The narrow window that let counterparties close out Iranian oil business has now shut. OFAC's General Licence X1 expired at 12:01am Eastern on Friday 17 July, ending a ten-day wind-down and completing Washington's reversal of last month's sanctions easing.
The sequence matters. General Licence X, issued on 21 June under the US-Iran memorandum of understanding, had temporarily authorised the production, sale, delivery and offloading of Iranian-origin crude, petrochemicals and petroleum products, and — crucially — the maritime services around them: vessel management, insurance, crewing and bunkering. It also permitted US-dollar payments and imports into the United States, and was originally set to run through 21 August.
On 7 July, as the truce collapsed and fighting resumed around Hormuz, OFAC issued GL X1, which revoked GL X and barred any new transactions in Iranian oil from that date. It allowed only activity 'ordinarily incident and necessary' to closing out deals already authorised, running to this morning's deadline. Any remaining payments to blocked persons made during the wind-down had to be routed into blocked, interest-bearing accounts in the United States — reversing the direct-payment allowance GL X had briefly created.
Because the original licence reached the whole service chain, its expiry does too. This is not only a traders' problem. Maritime security providers, private security companies, crewing agencies and vessel managers with any Iranian-oil nexus need to confirm they are not still riding on an authorisation that no longer exists. For UK and EU operators contracting into Gulf shipping, the live risk is secondary sanctions — US measures that reach non-US firms dealing in Iranian oil.
The practical task this week is diligence: verify charter, cargo provenance and counterparties on any Gulf tasking, and assume that 'we were winding down a permitted deal' stopped being a defence at one minute past midnight, Eastern. Where a contract can no longer be performed lawfully, that needs flagging to legal and to the client now, not after a cargo moves.
