General Licence DD, signed by OFAC on 8 September, permits only wind-down: settling overflight payments, bunkering and emergency repairs, and the temporary sojourn of civil aircraft. It expires at 00:01 Eastern on Wednesday 23 September1, and as of Monday 21 September OFAC's live general-licence page carried no extension, amendment or supersession marker against it2. The licence and its sibling were gazetted in the Federal Register on 11 September, so the expiry date has been public for a fortnight.
A carrier holding an unpaid Iranian overflight invoice has until Wednesday to pay it into a blocked, interest-bearing US account, which leaves one working day. The licence authorises only that closing-out step and never permitted new business. The same payment made on Wednesday afternoon becomes a violation with no cover, and the obligation does not disappear with the authority to settle it.
That is the trap in a wind-down instrument that nobody extends. Carriers still owe historic Iranian overflight charges for flights already flown. Let the licence lapse and those debts sit unpayable and unforgiven, which is a compliance problem for the airline's auditors long after the last flight. Whether OFAC extends, replaces or simply lets the clock run is the single thing to watch before Wednesday morning.
