OFAC REVOKES GENERAL LICENSE AUTHORIZING CERTAIN TRANSACTIONS INVOLVING IRANIAN-ORIGIN OIL AND PETROLEUM PRODUCTS
JULY 8, 2026
CIRCULAR NO. 15/26
TO MEMBERS OF THE ASSOCIATION
Dear Member:
OFAC REVOKES GENERAL LICENSE AUTHORIZING CERTAIN TRANSACTIONS INVOLVING
IRANIAN-ORIGIN OIL AND PETROLEUM PRODUCTS
Reference is made to Circular No. 14/26 of June 24, 2026, concerning the U.S. Department of the
Treasury’s Office of Foreign Assets Control (“OFAC”)’s issuance of General License X, which
authorized certain transactions involving Iranian-origin oil and petroleum products until August 21,
2026. On July 7, 2026, OFAC issued General License X1 “Revocation and Wind Down of June 21,
2026 Authorization for the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and
Petroleum Products of Iranian-Origin” (“General License X1” or “the Revocation”).
The Revocation supersedes General License X and the authorization provided therein, replacing it
with a limited wind down until 12:01am eastern daylight time on July 17, 2026, of the transactions
temporarily authorized by General License X.
The wind down is subject to additional conditions, including that any payment to a blocked person
must be made into a blocked, interest-bearing account located in the United States. The Revocation
also states that the wind down does not authorize any new transactions, including purchases or
loading of such products on or after July 7, 2026.
Members are encouraged to review the full General License X1 linked above. Members are reminded
that cover is not available for any trade that breaches applicable sanctions. Members are advised
that they should conduct thorough due diligence on the parties, cargoes, vessels and other service
providers that are or may be involved before they engage in any trade with a high sanctions risk.
Finally, Members are reminded to keep records of their due diligence investigations and findings.
Yours faithfully,
Dorothea Ioannou, CEO
Shipowners Claims Bureau, Inc., Managers for
THE AMERICAN CLUB
