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Iran General License X1 was a temporary OFAC authorization for winding down transactions previously permitted under Iran General License X. It took effect on July 7, 2026 and expired at 12:01 a.m. EDT on July 17, 2026. GL X1 is no longer a valid authorization for current transactions.
General License X1 did not extend the broader authorization previously available under General License X. Instead, it gave parties a short period to complete activities that were ordinarily incident and necessary to close transactions already covered by GL X.
What Was Iran General License X1?
General License X1 was issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on July 7, 2026.
On that date, OFAC revoked Iran General License X and replaced it in full with General License X1. OFAC described the new authorization as the revocation and wind-down of the June 21, 2026 authorization covering the production, delivery and sale of Iranian-origin crude oil, petrochemical products and petroleum products.
The change became effective on July 7, 2026. OFAC’s July 7 announcement confirms the replacement of General License X with General License X1.
GL X1 was therefore a wind-down license. Its purpose was not to open a new period of authorized trade, but to provide a limited period for closing transactions that had previously fallen within General License X.
What Was General License X Before X1?
General License X was dated June 21, 2026 and announced by OFAC on June 22.
It authorized specified transactions involving the production, delivery and sale of Iranian-origin crude oil, petrochemical products and petroleum products through August 21, 2026. The original authorization is described in OFAC’s announcement of General License X.
That original end date became irrelevant when OFAC revoked GL X on July 7.
From that point:
- General License X could no longer be relied upon;
- General License X1 replaced it completely; and
- only qualifying wind-down activity remained authorized through July 17.
This distinction is important when reviewing transactions carried out in July 2026.
What Did General License X1 Authorize?
GL X1 authorized transactions that were ordinarily incident and necessary to the wind down of transactions previously authorized by General License X.
The authorization lasted through 12:01 a.m. Eastern Daylight Time on July 17, 2026.
When assessing whether an activity fell within the license, two central questions were relevant:
- Was the underlying activity previously authorized by General License X?
- Was the later activity genuinely necessary to wind that transaction down?
The phrase “wind down” should not be interpreted as permission to continue normal business until July 17. The relevant activity had to relate to bringing previously authorized transactions to an end.
Did GL X1 Allow New Iranian Oil Transactions?
No. General License X1 expressly restricted new activity.
The license stated that, except where activity was ordinarily incident and necessary to complete the authorized wind-down, it did not authorize new transactions involving the covered Iranian-origin products.
OFAC specifically identified new purchases and loading on or after July 7, 2026 as examples of activity that was not newly authorized by GL X1.
This is one of the most important differences between GL X and GL X1.
General License X had provided a broader temporary authorization. General License X1 replaced that framework with a narrow closing period.
When Did General License X1 Expire?
General License X1 expired at 12:01 a.m. EDT on July 17, 2026.
OFAC now lists the licenses in its archive as follows:
- General License X — superseded by General License X1;
- General License X1 — expired on July 17, 2026.
The current status can be checked in OFAC’s archive of revoked and expired general licenses.
As a result, neither GL X nor GL X1 can now be treated as a current authorization.
A business assessing a transaction today must identify another legal basis if the activity would otherwise be prohibited under applicable U.S. sanctions.
What Were the Payment Rules Under General License X1?
GL X1 contained an important condition for payments owed to blocked persons.
Where a payment to a blocked person was required as part of the authorized wind-down, the payment had to be made into a blocked, interest-bearing account located in the United States.
This requirement should not be interpreted as applying automatically to every payment connected with Iran.
The relevant questions include:
- whether the recipient was a blocked person;
- whether the transaction otherwise fell within GL X1;
- whether the payment was necessary to the wind-down; and
- whether the specific payment conditions were followed.
A transaction should therefore be assessed against the wording of the license and the sanctions status of the parties involved.
What Transactions Were Not Authorized by GL X1?
General License X1 contained several express limitations.
First, it did not authorize new transactions outside the permitted wind-down, including new purchases or loading of the covered Iranian-origin products on or after July 7, unless necessary to complete an already authorized transaction.
Second, GL X1 did not authorize transactions involving persons located or organised under the laws of certain jurisdictions specified in the license, including:
- North Korea;
- Cuba;
- the Covered Regions of Ukraine specified in the relevant sanctions authorities; and
- Crimea.
The restrictions also extended to certain entities owned, controlled by, or involved in joint ventures with such persons.
Third, the license did not override prohibitions imposed by sanctions authorities or regulations that were not referenced in GL X1.
The existence of GL X1 therefore did not make an otherwise prohibited transaction automatically permissible.
What Happened to Transactions That Were Not Completed by July 17?
Once GL X1 expired, the authorization provided by that license ended.
A transaction could not continue relying on GL X1 simply because it had begun while GL X or GL X1 was still in effect.
The parties would need to determine whether another legal basis applied, such as:
- another valid general license;
- a statutory or regulatory exemption;
- an applicable specific license; or
- another authorization under the relevant sanctions framework.
Historical general licenses should not be relied upon without confirming their current status because OFAC may issue, amend, revoke, suspend or allow authorizations to expire.
What Is the Difference Between a General License and a Specific License?
An OFAC general license is a public authorization covering a defined category of transactions that would otherwise be prohibited.
General licenses are generally self-executing. A person whose transaction satisfies the terms of a general license does not normally need to submit a separate application for that authorization.
A specific license is different. It is an authorization issued by OFAC to a particular person or entity following an application.
Therefore, after GL X1 expired, a company could not simply continue operating under the old general license. It would first need to determine whether another existing authorization applied.
Can a Company Apply for an OFAC Specific License Now?
A person or company can submit a specific license application where a proposed transaction is otherwise prohibited, but an application does not guarantee authorization.
This is particularly important for Iran-related matters in September 2026.
On September 10, 2026, OFAC announced a change to its Iran-related specific licensing policy. OFAC now considers Iran-related specific license applications with a presumption of denial, except where approval is required by law or in certain circumstances such as risks to life, limb or environmental safety.
The current policy is described in OFAC’s September 10, 2026 announcement.
Businesses should therefore not assume that a transaction formerly covered by GL X or GL X1 can simply be moved into the specific licensing process with an expectation of approval.
Where a transaction requires a current licensing assessment, our OFAC sanctions lawyers can review the relevant restrictions, available authorizations and licensing options.
Why Does General License X1 Still Matter If It Has Expired?
GL X1 remains important for historical sanctions compliance.
Companies, banks, traders and other parties may still need to determine whether transactions carried out between July 7 and July 17 were properly authorized.
For example, a compliance review may need to establish:
- when the underlying transaction began;
- whether it was previously covered by GL X;
- what activity occurred after July 7;
- whether that activity was necessary to wind down the transaction;
- whether any new purchase or loading occurred;
- whether blocked persons were involved; and
- how any required payments were handled.
These questions can arise during internal investigations, banking reviews, due diligence, voluntary disclosures or OFAC enforcement matters.
The exact transaction history therefore matters more than simply establishing that GL X1 existed at the relevant time.
How Should a Historical GL X1 Transaction Be Reviewed?
A useful starting point is to build a transaction timeline.
That timeline should identify the relevant dates, parties, contracts, product movements and payments before and after July 7, 2026.
The next step is to compare those facts with the scope of General License X and then with GL X1’s narrower wind-down language.
A review should distinguish between:
- activity already authorized under GL X; and
- new activity initiated after GL X was revoked.
It should also check whether any blocked parties or additional sanctions authorities were involved.
For cross-border matters involving several sanctions regimes, our international sanctions lawyers can assess how U.S. OFAC restrictions interact with other applicable sanctions rules.
What Should Businesses Do Now?
General License X1 should now be treated as a historical authorization, not as permission for current activity.
A company dealing with an unresolved transaction should verify:
- whether the transaction was completed before GL X1 expired;
- what authorization covered each stage of the transaction;
- whether any activity continued after July 17;
- whether another current OFAC authorization applies;
- whether blocked persons or property were involved; and
- whether additional compliance or reporting issues require review.
Because OFAC’s Iran-related sanctions framework continued to change after July 2026, current transactions should always be checked against the present sanctions rules and licenses rather than against GL X1 alone.
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Frequently Asked Questions
Is Iran General License X1 Still Valid?
No. Iran General License X1 expired at 12:01 a.m. EDT on July 17, 2026. OFAC now lists it among expired general licenses.
Did General License X1 Allow New Iranian Oil Transactions?
No. GL X1 was primarily a wind-down authorization. It did not authorize new purchases or loading of the covered Iranian-origin products on or after July 7, except where the activity was ordinarily incident and necessary to complete the authorized wind-down.
