OFAC Issues Temporary Authorization for Iranian Oil Transactions

On March 20, 2026, OFAC issued Iran-related General License (“GL”) U (available here), authorizing all transactions otherwise prohibited under various (mostly Iran-related) sanctions programs that are ordinarily incident and necessary to the sale, delivery, or offloading of Iranian-origin crude oil or petroleum products already loaded onto vessels until 12:01 a.m. EDT on April 19, 2026.

GL U authorizes such transactions subject to the following conditions:

• The Iranian-origin crude oil or petroleum products must have been loaded onto vessels on or before 12:01 a.m. EDT on March 20, 2026;

• Transactions cannot involve a person located in or organized under the laws of, or an entity owned or controlled by or in a joint venture with a person located in or organized under the laws of, Cuba, North Korea, and certain Russian government-controlled areas of Ukraine subject to comprehensive U.S. sanctions; and

• Transactions cannot be prohibited under other OFAC sanctions programs not referenced in GL U.

GL U explicitly authorizes the importation of Iranian-origin crude oil or petroleum products into the United States where such importation is ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products authorized by this license.  And similar to OFAC’s recent Russia-related GL 134 (discussed here), GL U explicitly authorizes (1) transactions involving products produced by entities sanctioned under OFAC’s Iran-related sanctions programs, and (2) ancillary services ordinarily incident and necessary to complete the authorized voyages, including bunkering, crewing, vessel management, insurance, classification, salvage, and port services.

GL U is an exceptional (but still short-term) waiver of Iran-related oil sanctions as OFAC continues to respond to ongoing energy market disruptions.