Pull to refresh
Logo
What Changed
Following Why Sign Up
U.S. sets September deadlines to unwind Iran aviation and banking transactions

U.S. sets September deadlines to unwind Iran aviation and banking transactions

Rule Changes

Wind-down windows close; Iran sanctions now in full effect

September 23rd, 2026: GL DD wind-down period expires

Overview

Updated Oct 6

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.

Companies that kept transacting after those dates now face enforcement risk. OFAC has not announced extensions. One suspended license, the aircraft safety rule (31 CFR 560.528), was left off GL DD's wind-down list and lost its cover immediately.

Why it matters

Companies that missed the September deadlines now face enforcement risk for any continued Iran-related transactions.

Questions about this story

Free account needed to ask — your question is kept and asked for you right after sign-up. Answers are public.

No questions yet — be the first to ask.

Key Indicators

Expired
GL DD wind-down deadline
Civil aviation wind-down ended 12:01 a.m. EDT September 23, 2026. No extension announced.
Expired
GL CC wind-down deadline
Golden Global entity wind-down ended 12:01 a.m. EDT September 19, 2026. No extension announced.
4
Suspended Iran general licenses
OFAC suspended 31 CFR 560.522, 560.528, and 560.529, and stayed Iran GL J-1 on September 8.
1
License left off GL DD wind-down
31 CFR 560.528 (Aircraft safety) was suspended but not included in GL DD's wind-down list, losing cover immediately.

Voices

Curated perspectives — historical figures and your fellow readers.

Sign up to generate historical perspectives on this story.

Log in Sign Up

People Involved

Bradley T. Smith
Bradley T. Smith
Director, Office of Foreign Assets Control
Signed both GLs CC and DD; leads OFAC sanctions administration

Organizations Involved

U.S. Treasury — Office of Foreign Assets Control (OFAC)
U.S. Treasury — Office of Foreign Assets Control (OFAC)
US Treasury sanctions office
Wind-down periods ended; sanctions in full effect

The Treasury agency that administers U.S. economic sanctions and trade restrictions.
Golden Global group (3 firms)
Golden Global group (3 firms)
Turkish financial firms
Blocked under E.O. 13902 on September 4, 2026

Three Turkish financial firms blocked under U.S. sanctions on September 4, 2026.

Timeline

August 2026 September 2026

6 events Latest: September 23rd, 2026 · 2 months ago
Tap a bar to jump to that date

  1. GL DD wind-down period expires

    Latest Regulatory

    Civil aviation wind-down ended at 12:01 a.m. EDT. Transactions previously authorized under suspended licenses now require a specific license from OFAC.

  2. GL CC wind-down period expires

    Regulatory

    Golden Global entity wind-down ended at 12:01 a.m. EDT. Transactions involving the three blocked Turkish firms now require a specific license.

  3. Federal Register publishes GLs CC and DD

    Publication

    Both licenses formalized in the Federal Register (91 FR 57795), confirming the September 19 and 23 deadlines.

  4. OFAC suspends civil aviation licenses, issues GL DD

    Regulatory

    Suspends 560.522, 560.528, 560.529 and stays Iran GL J-1; GL DD authorizes wind-down through September 23.

  5. OFAC blocks Golden Global firms, issues GL CC

    Sanctions

    Three Turkish financial firms designated under E.O. 13902; wind-down authorized through September 19.

  6. OFAC issues GLs AA and BB

    Regulatory

    Initial wind-down authorizations for Iran-related transactions under E.O. 13902 and the ITSR, with deadlines of October 23 and September 8.

Scenarios

1

Wind-down deadlines pass without extension

Deadline passed (Q3 2026)

Discussed by: Analysts at Global Trade and Sanctions Law; OFAC's published license terms

Companies meet the September 19 and 23 deadlines and finish unwinding transactions. After September 23, any activity previously covered by the suspended licenses requires a specific license from OFAC, which analysts say will be harder to obtain. The suspension notice already states that transactions under the suspended licenses are no longer authorized except through GL BB or GL DD.

2

OFAC extends wind-down deadlines

Deadline passed (Q3 2026)

Discussed by: Sanctions compliance practitioners

If wind-down proves difficult for companies with complex aircraft leases or financing arrangements, OFAC could issue amended licenses extending the deadlines. The agency has historically granted limited extensions when industry demonstrates hardship. Any extension would appear on OFAC's website and in the Federal Register before the current deadlines.

3

Sanctions escalation continues beyond aviation

Possible Resolves by End of 2026

Discussed by: OFAC's September 8 suspension notice; sanctions policy analysts

The suspension notice says the changes reflect a shift in U.S. foreign policy toward Iran. OFAC could block additional Iranian entities under E.O. 13902 or target other sectors, repeating the pattern of short wind-down licenses followed by full restriction.

4

OFAC enforcement actions follow missed deadlines

Possible Resolves by End of 2026

Discussed by: Sanctions compliance practitioners, OFAC enforcement guidance

Companies that continued Iran-related transactions after the September deadlines face civil penalties or designation. OFAC's enforcement guidelines prioritize willful violations and those that undermine sanctions objectives.

Historical Context

2 moments from history that rhyme with this story — and how they unfolded.

May-November 2018

U.S. reimposes Iran sanctions after JCPOA exit (2018)

After President Trump withdrew the U.S. from the 2015 nuclear deal in May 2018, OFAC reimposed sanctions with two wind-down windows: 90 days for sectors including automobiles and gold, and 180 days for oil and banking. Companies raced to unwind Iranian business before the August 6 and November 4 deadlines.

Then

Most wind-downs completed; oil buyers cut Iranian imports under threat of secondary sanctions.

Now

The pattern of OFAC granting finite wind-down periods before full sanctions effect became standard practice.

Why this matters now

GLs CC and DD follow the same template: short grace periods before full restriction takes hold.

January 2020

E.O. 13902 takes effect (2020)

Executive Order 13902, signed January 10, 2020, expanded U.S. sanctions to Iran's construction, mining, manufacturing, and textiles sectors. OFAC issued wind-down authorizations so companies could exit those sectors without immediate penalties.

Then

Foreign companies withdrew from Iranian construction and manufacturing projects; secondary sanctions risk pushed most activity out of regulated channels.

Now

E.O. 13902 remains the legal basis for blocking Iranian-sector actors, including the Golden Global entities named in GL CC.

Why this matters now

GL CC is the most recent application of E.O. 13902, targeting new entities within its six-year-old scope.

Sources

(10)
+4
Federal Register Office of Foreign Assets Control Global Trade and Sanctions Law Pressure of Truth Lowdown U.S. Department of the Treasury Office of Foreign Assets Control Office of Foreign Assets Control Office of Foreign Assets Control Federal Register