OFAC (Office of Foreign Assets Control) General License U expires at 00:01 EDT on 19 April, five days from filing1. The licence authorises delivery, sale, offloading, bunkering, insurance and crewing for Iranian-origin crude and petroleum products loaded onto vessels on or before 20 March 2026. Approximately 325 tankers fall within its terms. A 14 April audit confirmed no renewal, replacement or extension has been published. Treasury has issued no Iran-related sanctions communication of any kind in 25 days, the same window that now covers every escalation since the 18 March signed actions tracks the silence.
Treasury's 25 days of silence reflect a structural bind, not administrative inertia. Renewing GL-U on Saturday would legally authorise the delivery of the same Iranian oil the blockade is trying to keep off the market. Allowing it to lapse would push every cargo currently moving under its protection into the same legal grey zone that makes dark-fleet identity fraud profitable. Windward has already tracked 14 sanctioned vessels using the registry identities of scrapped ships to evade detection in the strait; the economics of that trade improve every additional day non-sanctioned transits are blocked. CENTCOM patrols cannot cross-reference physical hulls against registry records in real time.
The practical edge for crews is sharper than the legal abstraction. A lapse at 00:01 EDT on Saturday means stranded cargoes that banks will not finance the unloading of, unpaid wage exposure while vessels sit at anchor waiting for owners to re-paper their insurance, and P&I (Protection and Indemnity) cover voids that can extend personal liability to the master and senior officers. OFAC general licences protect voyages already in transit on the effective date, but only if the licence remains valid at the moment of any enforcement action. The 325 vessels are at various voyage stages; the most exposed are those that load after 00:01 EDT without a successor licence in place.
The deadline sits inside a tighter cluster. The ceasefire window closes on 22 April. The 60-day clock under the War Powers Resolution expires around 29 April, with Senate Democrats forcing a vote this week. None of the three deadlines has a signed presidential instrument behind it. Treasury's silence is compatible with at least three explanations (successor licence in preparation, deliberate lapse as enforcement, internal stalemate), and the silence itself is not evidence of any of them.
