美国财政部海外资产控制办公室（OFAC）的通用许可证X以及伊朗能源制裁的放松

June 2026 On June 22, 2026, the US Treasury Department’s Office of Foreign Assets Control (OFAC)issued General License (GL) X, providing substantive, but temporary, sanctions relief for Scope of GL X Subject to terms and limitations, GL X authorizes US and non-US persons to engage in transactions that are ordinarily incidentand necessary to the production, sale, offloading and delivery of Iranian-origin crude, petrochemicals and petroleum products •Imports into the US of Covered Products purchased pursuant to GL X •US dollar payments to Iran, the government of Iran and certain blocked persons for the purchase of Covered Productsauthorized under GL X •Transactions involving certain blocked vessels, including the safe docking and anchoring of vessels carrying CoveredProducts; the preservation of the health or safety of the crew of any such vessel; emergency repairs or environmentalmitigation or protection activities relating to any such vessel or to Covered Products held in storage and services such as GL X authorizes the above transactions to the extent they would otherwise be prohibited by the following sanctions authorities: •Iranian Transactions and Sanctions Regulations, 31 CFR Part 560, as well as OFAC regulations at Parts 544, 561, 587, 589 •Executive orders 13846, 13876, 13902 and 3949 Notably, the list above includes two Russia-related sanctions authorities (31 CFR Parts 587 and 589). The inclusion of Part 587reflects the significant overlap between Iranian and Russian sanctions networks, as many parties in Iran’s energy sector weresimultaneously designated under both Iran and Russia-related authorities due to their participation in overlapping evasion Limitations Contacts Parties contemplating transactions pursuant to GL X shouldcarefully consider the following: Jeffrey OrensteinPartner, Washington DCT +1 202 457 5247jeffrey.orenstein@squirepb.com •EU and UK sanctions remain in effect at the time of thiswriting and may be applicable to transactions authorizedunder GL X. Accordingly, challenges may arise regarding D. Michael KayePartner, Washington DCT +1 202 457 6545michael.kaye@squirepb.com •Parties may be subject to restrictive sanctions clausesimposed by financial institutions, charterparties and other •GL X provides only temporary sanctions relief. While morepermanent relief is expected if the ongoing negotiationsbetween the US and Iran are successful, it is possible GLX could be revoked before its August 21, 2026 expirationdate if negotiations fall apart. This contingency should Mirrah Papovsky Associate, Washington DCT +1 202 457 5289mirrah.papovsky@squirepb.com GL X does not authorize: •Transactions involving persons located or organized inNorth Korea, Cuba, Crimea, Luhansk People’s Republic orDonetsk People’s Republic, or any entity that is owned or •Transactions prohibited by executive orders or OFACregulations beyond those addressed by GL X (listed If you have any questions about the scope of GL X or relatedissues under US, EU or UK sanctions, please contact a member