Lessons On Contingency Planning From OFAC's Iran Reversal

By Michelle Roberts ( July 14, 2026, 4:28 PM EDT) -- On June 22, the U.S. Department of the Treasury's Office of Foreign Assets Control issued General License X, authorizing a broad range of transactions involving Iranian-origin crude oil, petroleum products and petrochemical products. Despite the breadth of the authorization, its short duration — it extended only through Aug. 21 — meant that banks and many others were likely to proceed cautiously. That caution, as it turns out, was well-founded....

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