General License V

General Licence V is an OFAC authorisation issued on 24 April 2026 simultaneously with the designation of Hengli Petrochemical (Dalian) Refinery Co. Ltd — China's second-largest independent teapot refinery at roughly 400,000 Barrels Per Day — under sanctions bulletin sb0472. It permits Hengli and counterparties to complete, unwind, and wind down existing transactions that would otherwise be blocked by the new designation, with a 30-day wind-down expiry of 24 May 2026 . The licence was the only signed Iran instrument issued during the entire conflict at that date. Hengli denied any Iran trade on 26 April; China's Washington embassy called the designation 'illegal unilateral sanctions'. Hengli responded by pre-positioning three months of crude inventory and cutting its Singapore trading Arm's stake from 100% to 5%, transferring the remainder to a Chinese local government entity to insulate physical refining operations from OFAC reach within the GL-V window .

General Licences are a standard OFAC tool — blanket authorisations permitting specific activities that would otherwise violate US sanctions — issued under Executive Order 13902 (targeting Iran's construction, mining, manufacturing, and textiles sectors) and EO 13846 (reimposing nuclear-related sanctions). GL-V sits in a series of Iran-related instruments: it follows GL-U (the Iranian crude waiver for vessels loaded before 20 March, which lapsed 19 April 2026 with no renewal) and precedes GL-W (a wind-down instrument for newly blocked Iran-related persons issued 1 May 2026). Unlike GL-U, which covered a broad fleet of 325 tankers, GL-V is entity-specific, targeting a single Chinese corporate group and its majority-owned subsidiaries.

The GL-V designation is the first OFAC instrument to name Chinese refiners by designation — historically a threshold OFAC had avoided to prevent direct US-China economic escalation. Eight days after GL-V's issuance, China's MOFCOM activated its 2021 Blocking Rules for the first time on 2 May 2026, naming five Chinese refineries (Hengli Petrochemical (Dalian), Shandong Shouguang Luqing, Shandong Jincheng, Hebei Xinhai Chemical, and Shandong Shengxing) as legally barred from complying with OFAC's designations . With three days to expiry on 21 May 2026, Hengli Petroleum Singapore had begun laying off staff — the refinery's own operational signal that the dollar door is closing regardless of MOFCOM's blocking instructions. From Monday 25 May, any bank that clears a US-dollar Hengli payment loses US correspondent access; the secondary-sanctions trigger is automatic and requires no further OFAC action beyond the existing clock . The 24 May expiry is the first hard-dated OFAC-MOFCOM enforcement moment of the Iran war and the only Iran-relevant US instrument with a written timetable after 82 days of unsigned conflict management.