Iran General Licenses X and Z: OFAC’s Oil Authorization and the Shamkhani Shipping Crackdown

Over three weeks in the summer of 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two Iran-related general licenses that point in opposite directions. On June 22, 2026, it issued General License X, a broad authorization for transactions involving Iranian-origin crude oil, petrochemicals, and petroleum products. Then on July 14, 2026, it added more than 50 individuals, entities, and vessels tied to the Mohammad Hossein Shamkhani shipping network to the Specially Designated Nationals and Blocked Persons List (SDN List) and issued General License Z to wind those dealings down.

One license opens a lane. The other closes one. For anyone moving oil, chartering vessels, writing marine insurance, or clearing dollar payments anywhere near the Iranian energy trade, the compliance risk lives in the gap between the two. Here is what General License X and General License Z actually authorize, who OFAC hit on July 14, and what the sequence means if your company or your vessel is caught in it.

Iran General License X and Z at a Glance

What Iran General License X Authorizes

General License X carries the title “Authorizing the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian-Origin through August 21, 2026.” A general license is a self-executing authorization. Unlike a specific license, which you have to apply for and receive from OFAC, it lets any person conduct the described transactions as long as they stay inside its terms.

The core of GL X is broad. It authorizes all transactions otherwise prohibited by the listed Iran authorities that are ordinarily incident and necessary to the production, sale, delivery, or offloading of crude oil, petrochemical products, or petroleum products of Iranian origin. That authorization expressly extends to transactions involving vessels blocked under those authorities, and it runs through 12:01 a.m. eastern daylight time on August 21, 2026.

The license spells out what “ordinarily incident and necessary” covers, and the list is long:

• Safe docking and anchoring of vessels carrying the covered products
• Preservation of the health or safety of a vessel’s crew
• Emergency repairs and environmental mitigation or protection activities
• Vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage

Two notes to the license widen it further. First, the covered products include those produced by entities sanctioned under the Iranian Transactions and Sanctions Regulations (31 CFR part 560), the Iranian Financial Sanctions Regulations (31 CFR part 561), and the Global Terrorism Sanctions Regulations (31 CFR part 594). Second, the authorization reaches the importation of these products into the United States where that importation is ordinarily incident and necessary to the sale, delivery, or offloading. GL X also confirms in paragraph (b) that payments owed to Iran, the Government of Iran, or a blocked person for these purchases may be made in U.S. dollars.

What General License X Does Not Authorize

A general license is only as good as its four corners, and GL X draws hard lines. It does not authorize:

• Any transaction involving a person located in or organized under the laws of North Korea, Cuba, the Covered Regions of Ukraine (as defined by E.O. 14065), or the Crimea region of Ukraine (as defined by E.O. 13685), or any entity owned or controlled by, or in a joint venture with, such persons.
• Any other transactions or activities prohibited by any other Executive order or by any part of 31 CFR chapter V that the license does not reference.

GL X is a temporary, product-specific window, not a repeal of Iran sanctions. It expires on August 21, 2026. Anything outside the oil-and-petroleum supply chain it describes, and anything touching the excluded jurisdictions, stays prohibited. Companies relying on it should document that each transaction fits the license and should be ready for the authorization to lapse.

What Iran General License Z Authorizes

General License Z runs the other way. Issued alongside the July 14 designations under Executive Order 13902, it is a wind-down license. Its full title is “Authorizing Wind Down Activities, Limited Safety and Environmental Transactions, and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on July 14, 2026.”

GL Z authorizes transactions ordinarily incident and necessary to a defined set of activities involving the persons and vessels named in its Annex (and any entity those blocked persons own 50 percent or more) through 12:01 a.m. EDT on September 12, 2026. The catch is that any payment to a blocked person has to be made into a blocked, interest-bearing account located in the United States. The authorized activities are:

• Winding down financial transactions involving the blocked persons or vessels
• Safe docking, anchoring, and departure of the blocked vessels at ports outside Iran and Russia
• Preserving the health or safety of the vessels’ crews
• Emergency repairs and environmental mitigation for the vessels
• Delivering and offloading cargo that was already loaded on or before July 14, 2026, at a port outside Iran and Russia

As with GL X, the license clarifies that this includes services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage. But GL Z pointedly does not authorize entering into any new commercial contracts involving the blocked persons’ property, and it does not authorize anything otherwise prohibited by E.O. 13902 or the rest of 31 CFR chapter V, including transactions caught by the Iranian Transactions and Sanctions Regulations at 31 CFR part 560.

The GL Z Annex: Which Vessels Are Covered

The wind-down applies to a specific list of blocked persons and their vessels. The Annex pairs each blocked company with the identified vessel:

• Aare Lines Inc — NADIA (IMO 9122461)
• Ava Tarabar Darya Company — SEPEHR PAYAM (IMO 9110535)
• Hope 1 Shipping Inc — HOPE 1 (IMO 9514339)
• Kangri 1 Inc — CICCIO (IMO 9192442)
• Lubeck Shipping LLC — GEMMA (IMO 9509097)
• Nuvetrro Shipping Inc — JADE (IMO 9418999)
• Ocean Searum One Limited — ELPINIKI, also known as CORN (IMO 9606015)
• Sea Lead Shipping PTE. Ltd. — PAYA LEBAR (IMO 9134232), SHENTON WAY (IMO 9146314), and TANJONG PAGAR 1 (IMO 9404508)
• Veltrrivo Shipping Inc — OPAL (IMO 9467158)

If your company is party to a charter, an insurance policy, a bunkering contract, or a cargo already loaded onto one of these vessels, GL Z is the narrow path OFAC gives you to get out cleanly before September 12, 2026 — not a license to keep doing business.

The July 14 Shamkhani Designations: 50+ Added to the SDN List

The designations GL Z winds down are what the July 14 action was really about. OFAC targeted the illicit shipping and sanctions-evasion network of Mohammad Hossein Shamkhani, whom Treasury describes as a major force behind Iran’s oil exports and, increasingly, its global container shipping and commodities trade. The action was taken under Executive Order 13902, which reaches key sectors of Iran’s economy, and it followed prior rounds against the same network in July 2025 and April 2026. By Treasury’s count, it has now sanctioned more than 200 individuals, entities, and vessels operating under Shamkhani’s patronage.

Treasury framed the July 14 action as part of a maximum-pressure campaign under National Security Presidential Memorandum 2 (NSPM-2), tied to Iran’s resumed attacks in the Strait of Hormuz, and carried out in coordination with Treasury’s Financial Crimes Enforcement Network (FinCEN). Here is how the network breaks down.

The financiers. Iranian nationals Hossein Ghorbani Zahed and Mohammad Reza Rahbar Madani, who both also hold Dominica passports, served as primary financiers, providing exchange-house services, foreign currency, and shell companies outside Iran. Zahed owns British Virgin Islands- and Dubai-based Golden Nest Group Ltd and directs Dubai-based BSG Management Ltd, both designated. Iranian-Russian dual national Ali Rakhbarmadani, described as effectively the network’s head of shipping, is tied to sanctioned Koban Shipping, Crios Shipping, and Marvise SMC DMCC, and owns Dubai-based Al Kina Commercial Broker LLC.

The executives. Danish national Martin Austin Kaalund and Italian national Alessandra Ronco spent years running sanctioned shipping-oversight company House of Shipping Investment FZCO, where they served as global CFO and global CEO respectively, and co-founded Dubai-based Evorit Strategy Consulting LLC-FZ, also designated. Iranian national Asghar Aghili Dehkordi held strategy roles across multiple network companies.

The containerized shipping arm. Singapore-based Sea Lead Shipping PTE. Ltd. and its subsidiaries in Dubai, the Marshall Islands, and India, along with Dubai-based Volta Shipping Services LLC and the multi-country We Freight group, let the network blend licit and illicit cargo, including goods bound for the Houthis (Ansarallah) in Yemen, with the proceeds flowing back to Shamkhani.

The vessels and their shell owners. OFAC designated a fleet of single-vessel shell companies flagged across the Marshall Islands, Panama, Antigua and Barbuda, St. Kitts and Nevis, Palau, Barbados, and Hong Kong, and identified their ships as blocked property. The list runs from container ships like PAYA LEBAR and SHENTON WAY to a Caspian Sea fleet moving cargo between Iran and Russia (SEPEHR PAYAM, ERIKA, ARKANOOR 2, and ARKANOOR 3), to four ships of undisclosed ownership and unknown flag (SEA CRUISER, SEA CASTLE, SEA ANCHOR, and SEA GALLEON). OFAC also designated two tankers, DARIKA and VIRENT, that have carried Russian petroleum products for the network.

OFAC used the same action to update the SDN List entry for Bank Markazi (the Central Bank of Iran), adding six new TRON (TRX) digital-currency addresses. Listing a blocked party’s crypto addresses is routine for OFAC now.

How OFAC Reached a Global Shipping Network

For a compliance officer, the legal theories behind these designations matter more than the headline count. Almost none of the July 14 targets are located in Iran. OFAC reached a Danish executive, an Italian executive, Indian and British managers, and shell companies from the Marshall Islands to Hong Kong using three familiar authorities under E.O. 13902:

• Material support. The financiers, managers, and service companies — Zahed, Madani, the Sea Lead service providers, We Freight, Volta, and the shell owners — were designated for having materially assisted, sponsored, or provided support or services to Shamkhani or the network. You do not have to sit in Iran, or intend to break U.S. law, to be designated for providing goods or services to a blocked person.
• Ownership and control, and the 50% Rule. Subsidiaries like the Sea Lead entities and Evorit were designated as owned or controlled by, or acting on behalf of, a blocked parent. That mirrors OFAC’s 50% Rule: any entity owned 50 percent or more, individually or in the aggregate, by blocked persons is itself blocked, whether or not OFAC ever names it. The same logic makes the network’s vessels blocked property in which a designated owner holds an interest.
• Acting for or on behalf of a blocked person. Al Kina was designated as owned or controlled by Ali Rakhbarmadani; Kaalund for acting on behalf of House of Shipping; Ronco for acting on behalf of Evorit. OFAC can follow the chain of agency link by link.

The lesson for a flag registry, a classification society, a P&I club, a bunkering supplier, or a commodities trader is blunt: provide services to a sanctioned shipping network and your company can land on the SDN List, wherever it is based and whatever flag its ships fly.

What This Means for Shipping, Insurance, and Commodity Traders

The July 14 action shows how easily the maritime sector gets pulled into Iran sanctions exposure. A few points stand out:

• All U.S.-nexus property is blocked. Property and interests in property of the designated persons that are in the United States or in the possession or control of U.S. persons are frozen and must be reported to OFAC. The 50% Rule extends the freeze to entities the blocked persons own, even unnamed ones.
• Strict liability applies. OFAC can impose civil penalties on a strict liability basis, so a charterer, insurer, or trader can be penalized even if it did not know a counterparty or vessel was blocked. Screening vessels by IMO number — not just by company name — is the difference between catching a designation and missing it.
• Secondary sanctions and facilitation reach foreign parties. Non-U.S. persons risk exposure for causing U.S. persons to violate sanctions and for conduct that evades them. Flags of convenience, single-ship shell companies, and layered ownership are exactly the structures OFAC is designed to see through.
• The general licenses are narrow windows, not safe harbors. GL X authorizes a defined slice of the Iranian-origin oil trade through August 21, 2026, and GL Z gives a wind-down runway through September 12, 2026. Where a broad product authorization and a targeted new blocking overlap — for example, oil transactions that also involve a newly blocked vessel — the right course is careful legal analysis, not an assumption that one license cures the other.

If You or Your Vessel Was Caught in the July 14 Designations

Being swept into an action like this — whether OFAC named you directly, the 50% Rule pulled your company in, or your dollar payments froze mid-voyage — does not leave you without options. The realistic paths forward include:

• Wind down under GL Z. If you are a counterparty to a blocked person or vessel in the Annex, GL Z lets you complete safety, environmental, and cargo-offloading steps and wind down financial dealings before September 12, 2026, with payments routed into a blocked U.S. account.
• Apply for an OFAC license. Activity a general license does not reach may still be authorized through a specific license — for instance, transactions that need to continue past a wind-down deadline or that fall outside GL X’s scope.
• File an unblocking application. If your funds or accounts were frozen because of a designation, an unblocking application is often the route to releasing them.
• Petition for SDN List removal. A designated party can file a petition for administrative reconsideration under 31 C.F.R. § 501.807, arguing that the conduct behind the listing has stopped or that there was never an adequate basis for it. OFAC now routes these through its Reconsideration Portal.

Treasury made a point of saying the power of sanctions comes “not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law.” The stated goal is a change in behavior, not permanent punishment. A well-built delisting or unblocking case is meant to use that opening.

Frequently Asked Questions

What is Iran General License X?

Iran General License X is an OFAC authorization, issued June 22, 2026, that permits transactions ordinarily incident and necessary to producing, selling, delivering, or offloading Iranian-origin crude oil, petrochemical products, and petroleum products — including transactions involving blocked vessels — through 12:01 a.m. EDT on August 21, 2026. It does not authorize dealings involving North Korea, Cuba, Crimea, or the Covered Regions of Ukraine, and it does not override other sanctions prohibitions.

When does Iran General License Z expire?

General License Z authorizes wind-down, limited safety and environmental transactions, and cargo offloading involving the persons and vessels blocked on July 14, 2026, through 12:01 a.m. EDT on September 12, 2026. Payments to a blocked person during the wind-down must be made into a blocked, interest-bearing account in the United States.

Does General License X make it legal to buy Iranian oil?

Only within its terms and only until it expires. GL X authorizes a specific set of oil, petrochemical, and petroleum transactions and permits related U.S.-dollar payments, but it excludes several jurisdictions and does not touch prohibitions outside its scope. Because the authorization is temporary and product-specific, buyers should confirm each transaction fits the license and get counsel before relying on it.

What is the OFAC 50% Rule?

Under the 50% Rule, any entity owned 50 percent or more, directly or indirectly and individually or in the aggregate, by one or more blocked persons is itself blocked — even if OFAC never lists it by name. It is how designating a network principal like Shamkhani automatically reaches the subsidiaries and vessels his companies own.

How do I get my company or vessel removed from the SDN List?

You file a petition for administrative reconsideration with OFAC, generally through its Reconsideration Portal, showing that the basis for the designation no longer exists or never applied. For a shell company, that often means proving the sanctioned relationship has been severed; for an individual, it usually means showing they have left the blocked role. A sanctions attorney can help assemble the evidentiary record these petitions require.

Talk to an OFAC Sanctions Attorney

General Licenses X and Z show how quickly the ground can shift in the Iranian energy trade: a broad oil authorization one month, more than 50 shipping designations and a wind-down license the next. If your company charters vessels, insures cargo, trades petroleum, or clears payments anywhere near this network — or if you have been designated, blocked under the 50% Rule, or frozen out of the dollar system — the first few weeks are when your options are widest.

Sanctions Law Center is a Washington, DC firm focused on OFAC sanctions. We handle OFAC licensing, unblocking applications, SDN List removal petitions, and compliance counseling for clients around the world. Contact us for a confidential case evaluation.