The compliance clock runs out tomorrow. OFAC's General License X1, issued on 7 July, revoked the brief authorisation, General License X of 21 June, that had let firms deal in Iranian-origin crude, petrochemicals and petroleum products under last month's US-Iran memorandum of understanding. X1 replaced X in full and set a short wind-down.
That wind-down shuts at 12:01am Eastern on Friday 17 July. Until then, only activity "ordinarily incident and necessary" to closing out already-permitted transactions is allowed. After it, no entity is authorised to enter new dealings. No purchasing, no loading of Iranian cargoes. No new transactions have been permitted since 7 July.
Any payments to blocked persons made during the wind-down have to go into blocked, interest-bearing US accounts. Law firms tracking the change are clear that no extension should be assumed.
For operators this is the paperwork side of the same crisis. Anyone supporting tanker movements, charter work, or protective tasking tied to Gulf energy trade should treat any Iran-linked cargo as high-scrutiny from Friday, tighten vessel and counterparty checks, and assume sanctions exposure now sits alongside the physical threat in the strait as a live operational risk.
