The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on June 22, 2026, issued a broad general license (GL) authorizing the production, delivery and sale of Iranian oil, petrochemical products and petroleum products for a 60-day period through August 21, 2026. GL X was published early in the morning as negotiators in Switzerland sought to preserve a fragile U.S.-Iran interim peace agreement reached last week and described in a previous Holland & Knight alert. Qatari and Pakistani mediators indicated that the U.S. and Iran had agreed on a road map to reach a longer-term agreement in 60 days, and GL X will allow the sale of Iranian oil for the duration of those talks.
This is the third time that the U.S. has authorized the temporary sale of Iranian or Russian sanctioned oil since the outbreak of the war with Iran and the resulting closure of the Strait of Hormuz, a key chokepoint for the global energy trade. On March 20, 2026, OFAC issued GL U to authorize the delivery and sale of Iranian crude oil and petroleum products loaded onto vessels as of that date for a 30-day period, and a separate GL authorized the temporary delivery and sale of Russian crude oil and petroleum products for a 30-day period ending on April 11, 2026. Although many U.S. institutions refrained from engaging in transactions pursuant to these temporary licenses, the authorizations provided a respite from secondary sanctions risks for non-U.S. actors dependent on such oil.
Although GL X provides another temporary opportunity for Iran to reengage in the oil and gas markets, the risks will persist as long as the architecture of U.S. sanctions remain in place and a final, permanent peace deal is still elusive. Many U.S. sanctions on Iran are mandated by statute, and the U.S. administration will be required to engage with Congress to secure a longer-term waiver – or removal – of sanctions.
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