On June 22, 2026, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a new general license (Iran General License X or “GL X”) as the first step in implementing the US-Iran Memorandum of Understanding (“MOU”) to end recent hostilities in the Middle East. The MOU has not been formally or officially published by US Government agencies such as the State or Treasury Departments but its text has widely been reported and confirmed in news articles such as this BBC report. GL X provides broad authorization for parties to purchase and resell Iranian crude oil, petrochemical products, and petroleum products (together, “Iranian Energy Products”).
The MOU sets out the measures the United States and Iran have agreed on, including a commitment to negotiate a final deal that could lead to the lifting of US unilateral and other categories of sanctions against Iran in exchange for an agreement on nuclear issues. The final deal is to be negotiated within 60 days, which can be extended by the parties. Under the MOU, the United States will end its naval blockade of Iran and Iran will permit safe passage of commercial vessels through the Strait of Hormuz. Longer term, the MOU includes a provision under which the United States has agreed to develop “a definitive, mutually agreed plan with at least $300 billion (£225 billion) for the reconstruction and economic development of” Iran that will be part of a final deal for which the US Government has committed to issuing “required licenses, waivers and permissions.”
The immediate sanctions relief that the US Government agreed to under the MOU include (1) the issuance of “waivers for the export of Iranian crude oil, petroleum products and derivatives and all associated services including banking, transactions, insurances, transportation, etc.” and (2) releasing to Iran frozen or restricted funds and assets pursuant to procedures to be agreed upon. GL X is the implementation of the first immediate sanctions-related commitment by the US Government under the MOU. Broader sanctions relief is to be addressed in an agreed upon schedule as part of the final deal.
GL X authorizes all transactions prohibited under various US sanctions programs “that are ordinarily incident and necessary to the production, sale, delivery, or offloading of crude oil, petrochemical products, or petroleum products of Iranian origin” through 12:01 am EDT on August 21, 2026 (which aligns with the current 60-day negotiation period). OFAC has not published public guidance about the scope of GL X, nor have the White House or State or Treasury Departments provided explanations about GL X or the MOU. However, several notes in the authorization indicate that it is meant to facilitate shipments and sales of the Iranian Energy Products on global markets, including into the United States and with the involvement of vessels sanctioned under any of the US sanctions authorities cited. Furthermore, GL X provides that authorized payments may be made in “US-dollar denominated funds.”
One restriction under GL X is that authorized transactions may not involve individuals or entities located in or organized under the laws of Crimea, Cuba, Donetsk People’s Republic, Luhansk People’s Republic, or North Korea nor any entity owned or controlled by or in a joint venture with parties from those sanctioned jurisdictions. Unlike some comparable energy-sector general licenses that OFAC has recently issued in connection with Venezuela (such as General License No. 48B), note that GL X covers only “production” but not “exploration” or “development” of crude oil and GL X does not incorporate reporting requirements.
We will continue to monitor developments related to implementation of the MOU and negotiations of a final deal. In the coming days, we may see public guidance from OFAC to help better understand GL X, including whether the agency will adopt its usual approach that non-US parties engaging in transactions covered by the general license should not face US secondary sanctions risks.
