On June 22, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Iran General License X, “Authorizing the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian-Origin through August 21, 2026.” This general license temporarily authorizes transactions prohibited by various listed OFAC regulations and presidential Executive Orders “that are ordinarily incident and necessary to the production, sale, delivery, or offloading of crude oil, petrochemical products, or petroleum products of Iranian origin,” including transactions involving blocked vessels.

Such transactions include: “transactions for the safe docking and anchoring of vessels carrying such crude oil, petrochemical products, or petroleum products; the preservation of the health or safety of the crew of any such vessel; emergency repairs or environmental mitigation or protection activities relating to any such vessel or to such crude oil, petrochemical products, or petroleum products held in storage; and services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage.” The license makes clear that transactions authorized by the general license also includes “the importation into the United States of crude oil, petrochemical products, and petroleum products of Iranian origin, where such importation is ordinarily incident and necessary to the sale, delivery, or offloading of such crude oil, petrochemical products, or petroleum products authorized by this general license.”

Iranian-origin crude oil petrochemical products, and petroleum products subject to this general license include those produced by entities sanctioned under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560, Iranian Financial Sanctions Regulations, 31 C.F.R. Part 561, or the Global Terrorism Sanctions Regulations, 31 C.F.R. Part 594. Payment for any authorized transactions may be made in U.S. dollars.

This general license requires close review by parties intending to rely on it for conducting any oil-related transactions with Iran as it notes several continuing prohibitions, including transactions covered by other Executive Orders not identified in this general license.

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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.