Bradley T. Smith

Rule Changes

Signed both GLs CC and DD; leads OFAC sanctions administration

Companies tied to Iran's civil aviation sector have until September 23 to unwind transactions. That's the deadline in General License DD, one of two wind-down authorizations the Treasury Department's Office of Foreign Assets Control (OFAC) published in the Federal Register on September 11.

Updated Yesterday

Force in Play

Signed General Licenses X, X1, and Z — governing the brief rise and collapse of temporary sanctions relief tied to the Islamabad MOU

Treasury's December 2025 shadow fleet designations opened a campaign that turned into war. The U.S. and Israel launched Operation Epic Fury on February 28, 2026, hitting Iran's nuclear and military sites; Treasury ran a parallel 'Economic Fury' financial campaign. On June 17, Trump and Pezeshkian signed the Islamabad Memorandum, and OFAC issued General License X five days later, authorizing Iranian oil transactions through August 21.

Updated Aug 25

Rule Changes

Signed the December 17, 2025 general licenses extending Sakhalin-2 and civil nuclear authorizations

Sanctions are supposed to close doors. On December 17, the U.S. quietly propped two doors back open again, even as it slammed others shut. One narrow lane keeps Sakhalin-2 crude flowing to Japan; the other preserves financial channels for civil nuclear projects, even when payments touch sanctioned Russian banks—both running through June 18, 2026.

Updated May 15