The Office of Foreign Assets Control (OFAC), the US Treasury bureau that administers sanctions programmes, indefinitely stayed five Iran general licences with effect from Monday 24 August1. A general licence is a standing authorisation that permits a class of otherwise prohibited transactions without anyone applying for it. The five cover section 560.544 of the Iranian Transactions and Sanctions Regulations, on educational activities by US persons in third countries, 560.550 on noncommercial personal remittances to and from Iran, 560.554 on conference services, and General Licences F and G covering sports and academic exchange. Transactions already under way may be wound down only until 8 September2.
Section 560.550 is the one with the longest paper trail behind it. It exists because ordinary family transfers were being refused by banks that could not price the legal risk of handling them, so Treasury wrote an authorisation that told them the risk was zero. Withdrawing it does not return the position to neutral. It restores the over-blocking the licence was written to cure, and it does so through private compliance departments rather than through any instrument a person can appeal.
Two weeks of wind-down covers a bank's paperwork and does not cover a semester, an exchange programme or a family sending money on a monthly cycle. Switzerland was separately rebuilding the forms that carry lawful money into Iran through its own system in the same fortnight, which leaves the compliant channels in both jurisdictions changing shape at once.
Designations aimed at companies and vessels reach a household indirectly, through the bank that clears its transfers. A suspended remittance licence reaches it on the day it takes effect.
