U.S. Issues Two-Month Sanctions Waiver on Iranian Oil
International Trade attorney Manny Levitt was quoted in a Lloyd's List article on the U.S. Department of the Treasury's Office of Foreign Assets Control's (OFAC) issuance of General License X, a 60-day waiver authorizing a broad array of transactions related to shipments of Iranian crude, petroleum products and petrochemical products through August 21, 2026. Although the license marks the largest sanctions relief for Iran's oil and petrochemical sectors since President Donald Trump reimposed sanctions during his first term, Mr. Levitt cautioned that significant legal exposure remains for companies engaging in Iranian oil trade as a result of the Islamic Revolutionary Guard Corps' (IRGC) deep involvement in Iran's energy sector and the group's role as the de facto administrator of the Strait of Hormuz. He explained that the license offers foreign companies some comfort regarding secondary sanctions risks but does not eliminate liability under other U.S. regimes that criminalize providing support to designated Foreign Terrorist Organizations (FTO), regardless of what a particular license authorizes.
"Companies dealing with the IRGC and IRGC-linked entities, even indirectly, would still need to consider the risks they might face under separate U.S. laws that criminalize knowingly providing 'material support' to a designated FTO and permit victims of acts of terrorism carried out by an FTO to bring civil lawsuits against persons who have provided substantial assistance to that FTO," he said. "Importantly, these other legal authorities would apply regardless of whether General License X permits a particular transaction or activity."