The Iran Wind-Down Was Signed Day One, Published Day Three.

On 27 August 2026 the Office of Foreign Assets Control published two Iran-related general licences at 91 FR 55265. Both had been signed three days earlier, on 24 August, and posted to OFAC's website that day. General Licence BB authorises the wind-down of transactions previously permitted by the five authorisations OFAC suspended on the same date, through 12:01 a.m. eastern daylight time on 8 September 2026.

So there is a transition period after all. It runs fifteen days, and for two of them it was not in the Federal Register.

A correction to our previous report

HaiPay reported on 27 August that the suspension rule at 91 FR 54957 provided no transition period. That was accurate as a description of that document, which contains no wind-down authorisation and does not mention one. It was wrong as a description of what OFAC had actually done. General Licence BB was signed on 24 August, the same day as the suspension, and was available on OFAC's website from that date. We did not check the website. We read the Federal Register and reported what the rule said, and the rule was not the whole action.

The correction matters beyond this one story, because the sequence is the point. A firm relying on the Federal Register alone would have seen, on 26 August, five authorisations withdrawn with immediate effect and no relief. The relief had existed for two days by then and did not appear in the record until the following day.

General Licence BB covers exactly the five

The mapping is one to one. General Licence BB lists 31 CFR 560.544, 560.550 and 560.554, together with Iran General Licences F and G — the same five instruments named in the suspending rule, in the same order, with no additions and no omissions.

What General Licence BB permits is narrower than what the suspended licences permitted. It authorises transactions ordinarily incident and necessary to the wind down of a transaction previously authorised under one of the five. It does not authorise new business under them. A remittance begun before 24 August may be completed; a remittance initiated now is not covered.

One condition attaches. The authorisation applies provided that any payment to a blocked person is made into a blocked interest-bearing account located in the United States, in accordance with the ITSR. Paragraph (b) authorises nothing else prohibited by the ITSR, by any other Executive order, or by any other part of 31 CFR chapter V, unless separately authorised.

Fifteen days, and sixty

The same Federal Register notice carries a second authorisation. General Licence AA, also signed on 24 August, authorises transactions otherwise prohibited by Executive Order 13902 that are ordinarily incident and necessary to the wind down of transactions, or the maintenance of operations, contracts or other agreements in effect as of 24 August involving La Nivernaise De Raffinage SAS, or any entity in which it holds a fifty per cent or greater interest. That authorisation runs through 12:01 a.m. eastern daylight time on 23 October 2026.

Counted from the 24 August issue date, General Licence AA runs sixty days and General Licence BB runs fifteen. One is four times the other. The two are not directly comparable — AA covers one named company's operations under a different Executive order and expressly permits maintenance of operations as well as wind-down, while BB covers only the closing out of transactions under five general authorisations. But they were signed the same day by the same official, and the difference in the time allowed is a fact about how the two were treated.

What we could not verify

We did not locate a Federal Register notice designating La Nivernaise De Raffinage SAS. A search of the Federal Register for that name returns this document and nothing else, which is consistent with designation by addition to the SDN list rather than by rule, but we did not confirm the designation or its date. Everything this piece says about that company comes from the text of General Licence AA.

We again did not retrieve the text of 31 CFR 560.550 itself. As in our previous report, the descriptions of what each suspended authorisation permitted are OFAC's own wording, taken from the rule and from General Licence BB, not our reading of the underlying sections. Anyone assessing a specific transaction, and in particular anyone deciding what counts as ordinarily incident and necessary to a wind-down, needs the section text and their own legal advice.

We make no claim about volumes. Nothing in either document states how many transactions were being made under the five authorisations, or their value.

What to watch

The near date is 8 September. Eleven days remain on General Licence BB as of today, and the licence states no extension mechanism. If OFAC intends to extend it, the extension will appear on its website before it appears in the Federal Register, which is the practical lesson of the last four days.

For anyone maintaining a sanctions calendar, that is the operational change worth making. The Federal Register is the record, but it is not the fastest channel and on this action it was not the complete one. The authoritative and timely source for a general licence is OFAC's own site on the day of issue. We will be checking it.