Skip to content
Welcome, thoughtbot's Giant Robots listeners!Start here
General Licence DD
AI-generated illustration
LegislationUS

General Licence DD

OFAC wind-down licence for transactions affected by the 8 September aviation sanctions.

General Licence DD expired at 00:01 Eastern on 23 September 2026 with no successor. It had been the only American cover for Iranian overflight payments, bunkering and emergency ship repairs.

Last refreshed: 1 October 2026 · Appears in 1 active topic

Timeline for General Licence DD

#180 23 Sept

Expired on 23 September 2026 with no successor issued

Iran Conflict 2026: OFAC lets the ship repair licence lapse
#179 21 Sept
#178 11 Sept

Set a 23 September cut-off for settling overflight and bunkering obligations

Iran Conflict 2026: Two Iran wind-down windows shut four days apart
#177 7 Sept
View full timeline →

Background

General Licence DD was a wind-down authorisation, not a standing permission. The Office of Foreign Assets Control issued it on 8 September 2026, the day it suspended General Licence J-1, so that parties could unwind civil-aviation business already under way rather than face an immediate cut-off.

It covered three authorities: payments for flying over Iranian airspace at 31 CFR 560.522, refuelling or emergency repairs to a ship at 31 CFR 560.529, and certain civil aircraft flights into Iran and out again under General Licence J-1. Aircraft safety at 31 CFR 560.528 was left off the list. Publication in the Federal Register on 11 September 2026 put the expiry date on the public record twelve days ahead.

The licence expired at 00:01 Eastern on 23 September 2026 with no successor. OFAC is not required to announce a lapse and made none, which is the durable lesson: the absence of an Iran authority has to be read off a live list rather than waited for as a notice.

Key Issues
Sanctions licences

Expiry left no successor authority

The licence closed at 00:01 Eastern on 23 September 2026 and nothing replaced it. With it went the only American cover for paying Iranian overflight charges, bunkering a ship in Iran and carrying out emergency repairs there. A US person or US-linked insurer helping a ship in distress near Iranian waters now needs a licence of its own, or the narrower safety and environmental terms of General Licence T.

The Federal Register carried the expiry date on 11 September 2026, twelve days early. As of 21 September the live general-licence page still showed no extension, amendment or supersession marker against it. Airlines owing Iranian overflight charges had one working day to pay them into a blocked account; the same payment made later is a violation.

Common Questions
What does General Licence DD authorise?
It lets parties wind down civil-aviation transactions affected by the 8 September 2026 suspension of General Licence J-1 and the related airline designations.Source: update body
Why did OFAC issue General Licence DD?
To let pre-existing transactions unwind after OFAC suspended General Licence J-1 and designated 27 Iranian airlines on 8 September 2026.Source: update body
Who does General Licence DD cover?
Persons winding down transactions affected by the General Licence J-1 suspension and the 8 September 2026 airline designations.Source: update body
When does General Licence DD's wind-down period end?
12:01 a.m. eastern daylight time on 23 September 2026, per the licence's own text.Source: OFAC, Iran General License DD PDF (ofac.treasury.gov/media/936901/download), paragraph (a)