On March 20, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Iran-related General License U (“GL U”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026.” One day earlier, on March 19, 2026, OFAC issued Russia-related General License 134A (“GL 134A”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026,” amending the previously issued GL 134, which was the subject of our prior blog post. Both actions are part of the Administration’s continuing efforts to ease pressure on global energy markets amid ongoing disruptions.
Iran-Related General License U
GL U authorizes all transactions otherwise prohibited under various (mostly Iran-related) sanctions programs that are ordinarily incident and necessary to the sale, delivery, or offloading of Iranian-origin crude oil or petroleum products already loaded onto vessels until 12:01 a.m. EDT on April 19, 2026.
GL U authorizes such transactions subject to the following conditions:
- The Iranian-origin crude oil or petroleum products must have been loaded onto vessels on or before 12:01 a.m. EDT on March 20, 2026;
- Transactions cannot involve a person located in or organized under the laws of, or an entity owned or controlled by or in a joint venture with a person located in or organized under the laws of, Cuba, North Korea, and certain Russian government-controlled areas of Ukraine subject to comprehensive US sanctions; and
- Transactions cannot be prohibited under other OFAC sanctions programs not referenced in GL U.
Notably, GL U explicitly authorizes the importation of Iranian-origin crude oil or petroleum products into the United States where such importation is ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products authorized by this license.
Similar to OFAC’s recent Russia-related GL 134, GL U explicitly authorizes (1) transactions involving products produced by entities sanctioned under OFAC’s Iran-related sanctions programs, and (2) ancillary services ordinarily incident and necessary to complete the authorized voyages, including bunkering, crewing, vessel management, insurance, classification, salvage, and port services.
Amended Russia-Related General License 134A
On March 19, 2026, OFAC also amended Russia-related GL 134 by issuing GL 134A. As discussed in our prior blog post, OFAC issued GL 134 on March 12, 2026, expanding the scope of authorized transactions involving Russian-origin crude oil and petroleum products beyond India to apply globally. Under General License 134, transactions involving Russian origin crude oil and petroleum products are authorized for crude oil and petroleum products loaded onto vessels prior to 12:01 am ET on March 12, 2026, until 12:01 am ET on April 11, 2026.
The new GL 134A includes a restriction prohibiting transactions involving a person in or organized under the laws of North Korea, Cuba, Iran, the Crimea, Donetsk, and Luhansk regions of Ukraine, or a transaction involving any entity that is owned or controlled by or in a joint venture with any such person. This restriction mirrors a similar exclusion in GL U (which excludes persons from Cuba, North Korea, and certain Russian government-controlled areas of Ukraine, but does not exclude persons from Iran).
Takeaways
GL U is a notable development as it represents the first OFAC general license broadly authorizing transactions involving Iranian-origin crude oil and petroleum products, including their importation into the United States. Together with GL 134A, these temporary authorizations signal the Administration’s willingness to use targeted, short-term sanctions relief as a tool to manage energy market disruptions, even where doing so involves easing long-standing restrictions. GL U is an exceptional (but still short-term) waiver of Iran-related oil sanctions as OFAC continues to respond to ongoing energy market disruptions. Affected parties should carefully evaluate whether their planned transactions fall within the scope and conditions of GL U and GL 134A and should note the limited duration of each authorization.
We are closely monitoring Iran and Russia sanctions developments and will continue to post updates to this blog.
