X and GL X1. GL X started on June 21, 2026, but was replaced by GL X1 on July 7, which then expired on July 17, 2026. These licenses allowed certain transactions that are usually banned, affecting businesses and individuals dealing with Iran, but the short time frame means the money impact was limited.
Analyzed Economic Effects
3 provisions identified: 2 benefits, 1 costs, 0 mixed.
Temporary OK to Trade Iranian Oil and Products
From June 21, 2026, OFAC’s General License X authorized transactions ordinarily incident and necessary to the production, sale, delivery, offloading, and importation into the United States of crude oil, petrochemical products, and petroleum products of Iranian origin through 12:01 a.m. eastern daylight time on August 21, 2026. The license also explicitly covered related services such as docking, crewing, bunkering, piloting, registration, insurance, and salvage and included products produced by entities sanctioned under specified Iran-related regulations.
Revocation and Short Wind‑Down Period Limits Activity
Effective July 7, 2026, OFAC revoked General License X and replaced it with General License X1, which only authorized transactions ordinarily incident and necessary to wind down transactions previously authorized by GL X through 12:01 a.m. eastern daylight time on July 17, 2026. GL X1 prohibited any new transactions (including purchases or loading on or after July 7, 2026) and required that any payment to a blocked person be made into a blocked, interest-bearing account located in the United States.
Payments to Iran Allowed in U.S. Dollars
General License X allowed payments of funds owed to Iran, the Government of Iran, or any blocked person for the purchase of authorized Iranian-origin crude oil, petrochemical, or petroleum products to be made in U.S. dollar-denominated funds. This payment permission was part of GL X issued June 21, 2026.
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