US revokes sanctions relief for Iranian oil trade following Strait of Hormuz attacks

As explained in our earlier article, on 21st June, 2026, the US Office of Foreign Assets Control (“OFAC”) issued General License X (“GLX”), described as “Authorizing the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian-Origin through August 21, 2026”.

However, following recent attacks on ships in the Strait of Hormuz, on 7th July, 2026, OFAC revoked GLX and replaced it with General License X1 (“GLX1”), entitled “Revocation and Wind Down of June 21, 2026 Authorization for the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian Origin”.

In summary, GLX1:

• Revokes and supersedes GLX.
• Authorises until 17th July, 2026, activities that are ordinarily incident and necessary to wind down transactions that were previously authorised under GLX (subject to applicable exceptions).
• Requires any payments to blocked persons to be made into a blocked, interest-bearing US account.
• Prohibits any new transactions, including purchases or loading of Iranian-origin crude oil, petroleum or petrochemical products from 7th July, 2026.

In the meantime, as mentioned in our earlier update, the wide-ranging EU and UK measures targeting Iran remain in place and unaffected by these US measures.

The issuance of GLX1 highlights that sanctions and sanctions relief may be introduced, amended or withdrawn at short notice in response to geopolitical developments. 

Members with questions regarding the issues discussed above are invited to contact the Club for further information.