Iranian oil: an OFAC license that misleads companies

In mid-April 2026, the expiration of General License U issued by the Office of Foreign Assets Control led to widespread interpretations among international trade operators. Some viewed this license as a signal of easing sanctions on Iranian oil. In reality, this interpretation proved largely misleading.

While U.S. authorities did temporarily authorize certain transactions involving Iranian oil, the framework remained extremely restrictive. The license only applied to very specific situations, notably cargoes already in transit at the time of its publication. In addition, only transactions considered ordinarily incident and necessary were covered, excluding most real-world scenarios.

This approach highlights the increasing complexity of sanctions regulations. A general license does not constitute a broad authorization but rather a narrowly defined exception. Every element of the transaction chain remains exposed to risk, including insurers, transport operators, intermediaries and the jurisdictions involved.

For export control and compliance teams, this situation underscores a key point. Periods of apparent sanctions relief do not reduce regulatory obligations; they make them more difficult to interpret and apply. Companies must therefore exercise heightened vigilance by carefully assessing the scope of licenses and evaluating risks at every stage of a transaction.

In an environment shaped by rapidly evolving and sometimes ambiguous sanctions regimes, understanding the exact limits of exemptions is essential. Misinterpreting these measures can lead to significant compliance exposure.