OFAC's General License U (GL-U, the authorisation that kept 325 tankers carrying roughly $31.5 billion of Iranian crude legally tradeable in transit) lapsed at 00:01 EDT on 19 April 2026 with no renewal, no replacement General License, and no Federal Register notice1. The US Treasury Office of Foreign Assets Control, which administers Iran and Russia sanctions, neither extended the instrument nor terminated it by signed action; it simply did not sign.
The lapse had been on the board since Update #283, when Treasury's 25-day post-expiry silence first made non-renewal the base case. Treasury Secretary Scott Bessent told cable television on 15 April that GL-U would not be renewed and OFAC issued no designations alongside the statement. He repeated the non-renewal on 16 April without attaching a Federal Register instrument. The 19 April lapse is the execution of a path Bessent had already narrated on camera.
On a shipping compliance desk, the change reads starkly. Cargoes loaded before 00:01 EDT sit in a legal twilight where secondary-sanctions exposure depends on buyer jurisdiction and bank appetite rather than a written carve-out. Indian state refiners hold an estimated 60 to 70 per cent of that uncovered crude; Chinese terminals hold most of the rest. No document tells either where the line is, because Treasury did not publish one.
An OFAC lapse without a successor General License, without an Executive Order, and without a Federal Register notice is an enforcement event whose author is the gap in the paper trail. Compliance officers price the gap as policy, not administrative drift. With no replacement instrument on the page at the time of lapse, the 50-day no-Iran-instrument pattern now extends into the sanctions regime itself.
