Iran sanctions – OFAC issue General License X
On June 17, 2026, the United States and Iran concluded the Islamabad Memorandum of Understanding, an interim framework mediated by Qatar and Pakistan.
General License X
To give effect to the memorandum, on 22 June 2026 the US Treasury's Office of Foreign Assets Control (OFAC) issued General License X (GL X), a temporary authorisation expiring on 21 August 2026.
GL X authorises transactions ordinarily incident to the production, sale, delivery and offloading of Iranian-origin crude oil, petrochemical products and petroleum products, extends to transactions involving blocked vessels and to services including vessel management, crewing, bunkering, insurance, classification and salvage, and permits buyers to pay Iran directly in US dollars. Its scope is therefore considerable.
It is, however, a measure of US law only, and Members should not treat it as a general relaxation of the sanctions framework.
EU and UK measures remain in force
GL X does not amend the European Union (EU) or United Kingdom (UK) Iranian sanctions measures, which remain fully in force.
Following the United Nations "snapback" of September 2025, the EU reintroduced prohibitions on the import, purchase and transport of Iranian crude oil, petroleum products, natural gas and petrochemicals, together with any financing, insurance or related services concerning them. More on EU Sanctions relating to Iran here.
Since 1 January 2026, the EU has also prohibited the provision of classification, construction, repair, inspection and certification services to tankers flying the Iranian flag or owned, chartered or operated by Iranian persons – please see our news item of June 1, 2026 here.
The United Kingdom maintains a parallel regime, and the relevant wind-down periods have expired. More on UK Sanctions relating to Iran here.
Cover position
While GL X relieves secondary-sanctions pressure on non-US parties as a matter of US law, it does not displace the EU and UK prohibitions on the provision of insurance and related services for the carriage of Iranian oil and petrochemical products. Cover is accordingly not available for any voyage or operation that would breach those measures, notwithstanding the issuance of OFAC’s GL X.
Members are reminded that cover is not available for any trade that breaches applicable sanctions. Members considering any trade with an Iranian nexus should conduct thorough due diligence on the parties, cargoes, vessels and service providers involved, should obtain independent legal advice, and are encouraged to contact their usual Club contact before committing to any such business.