OFAC general licenses can create narrow operational relief, but their value depends on exact dates, counterparties, payment controls, and underlying sanctions authority. The formal publication of Iran GLs W, EE, and FF, together with Cuba GL 1, gives compliance teams a timely reason to validate license status and strengthen transaction screening.
What the Formal Publication Means for Compliance Teams
Publication Does Not Reopen an Authorization
OFAC filed notices on November 12, 2026, for publication on November 13, covering Iran GL W, Iran GLs EE and FF, and Cuba GL 1. These notices formally publish licenses that OFAC had already issued. The publication date does not generally replace the effective date, change the authorized activity, or restart a wind-down period.
That distinction is critical for transaction approval. A compliance team should not interpret the appearance of an older general license in the Federal Register as fresh authority to process a transaction. License availability must be evaluated using the original effective period, any subsequent amendments or superseding licenses, the parties involved, and the payment conditions.
The publication also does not cure activity completed outside an authorized window. Companies that relied on a wind-down license should preserve documentation showing when each transaction occurred, why it qualified, which entities were involved, and how any payment to a blocked person was handled. Relevant files may include contracts, invoices, bills of lading, vessel records, screening results, payment instructions, bank confirmations, and internal approval records.
Compliance teams should also distinguish sanctions authorization from commercial feasibility. Even when OFAC authorizes a transaction, financial institutions, carriers, insurers, and other service providers may apply more restrictive risk policies. A general license removes specified legal prohibitions only to the extent stated. It does not require another party to process the transaction or provide services.
Iran Wind-Down Licenses and Their Current Status
GL W and GL EE Are Closed
Iran GL W authorized the wind-down of transactions involving Qingdao Haiye Oil Terminal Co., Ltd. and entities it owned 50 percent or more. The authorization ran through 12:01 a.m. EDT on May 31, 2026. Payments to a blocked person were required to be placed in a blocked, interest-bearing account in the United States.
GL EE applied a similar structure to Samudra Marine Services Private Limited and entities it owned 50 percent or more. That authorization ended at 12:01 a.m. EDT on October 23, 2026. Neither license authorized transactions involving other blocked persons merely because the transaction also involved the named entity.
Original GL FF Was Superseded by GL FF-1
Original GL FF covered the wind-down of transactions involving International Development Bank for Investment and Finance, also known as Iraq Development Bank, and its 50 percent-owned entities. It initially ran through 12:01 a.m. EDT on October 30, 2026.
On October 29, OFAC issued GL FF-1, which replaced and superseded the original license. GL FF-1 extended the applicable wind-down period through 12:01 a.m. EST on December 1, 2026. As a result, compliance teams should not rely on the original GL FF text or deadline when reviewing a current transaction. They should evaluate the transaction under GL FF-1 and its specific conditions.
Payments to blocked persons under the applicable authorization must generally be placed into a blocked account as required by the Iranian Transactions and Sanctions Regulations. The licenses do not create broad authority to transact with unrelated blocked persons.
Shipping companies, terminal users, marine service providers, and banks should re-screen all parties, vessels, owners, and financial intermediaries. Screening should account for aliases, ownership, and changes in sanctions status, not merely exact-name matches against the SDN List.
Cuba GL 1 and Dual-Track Sanctions Compliance
CACR Authorization Remains the Starting Point
Cuba GL 1 authorizes transactions prohibited by Executive Order 14404 only to the extent those transactions are already authorized or exempt under the Cuban Assets Control Regulations, including activity covered by a CACR general or specific license. It does not create an independent authorization for activity that the CACR prohibits.
This structure requires a dual-track review. A company should first determine whether the transaction falls within Executive Order 14404 and the Cuba Sanctions Regulations in 31 CFR part 516. It should then identify the precise CACR exemption, general license, or specific license supporting the activity. Both analyses should be documented in the transaction file.
Sector Exposure Requires Broader Counterparty Review
The application of sector-based sanctions to Cuba's electronics, manufacturing, marine, and technology sectors increases exposure for foreign companies operating in or supporting those sectors. Screening should extend beyond the immediate Cuban buyer or seller to beneficial owners, vessels, freight forwarders, banks, agents, and other parties that may participate in the transaction.
Cuba compliance teams must also account for current restrictions affecting indirect dealings with restricted entities, U-turn processing, travel-related activity, and other financial flows. Humanitarian trade involving food, medicine, or medical devices may generally remain authorized, but each transaction still requires confirmation that all applicable conditions are satisfied.
A strong approval record should identify the business activity, involved sectors, relevant parties, payment route, CACR authority, and any conditions attached to that authority. Companies should also consider whether a change in vessel, bank, consignee, or intermediary requires renewed screening before execution.
For customs brokers, sanctions review should be coordinated with import and export workflows without being confused with customs duty law. A shipment may be properly classified and entered while still presenting sanctions risk. Conversely, OFAC authorization does not determine tariff treatment, admissibility, or eligibility for a customs refund.
- On November 12, 2026, OFAC filed three Federal Register notices (scheduled for publication November 13) formally publishing already-issued Iran wind-down GLs W, EE, and FF plus Cuba GL 1.* GL W (May 1 issuance under E.O. 13846) covered wind-down of Qingdao Haiye Oil Terminal Co., Ltd. and 50 percent-owned entities through May 31, 2026, with payments to blocked persons required in a U.S. blocked interest-bearing account. GL EE (October 8) similarly covered Samudra Marine Services Private Limited through October 23. GL FF (October 15 under the ITSR) covered International Development Bank for Investment and Finance (a.k.a. Iraq Development Bank) through October 30. Cuba GL 1 (May 7) authorizes E.O. 14404-prohibited transactions to the extent already authorized or exempt under the CACR.
- On October 29, 2026, OFAC issued Iran GL FF-1, replacing and superseding the original GL FF and extending the wind-down window for the Iraq Development Bank and 50 percent-owned entities until 12:01 a.m. EST December 1, 2026.* Payments to blocked persons must still go into a blocked account per the ITSR. This followed the October 15 designation of the bank.
- On November 5, 2026, OFAC determined that E.O. 14404 sector-based sanctions apply to Cuba's electronics, manufacturing, marine, and technology sectors, exposing foreign persons operating in them to blocking.* This accompanied State Department designations of eight entities, two individuals, and five vessels tied to Cuba's oil shipping, military support, and revenue networks (some previously Venezuela-linked). Cuba GL 1 continues to bridge the new Cuba Sanctions Regulations (31 CFR part 516, effective September 30) and the CACR.
- Law firm alerts in early November 2026 (e.g., around November 5-10) emphasized dual-track Cuba compliance under both the CACR (amended September 30 to restrict indirect CRL transactions, eliminate U-turn processing, and narrow travel GLs) and the new CSR.* GL 1 does not expand CACR authorizations and humanitarian trade (food, medicine, medical devices) remains authorized. Practitioner X posts focused more on the October 15 bank designations than the FR publications themselves.
Frequently Asked Questions
Do the Federal Register Notices Reopen the Iran Wind-Down Periods?
No. Formal publication does not generally restart or extend a license. GL W ended May 31, 2026, and GL EE ended October 23, 2026. Original GL FF was superseded by GL FF-1, which extended the relevant authorization through 12:01 a.m. EST on December 1, 2026.
What Does the 50 Percent Ownership Standard Mean?
An entity may generally be treated as blocked when one or more blocked persons own, directly or indirectly and in the aggregate, 50 percent or more of it. Screening processes therefore need reliable ownership information. An exact-name search alone may not identify entities covered through blocked ownership.
Does Cuba GL 1 Expand Existing CACR Authorizations?
No. Cuba GL 1 generally bridges Executive Order 14404 and the CACR. Activity must still be authorized or exempt under the CACR. If the CACR prohibits a transaction, Cuba GL 1 does not independently make that transaction permissible.
What Records Should Be Kept for Wind-Down Transactions?
Companies should typically retain contracts, invoices, shipment documents, screening records, ownership research, approval memoranda, payment instructions, and evidence of blocked-account handling. Records should show that the transaction occurred within the authorized period and complied with every relevant condition.
Do These OFAC Licenses Change Duty Drawback Eligibility?
The licenses do not state a change to customs duties or duty drawback eligibility. OFAC sanctions and customs refund rules operate separately. However, exports supporting a drawback claim remain subject to sanctions screening, including screening of consignees, vessels, banks, intermediaries, and other transaction parties.
How Stable Software Can Help
Connect Screening Discipline With Trade Operations
Customs brokers reviewing sanctions controls can explore Stable Software's denied-party screening platform and assess how technology fits into repeatable counterparty review workflows. Screening remains relevant across import, export, and duty drawback operations, particularly when transactions involve changing vessel, banking, ownership, or intermediary information.
Stable Software also makes DrawbackAI, duty drawback software that U.S. customs brokers can white-label for importer clients and use to file under their own filer codes. DrawbackAI is offered through a flat software license, and Stable Software never takes a percentage of the refund. This model allows brokers to retain control of client relationships, filings, and refund economics while maintaining separate sanctions compliance procedures.
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