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General Licence AA
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General Licence AA

OFAC licence authorising wind down of dealings with sanctioned French refiner La Nivernaise De Raffinage.

OFAC's Iran general licences lapsed through September 2026, leaving General Licence AA the only one live, and it expires at 00:01 Eastern on 23 October 2026. Its terms cover the wind-down of dealings with one French refiner and no bunkering or salvage work.

Last refreshed: 1 October 2026

Key Question

Which single company does the only live Iran general licence actually cover?

Timeline for General Licence AA

#180 23 Sept

Named as the most recent Iran general licence on OFAC's live list

Iran Conflict 2026: Mentioned in: OFAC lets the ship repair licence lapse
View full timeline →

Background

OFAC signed General Licence AA on 24 August 2026 and published its text in the Federal Register three days afterwards, as document 2026-17491. The licence sits under Executive Order 13902, the January 2020 instrument reaching Iran's construction, mining, metals and energy sectors. What it permits is narrow: ordinary wind-down of transactions involving La Nivernaise De Raffinage SAS, a French refiner, plus maintenance of operations and contracts already in effect on the day of signing. Cover extends to any company in which the refiner holds half or more.

Paragraph (b) draws the boundary. Dealings with any other person blocked under the same order need their own authorisation, and the document carries no annex of vessels and no safety, environmental or salvage terms. That distinction matters, because other licences in the Iran programme did carry such terms and have since run out.

OFAC uses letter-series general licences to close a position in an orderly way after a designation, not to open trade. Read that way, General Licence AA records one French refiner's removal from the lawful market and the window Washington allowed its counterparties. The window shuts at 00:01 Eastern on 23 October 2026, and nothing in the document extends it.

Key Issues
Iran licence expiries

General Licence AA outlasted the others

OFAC issued General Licence AA on 24 August 2026 and gazetted it three days later. Through September the other Iran authorisations ran out. General Licence CC ended on 19 September, General Licence DD on 23 September. That second expiry removed the standing cover for overflight payments, ship refuelling and emergency repairs.

Anyone reading OFAC's live list on 1 October 2026 finds General Licence AA at the top of it. That position invites the wrong inference, that the newest licence replaced the cover which lapsed. Its authorisation reaches only the wind-down of business with La Nivernaise De Raffinage SAS. The permission stops at 00:01 Eastern on 23 October 2026. A shipowner facing a salvage call near Iran must now seek specific authorisation instead.

Common Questions
what does General Licence AA authorise?
It permits transactions that wind down business with the French refiner La Nivernaise De Raffinage SAS, or that maintain contracts already in effect on 24 August 2026. Executive Order 13902 would otherwise forbid them.Source: https://www.federalregister.gov/documents/2026/08/27/2026-17491/publication-of-iran-related-web-general-licenses-aa-and-bb
when does General Licence AA expire?
At 00:01 Eastern time on 23 October 2026. It was issued on 24 August 2026 and remained in force as at 1 October 2026.Source: https://www.federalregister.gov/documents/2026/08/27/2026-17491/publication-of-iran-related-web-general-licenses-aa-and-bb
does General Licence AA cover ship repairs or bunkering near Iran?
No. It carries no safety, bunkering or salvage terms. The standing cover for bunkering and emergency repairs ended when General Licence DD expired on 23 September 2026, and OFAC has named no successor.Source: https://www.federalregister.gov/documents/2026/08/27/2026-17491/publication-of-iran-related-web-general-licenses-aa-and-bb
who is covered by General Licence AA?
La Nivernaise De Raffinage SAS, and any company in which it holds a 50 per cent or greater interest. Dealings with any other blocked person need separate authorisation.Source: https://www.federalregister.gov/documents/2026/08/27/2026-17491/publication-of-iran-related-web-general-licenses-aa-and-bb
Source Material