OFAC suspends Iran licenses for overflight payments, bunkering and aircraft safety

On 10 September 2026 the Treasury's Office of Foreign Assets Control published a short rule (91 FR 57511) that switches off several long-standing carve-outs in the Iran sanctions program. OFAC says it is "indefinitely suspending three general licenses and one licensing policy issued pursuant to the Iranian Transactions and Sanctions Regulations" in 31 CFR part 560.

The date matters more than usual. The suspension took effect on 8 September 2026, two days before the rule appeared in the Federal Register. Today OFAC also published the wind-down license that goes with it.

What was suspended

Four authorizations are affected:

The rule says the three CFR sections "are stayed indefinitely" and that General License J-1's effectiveness "is stayed indefinitely" as of the same date. Transactions relying on them "are no longer authorized by OFAC as of September 8, 2026." There was no comment period; OFAC says the Administrative Procedure Act's notice-and-comment requirements "are inapplicable."

The wind-down: General License DD

The rule itself mentions no wind-down. That sits in a separate document. On 8 September OFAC issued Iran General License DD on its website, and it was published in the Federal Register on 11 September (91 FR 57795).

GL DD authorizes "all transactions prohibited by the Iranian Transactions and Sanctions Regulations" that are ordinarily incident and necessary to wind down transactions that were previously authorized under three of the four provisions: § 560.522, § 560.529 and GL J-1. It runs until 12.01 a.m. eastern daylight time on 23 September 2026. Any payment to a blocked person has to go into a blocked, interest-bearing account in the United States.

Two details are easy to miss. GL DD doesn't list the § 560.528 licensing policy for aircraft safety. And it covers only winding down existing transactions, so new deals under the suspended licenses are out.

Why OFAC says it acted

The stated aim is to "align with changes in the foreign policy of the United States towards Iran." The rule points to "Iran's continued disruptions to global energy markets, attacks on partners and allies in the Middle East, reconstitution of its conventional and nuclear weapons programs, efforts to monetize the Strait of Hormuz, and continued support to terrorist proxies."

Who it may reach

Read on their face, these were narrow authorizations: overflight payments, ship fuel and emergency repairs, aircraft safety work and the temporary reexport of civil aircraft. A bank or credit union is mostly exposed through payments. A wire for one of these purposes that was routine on 7 September now needs to fit inside GL DD, and after 23 September it has nowhere to fit.

What it could mean

For most community banks and credit unions this will touch nothing. Few have customers paying Iranian overflight fees or relying on an Iran bunkering license. We'd still spend half an hour on it.

The backdated start is the reason. Your sanctions team may have learned about the change after it already applied, and the wind-down sits in a different document from the suspension. If you have customers in aviation services, freight forwarding, ship supply or marine fuel, we think it's worth pulling wires and ACH from 8 September onward and asking whether any of them leaned on these licenses. If one did, the question is whether the payment fits GL DD, and that's a call for your BSA officer and counsel. Put 23 September in the calendar.

Documentation matters too. A short note in your sanctions log saying you reviewed the rule and GL DD, and whether you had exposure, takes five minutes and answers the question examiners tend to ask about how you track sanctions changes.

If your screening or payment procedures name specific general licenses as approved exceptions, check whether 560.522, 560.529 or GL J-1 appear in them. A stale reference to a suspended license is how someone ends up releasing a payment they shouldn't.