On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of Iran-related sanctions designations targeting Iranian financial facilitator Ali Ansari and his financial network, as well as several Iranian exchange houses accused of facilitating transactions for sanctioned Iranian banks. Concurrently, OFAC issued General License Y (“GL Y”), authorizing the temporary wind down of transactions involving Smart Global Limited, a newly designated holding company allegedly controlled by Ansari.…
On July 7, 2026, the US Treasury Department’s Office of Foreign Assets Control revoked Iran General License X (“GL X”), which would have otherwise been valid through August 21, 2026. GL X was issued in June to authorize the production, delivery, and sale of Iranian crude, petrochemical products, and petroleum products. See our earlier summary here. OFAC replaced GL X with a narrow wind-down authorization issued as Iran General License X1 (“GL X1”). Under GL…
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…
Since issuing its Frequently Asked Questions (“FAQ”) 1249 on April 28, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has updated its position with respect to “toll” payments to Iran for safe passage through the Strait of Hormuz. At the time of its publication, FAQ 1249 made it clear that payments to Iran for “safe passage” through the Strait of Hormuz are prohibited for U.S. persons. However, to further maximize…