The window on Iranian oil trade is closing fast. On 7 July the US Treasury's Office of Foreign Assets Control revoked General License X — the permission it had issued only on 21 June to allow transactions in Iranian crude, petrochemicals and petroleum products — and replaced it with GL X1, a narrow wind-down authorisation. GL X had been due to run to 21 August; it lasted barely two weeks.
GL X1 permits only activity "ordinarily incident and necessary" to winding down business already authorised under GL X. New purchases and loadings are off the table from 7 July. The wind-down expires at 12:01 a.m. EDT on 17 July — a 10-day buffer, no more.
The trigger was the strait. Tankers were attacked in Hormuz in early July, and Washington pulled the licence on the 7th as a warning over Iran's conduct in the waterway.
For compliance teams and any operator supporting maritime, logistics or commodity clients, the actions are concrete. Map every live GL X transaction now. Close out cargoes, contracts and receivables before the deadline. Redirect any blocked-person payments to US interest-bearing accounts. Check that banks, insurers and P&I clubs can still process before you rely on them. And assess UK and EU exposure separately — they do not move in lockstep with OFAC.
OFAC's own guidance is blunt: do not assume the wind-down will be extended. Treat 17 July as hard.
