OFAC Iran General Licenses CC and DD — wind-down authorizations tied to Golden Global designations and Iranian airline SDN listings

Mechanism

Both licenses are administrative wind-down instruments, not policy relief. GL CC gives the three linked Golden Global entities — an Istanbul investment bank and its asset-leasing and portfolio-management affiliates, designated under E.O. 13902 on 4 September 2026 — a 15-day window to unwind pre-existing business before full blocking consequences apply. GL DD follows a much larger enforcement action four days later: OFAC added 34 entities (almost the entire roster of Iranian passenger airlines, including Air Shiraz, ASA Jet, ATA Airlines, Atlas Aviation, AVA Airlines, Iran Air Tour, Iran Aseman, Mahan Air-linked carriers, Qeshm and Kish airlines) plus one individual and their UAE/UK/Malaysia/Kazakhstan support entities to the SDN list, and simultaneously suspended General License J-1 — the authorization, in force since December 2016, permitting non-Iranian airlines to reexport civil aircraft to Iran. GL DD is the resulting wind-down carve-out for transactions that were legitimate under the now-suspended J-1 and related authorizations.

Both licenses are filed without polarity: liberalising: a wind-down window bolted onto an escalating sanctions posture (a fresh bank designation, a 34-entity airline purge, and a licence suspension) is a carve-out for existing counterparties, not a relaxation of policy.

Downstream implications

• Counterparties with pre-existing exposure to the Golden Global entities

must complete an orderly exit by 19 September 2026.

• Any party relying on GL J-1 to reexport civil aircraft or aircraft parts to

Iran, or otherwise engaged in transactions authorized under the now- suspended aviation-related general licenses, must wind down by 23 September 2026 — after which continued dealings with the newly designated airlines expose counterparties to secondary-sanctions risk under E.O. 13902.

• The 8 September designation effectively removes nearly all Iranian

passenger air carriers from lawful third-country dealings; downstream aircraft lessors, MRO providers, and fuel suppliers with Iranian aviation exposure are the most exposed counterparties.

Open questions

• The 8 September 2026 SDN designation of 34 entities/1 individual and the

GL J-1 suspension do not yet appear to have their own action file in this register — worth filing separately given its scale (near-total Iranian passenger-airline sector designation).