OFAC sets separate Iran wind-down routes and deadlines

The US Treasury Department’s Office of Foreign Assets Control (OFAC) issued General Licenses AA and BB on 24 August 2026, authorising specified Iran-related wind-down transactions through 23 October and 8 September respectively. The Federal Register published the licenses on 27 August.

The instruments apply only to the activities, entities and prior authorisations identified in their text. The Federal Register record identifies no state regulatory action or state-level implementation consequence.

General License AA’s entity-specific scope

General License AA authorises transactions otherwise prohibited by Executive Order 13902 that are ordinarily incident and necessary to wind down transactions or maintain operations, contracts or other agreements in effect on 24 August 2026 involving La Nivernaise De Raffinage SAS (LNR), or an entity in which LNR owns at least 50 per cent. The authorisation runs through 12:01 a.m. eastern daylight time on 23 October 2026.

The license does not cover transactions involving other persons blocked under Executive Order 13902 unless separately authorised. Counterparty and ownership checks therefore remain part of applying the authorisation.

General License BB’s prior-authorisation route

General License BB addresses transactions otherwise prohibited by the Iranian Transactions and Sanctions Regulations, 31 CFR part 560. It authorises wind-down transactions previously permitted under 31 CFR 560.544, 560.550 and 560.554, as well as Iran General Licenses F and G.

Those prior authorisations cover certain educational activities by US persons in third countries, noncommercial personal remittances, conference-related services, professional and amateur sports activities and academic exchanges. The wind-down authorisation expires at 12:01 a.m. eastern daylight time on 8 September 2026.

Payments to a blocked person under General License BB must be made into a blocked interest-bearing account located in the United States, in accordance with the ITSR. The license does not authorise other transactions or activities prohibited by the ITSR, another executive order or another part of 31 CFR chapter V unless separately authorised.

Compliance teams should use separate review paths: verify LNR ownership and whether the relevant transaction, operation, contract or agreement was in effect on 24 August for General License AA; for General License BB, identify the applicable prior authorisation, review the blocked-account routing condition and track the 8 September expiry. Neither instrument directs parties generally to complete transactions by its cutoff.

The Federal Register publication of General Licenses AA and BB is the official record. The record identifies no subsequent docket, response or implementation event; the next monitoring points are the 8 September and 23 October authorisation cutoffs, the applicable license conditions and the official Federal Register record.