OFAC Suspended Five Iran General Licences. One Moves Money.

The Office of Foreign Assets Control filed a two-page rule at 4:15 pm on 24 August 2026 that indefinitely suspends five general licences under the Iranian Transactions and Sanctions Regulations. It took effect that same day. It reached the Federal Register two days later, at 91 FR 54957.

Four of the five cover education, sport and conferences. The fifth, 31 CFR 560.550, authorised noncommercial personal remittances to or from Iran. For anyone who moves money for a living, that single line is the whole document.

The five, and the one that matters

OFAC stayed three sections of the regulations and two separately published general licences. In its own words, section 560.544 authorised certain educational activities by U.S. persons in third countries; section 560.550 authorised certain noncommercial, personal remittances to or from Iran; and section 560.554 authorised the importation and exportation of services related to conferences in the United States or third countries. General Licence F authorised certain services supporting professional and amateur sports activities and exchanges involving the United States and Iran. General Licence G authorised certain academic exchanges and the exportation or importation of certain educational services.

The two named licences had been in force a long time. General Licence F was issued on 10 September 2013 and published on 27 February 2014, which is 4,731 days before the suspension took effect. General Licence G was issued on 19 March 2014 and published on 19 August 2014, 4,541 days before. Both are now stayed with no stated end date.

OFAC gives its reasons in a single sentence: Iran's continued disruptions to global energy markets, attacks on partners and allies in the Middle East, reconstitution of its conventional and nuclear weapons programmes, efforts to monetize the Strait of Hormuz, and continued support to terrorist proxies.

What changed for a payments business

A general licence is a standing authorisation. It is what allows a transaction that the regulations otherwise prohibit to proceed without anyone applying for anything. Remove it and the underlying prohibition is simply back in force, because the prohibition never went away.

That is what happened to personal remittances on 24 August. The rule states the position plainly: as a result of this suspension, any such transactions are no longer authorised by OFAC as of that date. A payment that was permissible on 23 August under section 560.550 was not permissible on 24 August, and the notice recording that fact was not published until 26 August.

Two further points follow from the text. The stay is indefinite, not time-limited, and the rule sets no review date. And the suspension is a stay of the licences, not a repeal — the sections remain in the Code of Federal Regulations, marked stayed, which is a lighter-weight action that could be reversed the same way it was imposed.

Effective before it was published, and with no comment period

The procedural facts are as consequential as the substantive ones for anyone building a compliance calendar around Federal Register publication.

OFAC states that because the Regulations involve a foreign affairs function, the requirements of the Administrative Procedure Act at 5 U.S.C. 553 for notice of proposed rulemaking, opportunity for public participation and delay in effective date are inapplicable. Executive Order 12866 review does not apply for the same reason, and the Regulatory Flexibility Act does not apply because no proposed rule was required. There was no consultation, no comment file and no transition period.

The rule also carries a criminal-liability statement, included because Executive Order 14294 of 9 May 2025 directs agencies to say so explicitly. Wilful violations may be subject to criminal penalties under 50 U.S.C. 1705, and the statute requires a mens rea of wilfulness under section 1705(c). OFAC records that it consulted the Department of Justice in drafting that statement.

What we could not verify

HaiPay did not retrieve the text of 31 CFR 560.550 itself. The eCFR service did not respond when queried on 27 August, so every description of what each licence authorised in this piece is OFAC's own wording taken from the preamble of the suspending rule, not our reading of the underlying section. Anyone assessing a specific transaction needs the section text and their own legal advice, not a news summary.

We also make no claim about volumes. Neither the rule nor any source we consulted states how many personal remittances were being made under section 560.550, or their value, so this piece does not estimate the size of what was suspended. The rule states no issue date for the three CFR sections, only for the two named general licences, which is why Figure 1 shows a duration for two rows and not for the other three.

What to watch

Three things. Whether OFAC issues a wind-down authorisation, which is its usual instrument when transactions in flight need to be settled and which this rule does not provide. Whether any of the five sections is restored, since a stay is more easily lifted than a repeal is reversed. And whether the humanitarian channels that sit alongside these licences are touched next, because personal remittances and the food-and-medicine authorisations are separate provisions and only the former moved here.

The wider lesson is procedural. A rule that takes effect the day it is filed, is published two days later, and is exempt from notice and comment cannot be caught by a compliance process that watches the Federal Register on a weekly cycle. On this one, the gap between the change and the notice was two days.