Foley & Lardner·SANCTIONS / EXPORT CONTROLS

OFAC Revokes Iranian Sanctions Relief Amid Renewed Conflict

Any business with existing or planned operations, trade, or financial ties to Iran must immediately reassess compliance obligations to avoid steep penalties for violating the reinstated strict sanctions regime.

On July 7, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License X1, revoking its prior rollback of Iranian sanctions relief amid renewed regional conflict. The action reinstates full U.S. sanctions restrictions on all transactions, services, and trade with Iran, reversing the temporary relaxation that had been in place. Companies with existing Iran-related activities, supply chain links, or planned cross-border deals involving Iranian parties must immediately halt non-exempt transactions, review all pending contracts for compliance, and update internal sanctions screening protocols to align with the new strict regulatory requirements to avoid enforcement action.

ofac-sanctionsiran-sanctionsexport-controlssanctions-compliance

Stay ahead

Join the digest.

One email when the daily AmLaw 100 briefing ships. No noise, no pitch decks — just the grade 4–5 signal.