September 8, 2026: OFAC Update, Part 2: Iran and Counter-Terror GL changes

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is implementing the following actions with regard to its Iran sanctions programs:

Issuing Counter Terrorism General License 37, “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on September 8, 2026”

Publishing a Notice of Suspension of Certain Iranian Transactions and Sanctions Regulations General Licenses

Iran General License J-1, “Authorizing the Reexportation of Certain Civil Aircraft to Iran on Temporary Sojourn and Related Transactions” – Suspended as of September 08, 2026

Issuing Iran General License DD, “Authorizing the Wind Down of Certain Civil Aviation-Related and Other Transactions Previously Authorized Under the Iranian Transactions and Sanctions Regulations”