OFAC GLX Revoked July 7 — Iran Sanctions Fully Reinstated; OFAC Designates 10 Entities and 8 Vessels Linked to "Monetizing the Strait of Hormuz"

The US sanctions regime against Iran reached a critical inflection point this week. General Licence X (GLX), issued by OFAC on 22 June 2026 to authorise the production, delivery, and sale of Iranian-origin crude oil and petrochemical products (including associated shipping, port operations, insurance underwriting, financing, and US dollar payments), was revoked on 7 July following Iranian attacks on commercial vessels in the Strait of Hormuz. Its replacement, General Licence X1 (GLX1), provided only a ten-day wind-down period for businesses that had already commenced activities under GLX — with payments due to blocked persons required to be deposited into blocked, interest-bearing US accounts. As of the date of the Mishcon de Reya analysis (August 3), no general licence authorising trade in Iranian-origin oil remains in place, and the pre-22 June primary and secondary Iran sanctions are fully reinstated. On 29 July, OFAC designated ten additional entities and eight vessels linked to Iran's efforts to "monetize the Strait of Hormuz." For partners advising clients with Iranian commercial exposure: the revocation sequence — GLX issued, then revoked mid-term before its stated 21 August expiry — is the clearest available signal that sanctions-relief windows are operationally unreliable in conflict conditions and that any Iran-related compliance strategy must include contractual force majeure provisions that explicitly cover sanctions revocation, as well as payment routing that does not assume US dollar clearing remains available. The wind-down period provisions (blocked-account deposit requirement) are non-trivial to comply with quickly; lawyers must verify client structures in advance, not in response to a revocation notice.