Iran Sanctions update

On 22 June 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued Iran General License X, "Authorizing the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian-Origin through August 21, 2026."

General License X is broadly drafted and represents a very significant change in U.S. Iran sanctions, albeit temporarily. 

However, General License X does not impact on the application of E.U. and UK sanctions which apply independently of the U.S. sanctions framework. 

Members should in particular note EU Council Regulation (EU) 2025/1975 of 29 September 2025 which amended Regulation 267/2012 and re-imposed restrictive measures against Iran. 

Articles 11 and 13 of Regulation 267/2012 (as amended) mean it is prohibited to:

• (a) Import Iranian crude, petroleum products or petrochemical products into the EU;

• (b) Purchase crude oil, petroleum products or petrochemical products which are located in or which originated in Iran;

• (c) Transport crude oil, petroleum products or petrochemical products if they originate in Iran, or are being exported from Iran to any other country;

• (d) Provide, directly or indirectly, financing or financial assistance, including financial derivatives, as well as insurance and re-insurance related to the import, purchase or transport of crude oil, petroleum products and petrochemicals of Iranian origin or that have been imported from Iran.

The change in the U.S. position should not therefore materially impact on the Club’s ability to provide cover in relation to the carriage of Iranian crude, petroleum products or petrochemicals where still prohibited pursuant to EU Regulation 267/2012.  The UK also reimposed UN sanctions against Iran in October 2025 and maintains a significant Iran sanctions program. 

Members are reminded that cover is not available for any trade that breaches applicable sanctions.