The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued General License X, which authorizes, until August 21, 2026, certain transactions that are otherwise prohibited under sanctions regulations relating to the production, delivery, and sale of Iranian-origin crude oil, petrochemical products, and petroleum products.
General License X provides for a limited-time authorization of transactions that are ordinarily incident and necessary to the production, sale, delivery, or offloading of crude oil and Iranian-origin petrochemical products. Transactions involving vessels blocked under the sanction’s regimes referenced in General License X are also included within the scope of this exceptional authorization. Accordingly, such transactions may be carried out until
12:01 a.m. (EDT) on August 21, 2026.
“Ordinarily Incident and Necessary” Transactions
Transactions authorized under General License X include, inter alia, those relating to the safe berthing and anchoring of vessels carrying crude oil, petrochemical products, or petroleum products; the protection of the health and safety of crew members on such vessels; emergency repairs and environmental mitigation or protection activities related to such vessels or stored crude oil, petrochemical products, or petroleum products; as well as services such as vessel operations, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage services.
This exception also covers products produced by persons or entities included on sanctions lists, insofar as they are involved in the production chain of Iranian-origin crude oil, petrochemical products, and petroleum products, provided that certain conditions are met. However, this does not imply that unrestricted transactions with all sanctioned persons or entities are permitted; all transactions must be assessed in accordance with applicable sanctions regimes and other relevant regulations.
Transactions authorized under this general license also include, where they are ordinarily incident and necessary to the authorized sale, delivery, or offloading activities, the importation into the United States of Iranian-origin crude oil, petrochemical products, and petroleum products.
Payment Structure
Payments for permitted Iranian-origin crude oil, petrochemical products, or petroleum products may be made to Iran, the Government of Iran, or any blocked person, using U.S. dollar-denominated funds.
Expressly Excluded Transactions
Transactions involving persons located in or organized under the laws of the Democratic People’s Republic of Korea, Cuba, or certain regions of Ukraine, as well as entities owned, controlled by, or operating in joint venture with such persons, are excluded from the scope of this general license.
In addition, any transactions or activities prohibited under other sanctions programs or executive orders, beyond those expressly referenced in this general license, are also excluded from its scope
General Assessment
General License X provides a narrow and conditional exemption within the Iranian energy and petrochemical supply chain, particularly covering activities such as shipping, insurance, and port operations that would otherwise be subject to sanctions risk.
However, it remains essential to conduct a case-by-case assessment, including scope analysis and counterparty screening, to ensure compliance with all applicable conditions.
Furthermore, as General License X constitutes an OFAC-issued exemption only, it does not provide any relief under European Union or United Kingdom sanctions regimes. Accordingly, entities operating in the EU and the UK should ensure compliance with their respective sanctions frameworks, which have been updated in recent periods.
The General License X document can be accessed
here.
Aslı Kınsız, Managing Associate
Selen Akgün, Associate