OFAC Moves to Presumption of Denial for Iran-Related Specific Licenses

Effective September 10, 2026, OFAC replaced its prior favorable licensing posture with a presumption of denial for Iran-related specific license applications under the ITSR, suspending previously issued Statements of Licensing Policy and limiting authorizations to those required by law or justified by exceptional and urgent circumstances such as risk to life, limb, or environmental safety, subject to written attestation and case-by-case review in consultation with the State Department.