OFAC Iran General Licenses AA and BB — wind-down authorizations tied to E.O. 13902 sector expansion

Mechanism

Both licenses are administrative wind-down instruments issued the same day (24 August 2026) OFAC also determined that E.O. 13902's section 1(a)(i) sanctions authority now reaches the aviation, digital-asset, gold, shipping, and technology sectors of the Iranian economy (a companion determination, FR Doc 2026-17487, filed separately if not already in the register). GL AA is entity-specific: it gives La Nivernaise De Raffinage SAS — a French petroleum-refining company — and its majority-owned affiliates a 60-day window to unwind pre-existing business rather than face immediate blocking, which is the standard OFAC pattern following a sanctions-exposure event tied to E.O. 13902. GL BB is a housekeeping instrument: it lets counterparties finish transactions that were legitimately authorized under five older, narrower general licenses (education, remittances, conferences, sports and academic exchange) whose underlying authorizations have lapsed or been superseded, again with a hard wind-down deadline (8 September 2026) and a blocked-account payment requirement for any payment reaching a blocked person.

Neither license expands what is permitted going forward — both are exit ramps for pre-existing activity under a sanctions regime that, per the companion E.O. 13902 sector determination, is simultaneously widening. That is why this is filed without a polarity: liberalising tag: a wind-down window on a restrictive measure is a carve-out, not relief.

Downstream implications

• La Nivernaise De Raffinage SAS and any counterparties with pre-existing

contracts must complete an orderly exit by 23 October 2026 or become exposed to secondary-sanctions risk under E.O. 13902.

• Entities relying on the five general licenses named in GL BB (educational,

remittance, conference, sports, and academic-exchange channels) have until 8 September 2026 to close out transactions under the old authorizations.

• Confirms OFAC's standard operating pattern of pairing a sector-expansion

determination with narrow wind-down licenses for entities caught by the expanded scope — worth checking for a parallel SDN designation or E.O. 13902 determination naming La Nivernaise De Raffinage SAS directly.

Open questions

• No OFAC press release or SDN list entry specifically naming La Nivernaise

De Raffinage SAS was located in this pass — worth re-checking OFAC's recent-actions page for the underlying designation or determination that triggered GL AA.

• Whether the companion E.O. 13902 sector-expansion determination (FR Doc

2026-17487, aviation/digital-asset/gold/shipping/technology sectors) is separately filed in the register.