United States Wind Down on Iranian Petroleum Trade – Developments and Key Implications On 1 July, we drew Members’ attention to the U.S. Office of Foreign Assets Control’s ("OFAC") General License X ("GL X"), which temporarily authorised certain activities involving Iranian petroleum trade under US law. In particular, it was highlighted that significant risks remained from an EU and UK sanction perspective, and that the Licence may be revoked or amended by OFAC at any time. Effective 7 July 2026, GL X, dated 21 June 2026, is revoked and superseded in its entirety by General License X1 (“GL X1”). Key takeaways for Members US wind down: GL X1 requires that all activity conducted under the previous GL X be wound down by 17 July 2026 and that any payments in relation to this activity that amount to funds passing to a blocked person be made into a blocked, interest-bearing account located in the US. In particular, it should be noted that GL X1 does not permit any new activities/transactions that would have previously been authorised via GL X. EU prohibitions continue to apply: EU sanctions continue to prohibit the purchase, transport and insurance of Iranian-origin oil, irrespective of destination. UK regime remains designation-based: The UK continues to impose asset freezes on Iranian persons/entities, although it does not currently impose a comprehensive prohibition on Iranian oil trade itself. Lawful trade may still result in uninsured exposure: Members should not assume that a transaction which is permissible under applicable UK sanctions laws will necessarily be free from significant insurance or financial risk. Even where a transaction involving Iranian-origin oil is permissible under applicable UK sanctions laws (for example because no designated person or entity is involved), sanctions restrictions affecting the International Group pooling arrangements, EU-based pooling partners or reinsurers may, in the event of a substantial claim, prevent or restrict the