22OCT

OFAC publishes the licence it revoked

4 min read

17:24UTC

The Office of Foreign Assets Control put the full texts of General Licence X and its revoking instrument into the Federal Register on 30 September. The June licence had briefly let Iranian crude be produced, sold and shipped by blacklisted tankers.

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Key takeaway

Washington printed a June authorisation for Iranian crude sales six weeks after it stopped mattering.

OFAC put the full text of General Licence X and of General Licence X1, the instrument that revoked it, into the Federal Register on Wednesday 30 September 2026⁠¹. The Federal Register is the daily gazette where the American government has to print its rules before they bind anyone, and until that filing neither text was readable in full.

General Licence X was the June authorisation that briefly let Iranian crude be produced, sold and shipped, including by tankers already blacklisted. Issued on 21 June 2026 to run to 21 August, it expressly reached vessels blocked under seven sanctions programmes, the Iranian and the Russian ones among them⁠². Blocked means frozen out of any dealing with an American person or bank. General Licence X1 withdrew the authorisation in full on 7 July 2026, sixteen days after issue, allowing a wind-down only to 17 July⁠³. The June text shows what Washington was prepared to allow; the July revocation shows what collapsed. Both became readable on 30 September. On 14 September we reported that no Iran-specific presidential document had reached the Federal Register at all.

The same day Treasury filed a rule rather than a licence. An executive order is an instruction from the President; the Code of Federal Regulations is the rulebook that corporate compliance departments and American courts actually read. Executive Order 13902, signed in January 2020, let Washington sanction anyone working in Iran's construction, mining, manufacturing or textile sectors. Treasury wrote it into 31 CFR part 560 on 30 September, six years on, effective the same day with no consultation period, at Federal Register volume 91, page 61759⁠⁴.

The rule also adds a note at 31 CFR 560.425. Property of the Government of Iran or of an Iranian financial institution is blocked under Executive Order 13599 whether or not the name appears on the Specially Designated Nationals list⁠⁵, the blacklist that freezes a named party out of the dollar. A bank can no longer treat a missing name as a clean one, which removes a defence built on absence from the list and shifts the screening burden onto ownership research. A lawyer clearing a six-year backlog would file exactly these documents, and nothing in the rule says which it was.

Deep Analysis

In plain English

American sanctions on Iran come in two layers. Presidents sign executive orders, which bite immediately, and the Treasury Department later writes those orders into a permanent rulebook, the Code of Federal Regulations, which is what banks screen against and what courts read. On 30 September 2026 the Treasury finally wrote an order signed in January 2020 into that rulebook. It also added a short note saying something important in plain terms: property belonging to the Iranian government or an Iranian bank is frozen whether or not that name has ever appeared on the published sanctions list. Until now, a foreign bank could point to the list and say the name was not on it. The same day, the Treasury published the full text of a licence it had issued in June 2026 that briefly allowed Iranian oil to be sold, and of the document that cancelled it sixteen days later. Nobody outside the deal could read either until now, so this is the first public sight of how far Washington was prepared to go before the policy reversed.

Deep Analysis

Root Causes

Executive Order 13902 was signed in January 2020 and bound its targets immediately, but it sat outside 31 CFR part 560 until a drafter wrote it in. The Iranian Transactions and Sanctions Regulations are the text compliance departments screen against and American courts construe, so for six years the rulebook ran behind the instrument it was meant to describe.

General Licence X was issued, used and revoked before its text reached the public record, so for three months the measure of what Washington had been prepared to authorise existed only in the hands of the parties holding the licence. An authority can therefore be created, exercised and withdrawn entirely inside the gap between a decision and its gazetting.

Escalation

Sideways. Neither instrument changes the naval blockade or the designations driving it; both tidy the legal record behind positions already taken. The trigger worth watching is the first enforcement action brought against a foreign bank under the 31 CFR 560.425 note, which would show whether Treasury intends the status test to be used rather than merely stated. A second signal would be the issue of any successor to General Licence X, which would mean the June position had returned.

What could happen next?

Consequence
A foreign bank can no longer rely on a counterparty's absence from the Specially Designated Nationals list, because the blocking now turns on the definitions at 31 CFR 560.304 and 560.324.
Immediate · Assessed
Meaning
The published General Licence X text shows Washington was briefly prepared to authorise Iranian crude lifted by vessels already blocked under Russian sanctions authorities, which is a wider concession than anything since offered.
Immediate · Reported
Precedent
Codifying Executive Order 13902 moves the construction, mining, manufacturing and textiles sectors into the text American courts construe, which matters whenever a designation under it is litigated.
Long term · Assessed

Source Landscape

This story draws on neutral-leaning sources

Primary parallel: Executive Order 13599 of February 2012 blocked the property of the Government of Iran and Iranian financial institutions, and the practical dispute ever since has been whether a bank or state body not named on the Specially Designated Nationals list is caught. The new note at 31 CFR 560.425 answers that question in the rulebook rather than in guidance, which is the same move the 2012 order needed and never got.

Counter-parallel: General Licence X ran for sixteen days, from 21 June to 7 July 2026, with wind-down to 17 July. On this programme an instrument can also die faster than the paperwork describing it can be published, so the six-year codification gap is not the only speed Treasury works at.

The note at 31 CFR 560.425 removes a defence rather than creating a prohibition, and the exposure is held by non-American banks. A foreign institution clearing a dollar payment for an Iranian state body that has never appeared on the Specially Designated Nationals list could previously argue that absence from the list was the operative fact.

Written into the regulations, the blocking under Executive Order 13599 now applies to any entity meeting the definitions at 31 CFR 560.304 and 560.324, which is a status test rather than a list check.

Matching a name against a published list is cheap and automatable; determining whether a counterparty meets the regulatory definition of an Iranian financial institution requires ownership research the screening vendors do not sell. The predictable response is over-blocking of Iranian-linked payments that were never prohibited, which is how sanctions reach humanitarian and food trade that carries its own exemptions.

Consensus view: The Federal Register text at 91 FR 61758 shows what General Licence X actually authorised: production, sale, delivery and offloading of Iranian-origin crude, petrochemicals and petroleum products, expressly including transactions involving vessels blocked under seven sanctions regimes, among them the Russian Harmful Foreign Activities regulations at 31 CFR part 587.

Publishing it on 30 September puts the June position on the record for the first time, three months after General Licence X1 killed it.

Counter-view: Treasury's own final rule at 91 FR 61759 took effect on publication with no comment period, on the ground that the regulations involve a foreign affairs function. The agency is therefore saying this codification changes no obligation: Executive Order 13902 has been available since January 2020 and Executive Order 13599 has blocked Government of Iran property since 2012, so on Treasury's account nothing new became unlawful on 30 September.

Key tension: Whether writing a standing authority into the Code of Federal Regulations alters anything a court or a compliance department will actually do, or whether the note at 31 CFR 560.425 is the only operative line in the package.

Sources:Federal Register·Federal Register

Mentions:OFAC →General License X →General License X1 →Executive Order 13902 →Executive Order 13846 →Specially Designated Nationals (SDN) →Federal Register →US Treasury →Code of Federal Regulations →Iran →Washington →

First Reported In

Update #180 · Washington left Iraq as it answered Tehran

Federal Register· 1 Oct 2026

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Causes and effects

This Event

OFAC publishes the licence it revoked

Compliance departments learned in September what Washington had been prepared to authorise in June, and the gap is the whole story.

Led to

Trump signed nothing on Iran this week

The 30 September gazetting supplies the Iran-specific Federal Register text that was absent on 14 September.

Occurred 14 Sept 2026

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