OFAC suspends Iran's aviation-safety general licences

The Treasury Department’s Office of Foreign Assets Control published a final rule on 10 September 2026 “indefinitely suspending three general licenses and one licensing policy issued pursuant to the Iranian Transactions and Sanctions Regulations to align with changes in the foreign policy of the United States towards Iran.”¹ The stay took effect on 8 September, two days before publication.¹ The regulations are at 31 CFR part 560, reissued under their present name in 2012.¹²

1. Every suspended authorisation concerns aviation. OFAC stays 31 CFR 560.522, 560.528 and 560.529, which “authorize, respectively, certain payments for overflights of Iranian airspace; the issuance of specific licenses for certain transactions related to aircraft safety; and bunkering and emergency repairs.”¹³ It also suspends Iran General License J-1, published on OFAC’s website on 15 December 2016, which “authorizes the reexportation of certain civil aircraft to Iran on temporary sojourn, as well as related transactions.”¹ These are the carve-outs that allow civil aviation to function across a sanctioned airspace — the payments an airline makes to overfly, the parts and services that keep an aircraft airworthy, the fuel and repairs a vessel or aircraft needs in an emergency. As of 8 September “any such transactions are no longer authorized by OFAC.”¹

2. The stated grounds are the conduct of the war and its economics. The suspension is made “[i]n response to Iran’s continued disruptions to global energy markets, attacks on partners and allies in the Middle East, reconstitution of its conventional and nuclear weapons programs, efforts to monetize the Strait of Hormuz, and continued support to terrorist proxies.”¹ Three of those five track events already in the published record: the tanker strikes of September, the lapse of the Islamabad Memorandum’s negotiating window in mid-August, and the President’s remark on 19 August that “we have things that we could sanction” (see The Islamabad Memorandum’s window lapsed without a word and Five more tankers destroyed, and the ratio keeps rising).⁴⁵

3. The rule was not put out for comment, and it did not have to be. OFAC states that “[b]ecause the Regulations involve a foreign affairs function,” the notice-and-comment and delayed-effective-date provisions of the Administrative Procedure Act are inapplicable, along with Executive Orders 12866, 14192 and 14219.¹⁶ That is the ordinary rule for sanctions, and it is what permits an authorisation to end two days before the public notice of its ending appears.

4. What lapsed on 8 September is backed by criminal law. Under the statement Executive Order 14294 requires, OFAC records that “[w]illful violations of the regulations set forth in this final rule may be subject to criminal penalties pursuant to 50 U.S.C. 1705,” and that “[t]he statutory authority for criminal liability requires a mens rea of willfulness as an element pursuant to 50 U.S.C. 1705(c).”¹⁷⁸ The practical effect is narrow but sharp: a transaction that was lawful under a general licence on 7 September was, without further notice, an offence if willfully undertaken on the 8th.