Bradley T. Smith

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 designation of 29 tankers fed into a war. The U.S. and Israel launched Operation Epic Fury on February 28, 2026, and a June 17 memorandum signed at the G7 briefly reopened Iran's oil trade under General License X. That relief died on July 17, when the license's wind-down expired after IRGC attacks on three tankers.

Updated 6 days ago

Rule Changes

As of October 2026: Signed both GLs CC and DD; leads OFAC sanctions administration

Both wind-down windows have closed. General License CC expired September 19, ending the grace period for the three Turkish Golden Global firms blocked under Executive Order 13902, and General License DD expired September 23, ending the civil aviation wind-down.

Updated Oct 6

Rule Changes

As of May 2026: 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