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European Tech Sovereignty
22SEP

Two Iran wind-down windows shut four days apart

3 min read
10:47UTC

OFAC gazetted General Licences CC and DD in the Federal Register on Friday 11 September. Holland & Knight reads the notice as expiring the banking licence on 19 September and the aviation licence on 23 September.

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OFAC, the Office of Foreign Assets Control that runs US sanctions programmes, gazetted Iran-related General Licence CC and General Licence DD in the Federal Register on Friday 11 September 2026 as Document 2026-18576 1. The law firm Holland & Knight, reading the notice for clients, puts the expiry of General Licence CC at 00:01 Eastern time on Saturday 19 September and General Licence DD at 00:01 Eastern on Wednesday 23 September 2. The 23 September date has not previously appeared in reporting.

A general licence is standing permission that nobody has to apply for, and a wind-down licence is the narrow version: a fixed period in which existing business may be closed out and nothing new begun. General Licence CC covers dealings with the three Golden Global institutions OFAC designated on 4 September over alleged transactions for the Revolutionary Guard's Quds Force . Golden Global Yatirim Bankasi denied the allegations to Turkey's disclosure platform the same evening , and the group's asset manager closed three funds to new subscriptions four days later .

General Licence DD covers aviation, and it permits only the settling up. It was issued on 8 September alongside the suspension of General Licence J-1, the standing carve-out that had let non-Iranian carriers pay to overfly Iran, take on fuel there and make emergency or temporary landings . A carrier holding an unpaid overflight invoice from before 8 September, a fuel bill from an Iranian airport, or an aircraft still on Iranian ground has until 23 September to clear it. Pay the same invoice on 24 September and it becomes a violation rather than a wind-down.

OFAC is retiring these exits on a published calendar rather than closing them in one stroke. OFAC adopted a presumption of denial for Iran licence applications on 10 September , so a counterparty that misses its window applies into a queue whose default answer is no.

Deep Analysis

In plain English

American sanctions law does not simply ban a company from dealing with a sanctioned party overnight. It usually gives a window to unwind existing business: pay the outstanding invoice, close the account, get the aircraft home. That window is called a wind-down licence. The US Treasury has now published two of them for Iran. One covers dealings with three Turkish financial institutions sanctioned on 4 September. The other covers airlines that used to pay to fly over Iran, refuel there or land there in an emergency. A law firm reading the published notice says the first window shuts on 19 September and the second on 23 September. After that, paying the same old bill stops being permitted tidying-up and becomes a breach.

Deep Analysis
Root Causes

Sanctions exposure does not sit in new business. It sits in unsettled invoices, custody positions and aircraft that are already somewhere, and closing those takes signatures from parties who are not being sanctioned and have no deadline of their own.

The two licences reach different populations. General Licence CC is a banking and funds problem: correspondent relationships, distributors and custodians holding Golden Global paper. General Licence DD is an aviation problem: overflight billing, bunkering settlements and aircraft on Iranian ground. Almost nobody is exposed to both.

A wind-down licence only helps a party that has spotted its own exposure. A custodian holding fund units through a distribution platform, or a lessor whose aircraft was serviced under a subcontract, can hold exposure without a name on any designation list, and the calendar runs for them at the same speed.

Escalation

Up, on a fixed calendar rather than on a decision. The trigger dates are 19 and 23 September, and the party that moves is any counterparty that discovers its exposure after the window has shut.

What could happen next?
  • Consequence

    Any Golden Global counterparty still holding exposure after 19 September has no authorised route out and has to choose between freezing the position and explaining a transfer to Treasury.

    Short term · Assessed
  • Risk

    The 23 September aviation date has not previously appeared in reporting, so an exposed lessor or maintenance provider may not know the window exists.

    Immediate · Assessed
  • Precedent

    Retiring carve-outs on a published calendar rather than in one stroke lets Treasury fix the date exposure crystallises without naming a single counterparty.

    Long term · Suggested
Sources:Federal Register / US Treasury OFAC·Federal Register / US Treasury OFAC·Holland & Knight
Mentions:OFAC →Federal Register →Holland & Knight →Islamic Revolutionary Guard Corps (IRGC) →IRGC Quds Force →Emirates →Iran →Qatar →Turkey →Tehran →United States →US Treasury →European Union →
First Reported In

Update #178 · Saudi bypass hit, and Riyadh holds fire

Federal Register / US Treasury OFAC· 13 Sept 2026
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Causes and effects
Caused by
OFAC blacklists three Turkish Golden Global institutions
General Licence CC winds down dealings with the Golden Global entities designated on 4 September.
Occurred 3 Sept 2026
Read story →
OFAC designates 27 of Iran's airlines
General Licence DD winds down the aviation dealings left by the suspension of General Licence J-1.
Occurred 7 Sept 2026
Read story →
Treasury defaults Iran licences to no
A presumption of denial means no replacement authorisation follows the wind-down.
Occurred 9 Sept 2026
Read story →
Golden Global shuts three of its funds
Golden Global closed three funds before the wind-down window was gazetted.
Occurred 7 Sept 2026
Read story →
Golden Global denies the allegations that same evening
The designated bank's denial stands against the licence that winds its business down.
Occurred 4 Sept 2026
Read story →
This Event
Two Iran wind-down windows shut four days apart
Banking and aviation counterparties lose their authorised route out of Iranian business within four days of each other, on a published calendar.
Led to
Iran aviation licence expires 23 Sept
General Licence DD was gazetted on 11 September and now approaches its own expiry.
Reported 21 Sept 2026
Read story →
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