General License Z, issued by the US Treasury's Office of Foreign Assets Control (OFAC) to let counterparties wind down dealings with vessels blocked on 14 July, lapsed on 17 July 1. General License X1, which had covered Iranian oil transactions, expired the same day with no renewal .
OFAC issues wind-down licences to open a legal grace period. Each one gives banks, charterers, insurers and port agents a fixed window to settle outstanding obligations with a newly sanctioned party without themselves becoming sanctions violators. Three days is a short window when the counterparties are ships mid-voyage in a war zone whose insurers have already repriced the passage.
With both licences gone, anyone still holding contracts tied to those vessels is exposed with no authorised path to unwind them. The practical effect falls on intermediaries rather than on Tehran: the Greek owner, the Singaporean bunker supplier and the Dubai trading desk now face a choice between breaching a contract and breaching US sanctions, and OFAC has published no successor authorisation.
