The Office of Foreign Assets Control (OFAC) adopted a presumption of denial for Iran-specific licence applications on Thursday 10 September, and Treasury said its Licensing Division began refusing most outstanding requests immediately1. Two exceptions survive: approvals the law compels, and cases touching safety, meaning life, limb or environmental harm2.
A licence application is how anyone with a lawful reason to touch a sanctioned economy asks permission. A family sending a remittance to a relative in Tehran files one. So does a hospital importing a component, a university paying a conference fee, and an operator seeking a certified aircraft safety part. Until Thursday each of those was assessed on its merits, and Treasury carried the argument for refusing. Now the applicant carries the argument for approval, and must show its transaction fits one of two narrow exceptions.
The change completes a sequence that began on Monday 24 August with the indefinite stay of five Iran general licences, whose wind-down expired on 8 September. Removing those licences pushed every affected transaction into the application queue. The 10 September policy sets the default answer in that queue to no. Taken together, the two steps mean a remittance, a conference fee and a spare part now travel the same route and meet the same presumption.
This is also the most durable of the week's American actions, and the least visible. It carries no expiry date, it was published in a paragraph, and it inverts the default of a whole country programme without amending a statute. A designation names a target that can contest it. A presumption names nobody, so nobody has standing to challenge it, and the humanitarian carve-outs that survive are the ones the law forces Treasury to keep.
