制裁简报

July 2026 The Commodities & Shipping Practice at Squire Patton Boggs highlights the following recentdevelopments regarding US economic sanctions: Iran •Longterm sanctions relief– Under a memorandumof understanding (MOU) signed on 17 June, a 60-day negotiation process is underway to reach a finalagreement between Iran and the US. A final agreement, ifreached, would provide long-term relief from US primaryand secondary sanctions against Iran. Termination ofsanctions is expected to be conditional and phasedpursuant to an agreed schedule. Vice President J.D.Vance has emphasized that further sanctions relief will becontingent on Iran meeting its agreement obligations. •Temporary sanctions relief– On 22 June, the Office ofForeign Assets Control (OFAC) issued General License (GL)X, providing substantive, but temporary, sanctions relief forIran’s energy sector for the first time since 2016. –Subject to limitations, GL X authorizes US and non-USpersons to engage in transactions necessary to theproduction, sale, offloading and delivery of Iranian-origincrude, petroleum products and petrochemicals until GL Xexpires on August 21, 2026, at 12:01 a.m. EDT. –GL X also authorizes US imports, US$ transactions anddealings with certain blocked vessels (e.g., docking,anchoring, crewing, emergency repairs, environmentalmitigation, salvage, vessel management, crewing,bunkering, piloting, registration, flagging, insurance andclassification). •Strait of Hormuz– The MOU reopened the Strait of Hormuzand initiated an end to the US naval blockade of Iranianports. Under the agreement, passage through the straitis toll-free for 60 days, although it is unclear whether Iranwill attempt to impose tolls at a later date. US and Iranianforces exchanged strikes from 25 to 28 June after Iranstruck a commercial vessel in the strait, threatening theMOU’s status. However, both sides agreed to stand downand resume negotiations, leading to increased traffic in thestrait. Before the strikes, reports indicated an increase invessels crossing the strait with their automatic identificationsystem (AIS) activated. Following the strikes, the number ofvessels broadcasting their passage dropped, but traffic hasrebounded again in recent days. Still, visible traffic is higherthan it has been for several months. –EU and UK sanctions remain in effect, and may beapplicable to transactions authorized under GL X.Challenges may arise regarding insurance, financialservices, logistics and other services. –Parties may be subject to restrictive sanctions clausesimposed by financial institutions, charterparties andother agreements. –GL X provides only temporary sanctions relief. Indeed,it is possible GL X could be revoked before it expires ifUS-Iran negotiations fall apart. This contingency shouldbe addressed in relevant contracts, both with regard tothe assignment of risk and setting realistic timelines forperformance of all relevant transactions and activities. •Liquefied petroleum gas (LPG) exports– New blockingsanctions were imposed on tank vessels, as well asa network of front companies in the UAE involved inexporting Iranian LPG to Asia. In many cases, such exportswere carried out under false Omani certificates of origin. Cuba •Contract terms– Some of the Venezuela GLs require USlaw and specific dispute venues. OFAC has clarified in FAQ1260 that US law must govern contract interpretation(e.g., performance, breach, remedies, paymentobligations, termination, validity, assignment/novationand enforceability), but contract terms can recognizeVenezuelan law concerning the underlying activity (e.g.,governing exercise of Venezuela’s sovereign regulatoryauthority, permits and licenses, concessions, labor,environmental, health and safety, etc.). Regarding venue,certain GLs require dispute proceedings to be in the US,UK, France or Singapore. If parties agree to arbitration,the procedural rules applicable are those agreed bythe parties or the rules of internationally recognizedinstitutions, or the rules of the seat of arbitration. •Energy– The US Department of State designated Cuba’sstate-owned oil and gas company, Union Cuba-Petroleo(CUPET), on the Specially Designated Nationals andBlocked Persons (SDN) List pursuant to Executive Order(EO) 14404 (May 1, 2026), which expanded Cuba sanctionsto authorize the blocking of non-US parties operatingin Cuba’s energy sector. The Trump administrationannounced it will “continue to target Cuba’s ability toleverage energy trade.” Also at risk are non-US personsengaged in Cuba’s metals, mining, finance and defensesectors. •Grupo de Administración Empresarial SA(GAESA)– OFACissued FAQ 1258 to confirm the risk to non-US personsdealing with GAESA, the Cuban military-run conglomerate.GAESA is involved in Cuba’s shipping and port sector,particularly port management (e.g., Port of Mariel),container terminals, warehousing, logistics and relatedservices. GAESA typically acts through subsidiaries, likeAlmacenes Universales SA(AUSA). Al