10MAY

Two Iran wind-down windows shut four days apart

3 min read

14:22UTC

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 2026-18576⁠¹. 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 September⁠². 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

Source Landscape

This story draws on neutral-leaning sources

Primary parallel: When the United States left the nuclear deal on 8 May 2018, Treasury retired the Iran carve-outs on a published calendar too, giving counterparties 90-day and 180-day wind-down periods rather than an immediate prohibition. Anyone who missed a window applied for a specific licence instead.

Counter-parallel: Those windows ran months. General Licence CC was issued on 4 September and lapses on 19 September; General Licence DD was issued on 8 September and lapses on 23 September. A counterparty that needs a court, a custodian or a foreign regulator to sign off has no realistic chance of closing inside a fortnight.

The deadlines fall four days apart, which puts two unrelated sets of counterparties into the same fortnight of forced closing. Banks and custodians face 19 September; carriers, lessors and maintenance providers face 23 September.

The structural cost lands in what replaces the licence. After the second date, an entity with a lawful reason to settle an old Iranian bill has to ask permission case by case, and Treasury adopted a presumption of denial for Iran licence applications on 10 September.

Consensus view: Holland & Knight, reading the gazetted notice for clients, gives the two deadlines as 00:01 Eastern on 19 September for General Licence CC and 00:01 Eastern on 23 September for General Licence DD. No other reading of the notice has been published.

Counter-view: Aviation trade reporting collected for this briefing puts the added cost of flying around Iranian airspace at $6,000 to $7,500 per flight-hour, and names Lufthansa, SWISS, Austrian, Emirates, flydubai and Qatar Airways among the carriers already doing it.

The European Union Aviation Safety Agency has advised against flying the Tehran flight information region at any altitude. On that picture the aviation cliff on 23 September reaches a narrow population: carriers, lessors and maintenance shops that still hold unpaid Iranian invoices from before 8 September.

Key tension: No party has published how many counterparties actually hold outstanding wind-down obligations under either licence, so the size of both deadlines is asserted rather than measured.

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

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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

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Treasury defaults Iran licences to no

A presumption of denial means no replacement authorisation follows the wind-down.

Occurred 9 Sept 2026

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Golden Global shuts three of its funds

Golden Global closed three funds before the wind-down window was gazetted.

Occurred 7 Sept 2026

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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

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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

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Different Perspectives

Shipping and insurance industry

UKMTO counted about 20 US-facilitated Hormuz transits a day to 11 September against only 6 visible on AIS, with traffic still around 90% below the 138-a-day pre-war baseline. War-risk underwriters cannot price hulls they cannot see, or resolve whether the tanker El Gaia hit a mine, as Iran claims, or a missile and drone, as CENTCOM says.

European refiners

European refiners, including Poland's Orlen, absorbed a roughly $26 gap between Dated Brent at $130.80 on 15 September and ICE Brent futures settling at $103.87 on 18 September, a spread that widened from $13.45 on 9 September rather than newly opening. Their futures hedges no longer cover what they now pay for physical barrels.

Saudi Arabia

Saudi Aramco zeroed European term customers' October allocations and rerouted roughly 60 million barrels to Asia through Ras Tanura and Sohar, using Red Sea and Gulf terminal capacity built years ago to cut Hormuz exposure. Riyadh reallocated existing supply rather than negotiating a shortfall with Europe.

Qatar

Qatar's energy minister Saad al-Kaabi told Bloomberg at the Qatar Economic Forum on 20 September that Bessent's two-year Hormuz-obsolescence forecast is wrong, and that Doha has deliberately built no bypass pipeline. Qatar's gas exports run through one waterway by choice, not oversight.

Iran (foreign ministry and Majlis)

Iran's foreign ministry and 130 Majlis deputies moved toward NPT withdrawal this week, with lawmaker Hossein-Ali Haji Deligani filing a triple-urgency bill on 20 September that Speaker Qalibaf has not yet scheduled. Tehran treats treaty membership as leverage still on the table, not yet spent.

Russia and China

Moscow and Beijing vetoed the Panel of Experts' renewal, maintaining Resolution 2231 lapsed in October 2025 and the 2025 snapback was never validly triggered, so the sanctions architecture the Panel enforces has no current legal standing. Both governments frame the veto as upholding law, not shielding Tehran.