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Treasury Issues General License Authorizing Iranian Oil Sales Through Aug. 21

Dispatch

The Treasury Department's Office of Foreign Assets Control issued Iran General License X on June 22, 2026, authorizing the production, delivery, and sale of Iranian-origin crude oil, petrochemical products, and petroleum products through Aug. 21, 2026. The license creates an authorization for U.S. businesses to engage in commercial transactions involving Iranian oil, representing a significant shift in sanctions policy and a direct consequence of ongoing U.S.-Iran negotiations. The license expressly permits the importation of Iranian-origin crude oil and petroleum products into the United States.

General License X fulfills the first immediate sanctions-related commitment made by the U.S. government under the MOU. Broader sanctions relief is to follow on an agreed schedule as part of any final deal. The MOU was signed remotely by President Trump and Iranian President Masoud Pezeshkian, as well as by the prime minister of Pakistan, which served as mediator between the two parties. Trump signed the document during dinner with French President Emmanuel Macron at the Palace of Versailles following the G7 summit, after which Pezeshkian signed in Tehran. The MOU is not a final agreement. It is a 14-point framework that extends the ceasefire and sets the stage for talks on a permanent nuclear arrangement.

Paragraph 10 of the MOU commits the Treasury Department to issuing, "immediately upon the signing of this MOU, and until the termination of sanctions," waivers for the export of Iranian crude oil, petroleum products, and derivatives, along with all associated services including banking, insurance, and transportation. The MOU established a 60-day ceasefire period during which further talks are expected to address unresolved issues, including Iran's nuclear program, enrichment levels, and the status of its highly enriched uranium stockpiles. General License X's expiration at 12:01 a.m. EDT on Aug. 21, 2026, aligns with that 60-day negotiation window.

General License X provides a time-limited authorization for a broad category of transactions that would otherwise be prohibited under multiple Iran-related sanctions authorities, including the Iranian Transactions and Sanctions Regulations, the Iranian Financial Sanctions Regulations, and the Global Terrorism Sanctions Regulations. OFAC grounds the broader Iran sanctions regime primarily in the International Emergency Economic Powers Act, implementing it through a combination of statutes, executive orders, and regulations, most notably the Iranian Transactions and Sanctions Regulations at 31 C.F.R. Part 560. OFAC issues general licenses to authorize activities that would otherwise be prohibited with regard to Iran; such licenses allow all U.S. persons to engage in the described activity without applying for a specific license. One restriction under General License X bars authorized transactions from involving individuals or entities located in or organized under the laws of Crimea, Cuba, the Donetsk People's Republic, the Luhansk People's Republic, or North Korea.

A prior instrument, Iran General License U, had briefly authorized the direct importation of Iranian crude into the United States for the first time in decades before expiring. After the United States withdrew from the Joint Comprehensive Plan of Action in 2018, the government restored sanctions that had been suspended under the JCPOA and expanded them further, pursuant to Executive Order 13846, restoring broad restrictions on Iran's energy, financial, and shipping sectors. On Feb. 4, 2025, President Trump signed a National Security Presidential Memorandum directing the imposition of maximum pressure on Iran's government, including "a robust and continual sanctions enforcement campaign" that would deny the regime and its proxies access to revenue. General License X marks a direct reversal of that posture.

The license represents a significant but temporary relaxation of restrictions affecting Iran's oil sector while leaving intact the broader and highly complex U.S. sanctions architecture applicable to Iran. As of publication, General License X is the only official OFAC guidance addressing the Iran sanctions programs in relation to the MOU. The MOU commits the United States to terminate all types of sanctions against Iran, including United Nations Security Council resolutions, IAEA Board of Governors resolutions, and all unilateral U.S. sanctions, primary and secondary, on an agreed schedule as part of a final deal. The United States is reportedly pushing for a 20-year enrichment pause in final deal negotiations; Iran reportedly will not go above 10 years, with terms to be negotiated during the 60-day window. The authorization under General License X is expressly limited in duration, and there is no assurance that OFAC will issue an extension or successor license if negotiations remain unresolved by the August deadline.

Featured image: Photo by Mohsen L on Unsplash


References

[1] Office of Foreign Assets Control. (2026, June 22). Issuance of Iran-related General License. https://ofac.treasury.gov/recent-actions/20260622_33

[2] Baker McKenzie. (2026, June 22). OFAC begins to relax US sanctions to implement US-Iran memorandum of understanding. https://sanctionsnews.bakermckenzie.com/ofac-begins-to-relax-us-sanctions-to-implement-us-iran-memorandum-of-understanding/

[3] Steptoe. (2026, June 22). Weekly sanctions update: June 22,

[4] Herbert Smith Freehills Kramer. (2026, June 22). OFAC issues Iran General License X authorizing production and sale of Iranian-origin oil and petroleum products. https://www.hsfkramer.com/notes/sanctions/2026-posts/ofac-issues-iran-general-license-x-authorizing-production-and-sale-of-iranian-origin-oil-and-petroleum-products

[5] Buchanan Ingersoll & Rooney. (2026, June 29). U.S. sanctions on Iran: Settlement negotiations, General License X and status update. https://www.bipc.com/u.s.-sanctions-on-iran-settlement-negotiations-and-status

[6] Paul, Weiss. (2026, April 21). OFAC issues coordinated energy-related general licenses for Venezuela, Russia and Iran. https://www.paulweiss.com/insights/client-memos/ofac-issues-coordinated-energy-related-general-licenses-for-venezuela-russia-and-iran-key-updates

[7] NPR. (2026, June 18). Read the full text of Trump's preliminary U.S.-Iran agreement to end the war. https://www.npr.org/2026/06/18/nx-s1-5863027/us-iran-trump-memorandum-of-understanding-full-text

[8] CBS News. (2026, June 17). Read the 14 points of the agreement between Iran and the U.S. https://www.cbsnews.com/news/us-iran-deal-memorandum-of-understanding-text/

[9] CBS News. (2026, June 19). Here's how Trump's memo of understanding with Iran compares to the Obama nuclear deal. https://www.cbsnews.com/news/how-trump-iran-nuclear-deal-memorandum-of-understanding-compares-to-obama-nuclear-deal-jcpoa/

[10] Wikipedia. (2026, July 1). 2025–2026 Iran–United States negotiations. https://en.wikipedia.org/wiki/2025%E2%80%932026_Iran%E2%80%93United_States_negotiations

[11] Council on Foreign Relations. (2026, June 17). Trump's Iran deal: What we know so far. https://www.cfr.org/articles/is-a-u-s-iran-deal-within-reach-six-key-issues-that-could-shape-a-ceasefire

[12] Congressional Research Service. (2026). U.S. sanctions on Iran. https://www.congress.gov/crs-product/IF12452

[13] Greenberg Traurig. (2026, February 19). U.S. announces tariff framework targeting countries that acquire goods or services from Iran. https://www.gtlaw.com/en/insights/2026/2/us-announces-tariff-framework-targeting-countries-that-acquire-goods-or-services-from-iran

[2026] https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-june-22-2026.html

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