"Expert Q&A: Decoding the Treasury Department's Actions on Iran," Just Security

Partner Rachel Alpert authored an article for Just Security examining the Treasury Department's short-lived Iran sanctions relief, from the issuance of General License X to its revocation weeks later.

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The article walks through how General License X, issued to implement a sanctions-relief commitment in the recent US-Iran Memorandum of Understanding, broadly authorized transactions tied to Iranian oil, petrochemical, and petroleum products, but stopped short of covering transactions touching the IRGC, leaving significant practical barriers given the IRGC’s pervasive role in Iran's energy sector. Rachel details how the license was revoked just over two weeks later via General License X1 after Iran struck vessels in the Strait of Hormuz and the US responded with airstrikes, leaving companies only a ten-day window to unwind transactions they'd expected to have far longer to complete.

Rachel explains that the episode is a cautionary tale for companies operating in volatile sanctioned environments: any future Iran sanctions relief will need multilateral coordination, statutory waivers, and a longer wind-down runway to be workable, but ultimately won't be durable without real diplomatic progress and behavioral change from Iran.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

"Expert Q&A: Decoding the Treasury Department's Actions on Iran," Just Security

Partner Rachel Alpert authored an article for Just Security examining the Treasury Department's short-lived Iran sanctions relief, from the issuance of General License X to its revocation weeks later.

Read More

The article walks through how General License X, issued to implement a sanctions-relief commitment in the recent US-Iran Memorandum of Understanding, broadly authorized transactions tied to Iranian oil, petrochemical, and petroleum products, but stopped short of covering transactions touching the IRGC, leaving significant practical barriers given the IRGC’s pervasive role in Iran's energy sector. Rachel details how the license was revoked just over two weeks later via General License X1 after Iran struck vessels in the Strait of Hormuz and the US responded with airstrikes, leaving companies only a ten-day window to unwind transactions they'd expected to have far longer to complete.

Rachel explains that the episode is a cautionary tale for companies operating in volatile sanctioned environments: any future Iran sanctions relief will need multilateral coordination, statutory waivers, and a longer wind-down runway to be workable, but ultimately won't be durable without real diplomatic progress and behavioral change from Iran.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

News and Insights

Recognition

Partner Adam Unikowsky Named 2026 Appellate Attorney of the Year by The National Law Journal

Partner Adam Unikowsky has been named Appellate Attorney of the Year at The National Law Journal’s 2026 DC Legal Awards.  

 

October 23, 2026

Publications

EPA’s Power Plant Rule Adds to a Predictably Volatile Landscape, Bloomberg Law

Partner Amanda Shafer Berman and Meghan Greenfield authored an article for Bloomberg Law on the Environmental Protection Agency’s recent repeal of most Biden-era greenhouse gas standards for power plants and the litigation that followed.

October 21, 2026

Recognition

Lawdragon Names Eight Jenner & Block Partners to 2027 500 Leading Dealmakers in America List

Lawdragon has named eight Jenner & Block partners to its 2027 500 Leading Dealmakers in America guide, which recognizes the lawyers behind the most significant transactions in the United States. The honorees practice in Chicago, Los Angeles, and New York across M&A, corporate, securities, private equity, and finance.

October 19, 2026

Event

Amanda Shafer Berman to Speak on Energy and Administrative Law at WEN-DC Webinar

As the Supreme Court's new Term begins, Jenner & Block Partner Amanda Shafer Berman will join a Women's Energy Network of Washington, DC (WEN-DC) webinar on how the Court's decisions are shaping the energy sector.

October 14, 2026