"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 Rachel details how the license was revoked just over two weeks later via General License X1 after Iran struck vessels in the Strait of Hormuz and the US responded with airstrikes, leaving companies only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.

"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

Event

Associate Steven Arango to Speak at the Veterans' Legal Career Fair

On September 18, Associate Steven Arango will speak on a panel at the Veterans' Legal Career Fair (VLCF), the only legal career fair in the United States dedicated to veterans, active-duty service members, and military spouses.

September 18, 2026

Publications

Partner Lucy Blake Discusses the FCA's New Non-Financial Misconduct Regime in Law360

Partner Lucy Blake spoke with Law360 for an article examining the Financial Conduct Authority's new non-financial misconduct rules, which took effect this week and extend existing banking-sector conduct standards to roughly 37,000 non-banking financial businesses.

September 2, 2026

Publications

In American Banker, Partner Laurel Loomis Rimon Weighs in on OCC's Handling of Fintech Bank Charter Applications

Partner Laurel Loomis Rimon spoke with American Banker about how the Office of the Comptroller of the Currency is approaching bank charter applications from fintechs, amid a growing wave of companies seeking charters from federal regulators.

August 18, 2026