OFAC issues Iran wind-down GL Z and adds crypto addresses to Central Bank of Iran listing
Screening, maritime and crypto-compliance teams must treat the newly listed SDNs, six new Central Bank of Iran Tron addresses and named vessels as blocked, relying on GL Z only for authorised wind-down, safety or offloading transactions
Change
On 14 July 2026, OFAC issued Iran General License Z authorising a wind-down through 12 September 2026, limited safety-and-environmental transactions, and cargo offloading involving the persons and vessels blocked on 14 July 2026, and updated the SDN List with numerous Shamkhani-network parties and vessels and with six new Tron (TRX) digital-currency addresses added to the Central Bank of Iran (Bank Markazi) designation.
Why it matters
GL Z is a narrow wind-down authorisation running to 12:01 a.m. EDT on 12 September 2026: dealings otherwise prohibited by the 14 July blocking may proceed only to wind down existing positions or to carry out limited vessel safety, emergency-repair, and cargo-offloading activity, and only under three conditions — payments to blocked persons must route into a US blocked interest-bearing account, no port activity may occur at Iranian or Russian ports, and cargo qualifies only if loaded on or before 14 July 2026. GL Z does not authorise any new commercial contract with the blocked persons. The SDN update simultaneously adds Shamkhani-network individuals, companies and vessels (with addresses, passport numbers and IMO/MMSI identifiers) and, in a separate amendment, adds six Tron addresses to the existing Central Bank of Iran listing. Firms must load the new identifiers into screening and document any GL Z reliance against these conditions and the 12 September deadline.
Implications
- — Sanctions and transaction-monitoring teams at virtual-asset service providers and custodians must add the six Tron (TRX) addresses now listed under the Central Bank of Iran (Bank Markazi) designation to on-chain screening and block any transfer to or from them — they are property of a designated party marked subject to secondary sanctions, so dealing in them breaches OFAC blocking rules and creates exposure even for non-U.S. persons.
- — Bank sanctions-screening teams at financial institutions must add the newly listed Shamkhani-network SDNs and identify blocked vessels by IMO number, blocking matching property and transactions unless a specific transaction qualifies under General License Z.
- — Compliance and treasury teams relying on General License Z must complete authorised wind-down dealings before 12:01 a.m. EDT on 12 September 2026 and route any payment to a blocked person into a blocked interest-bearing account located in the United States; a payment into any other account, a transaction outside the wind-down and limited safety, repair or offloading categories, or any dealing after expiry remains prohibited and exposes the firm to strict-liability penalties and secondary sanctions. GL Z does not authorise entry into any new commercial contract with the blocked persons.
- — Shipowners, charterers, port operators and terminal agents relying on General License Z must confirm three conditions before acting: the cargo was loaded on or before 14 July 2026; the docking, departure or offloading does not occur at a port in Iran or the Russian Federation or under those governments' control; and reliance on GL Z is documented. Offloading outside these conditions, or after 12 September 2026, involves blocked property and is unauthorised.
Who is affected
- — Sanctions and transaction-monitoring teams at virtual-asset service providers and custodians
- — Bank sanctions-screening teams at financial institutions
- — Compliance and treasury teams relying on General License Z
- — Shipowners, charterers, port operators and terminal agents
What to watch
- — General License Z expires at 12:01 a.m. EDT on 12 September 2026. After that time, transactions with the persons and vessels blocked on 14 July 2026 are no longer permitted under the wind-down exception and require a specific OFAC licence.