OFAC Publishes Temporary General Licenses for Iran Sanctions Wind-Down

You might care about this because the U.S. Treasury's Office of Foreign Assets Control, or OFAC, has officially published two new temporary general licenses related to sanctions on Iran. These licenses, called GL AA and GL BB, were first made available on OFAC's website in August 2026. They are important because they allow for specific activities that would otherwise be against U.S. sanctions. GL AA permits certain operations and the winding down of transactions involving a company called La Nivernaise De Raffinage SAS, or LNR, and its related entities. This authorization helps these entities conclude their affairs without violating Executive Order 13902, which imposes sanctions on various sectors of Iran. This particular license is temporary and expires on October 23, 2026. GL BB, on the other hand, deals with winding down transactions that were previously allowed under a different set of rules, the Iranian Transactions and Sanctions Regulations. This includes activities like certain educational exchanges, personal money transfers, and services for conferences or sports. This license has an earlier expiration date of September 8, 2026. Both licenses are designed to provide a limited window for certain activities to conclude or continue for a short period, rather than imposing an immediate and complete halt. They clarify what is allowed and under what conditions, offering guidance to those affected by Iran sanctions. What makes these licenses particularly interesting is their temporary and specific nature. They are not broad changes to sanctions policy, but rather targeted authorizations for specific wind-down periods. GL AA focuses on a particular entity, La Nivernaise De Raffinage SAS, allowing for an orderly exit or continuation of certain operations. This suggests that the U.S. government is providing a structured approach for companies to adjust to sanction requirements. GL BB is also noteworthy because it acknowledges that some previously authorized activities, like educational and cultural exchanges, may need a grace period to conclude. Instead of an abrupt end, it offers a short extension to finalize these transactions. This shows a practical approach to implementing sanctions, recognizing that immediate cessation can create complications. These licenses serve as administrative tools to manage the practical effects of complex sanctions, providing clarity and temporary relief in defined circumstances. They highlight how OFAC uses general licenses to manage the practical impact of sanctions enforcement, ensuring that affected parties have a clear path for compliance during transition periods. People who would be most interested in this legal document include businesses and individuals who have or had dealings with Iran, especially those affected by U.S. sanctions. Companies that have had contracts or operations with La Nivernaise De Raffinage SAS, or LNR, would find GL AA directly relevant as it provides a timeline for winding down their activities. Legal professionals specializing in international trade law, sanctions compliance, or U.S.-Iran relations would also need to be aware of these publications to advise their clients. Furthermore, academic institutions, students, and organizations involved in cultural or sports exchanges with Iran, or those sending noncommercial personal remittances, would be interested in GL BB. This includes anyone who was previously operating under the specific general licenses mentioned in GL BB and needs to finalize those transactions. Essentially, anyone whose activities might be affected by U.S. sanctions on Iran, either directly or indirectly, would find these temporary authorizations important for ensuring they remain in compliance with the law.