A compliance deadline lands this week for anyone with exposure to Iranian oil. On 21 June, in the brief thaw around the US and Iran memorandum of understanding, OFAC issued General License X, temporarily authorising transactions in Iranian-origin crude, petrochemicals and petroleum products. When the conflict reignited, Washington reversed course. On 7 July OFAC issued General License X1, revoking that authorisation.
GL X1 allows only a ten-day wind-down. It runs out at 12:01am Eastern time on Friday 17 July. From 7 July no new transactions have been permitted, which means no fresh agreements to purchase or load Iranian petroleum may be negotiated or finalised. The only activity still allowed is what is "ordinarily incident and necessary" to close out business already authorised under the earlier licence, and any payments to blocked persons must go into blocked, interest-bearing accounts in the United States.
The official guidance is explicit that firms should not assume the wind-down period will be extended. For security and risk teams supporting maritime, trading or logistics clients touching this trade, the practical steps are the familiar ones: identify any residual Iranian-linked cargoes, contracts or receivables, close or safely park them before Friday, and document the wind-down. After the deadline, the full weight of US secondary sanctions is back in force, and the enforcement posture that comes with an active conflict is a great deal less forgiving.
