Iran Sanctions Fully Reinstated; OFAC GL X1 Terminates Waiver
OFAC issued General License X1 on July 7, superseding GL X and terminating the sanctions waiver for Iranian oil exports structured to run through August 21. In the 16 authorized days (June 22–July 7), approximately 20 Iranian tankers moved ~70 million barrels generating an estimated $5–6bn in export revenue before the ceasefire talks collapsed. Cargoes loaded before July 7 face payment and clearan
BY FRONTIER DESK · JULY 23, 2026 · 1 MIN READ
OFAC issued General License X1 on July 7, superseding GL X and terminating the sanctions waiver for Iranian oil exports structured to run through August 21. In the 16 authorized days (June 22–July 7), approximately 20 Iranian tankers moved ~70 million barrels generating an estimated $5–6bn in export revenue before the ceasefire talks collapsed. Cargoes loaded before July 7 face payment and clearance ambiguity depending on OFAC's retroactivity interpretation. Full sanctions enforcement is now restored. For sanctions counsel, the retroactivity question is the active risk: clients who contracted during the GL X window need a careful analysis of whether payment flows and clearance are protected or exposed under GL X1.