USA – WASHINGTON, DC Trends and Developments Contributed by: Stephanie L. Connor, Andrew K. McAllister, Matt Rosenbaum and Manny Levitt, Holland & Knight LLP
Iran: Maximum Pressure and Early Attempts at Relief For the first half of 2026, the Trump Administration pursued a “maximum pressure” campaign against Iran, combining aggressive sanctions with the use of military force. The administration’s reliance on sanc - tions appeared to change in mid-June, when the United States and Iran agreed to a fragile peace deal under which the US promised substantial sanctions relief. Accordingly, GL X, which OFAC published on 22 June 2026, provides a temporary waiver on sanctions restricting Iran’s oil, gas, and petrochemical sector. From 22 June 2026 through to 21 August 2026, GL X has authorised transactions ordinarily incident to the production, sale, delivery or offloading of Iranian crude oil, petrochemical products or petroleum prod - ucts that would otherwise be prohibited by numerous US sanctions programmes, including those designed to counter terrorism and the proliferation of weap - ons of mass destruction, as well as those imposed on Iran and Russia. Authorised transactions include the production, sale, delivery or offloading of such crude oil, petrochemical products or petroleum prod - ucts, including transactions for the safe docking and anchoring of vessels carrying such crude oil, petro - chemical products or petroleum products; the preser - vation of the health or safety of the crew of any such vessel; emergency repairs or environmental mitigation or protection activities relating to any such vessel or to such crude oil, petrochemical products or petroleum products held in storage; and services such as vessel management, crewing, bunkering, piloting, registra - tion, flagging, insurance, classification and salvage. The authorisation extends to Iranian-origin crude oil, petrochemical products and petroleum products pro - duced by some sanctioned entities. Notwithstanding the breadth of sanctions risks miti - gated by GL X, significant compliance and other risks remain for companies doing work in Iran. Specifically, the Islamic Revolutionary Guard Corps (IRGC) status as a Foreign Terrorist Organisation (FTO) continues to present significant risks under other US laws, includ - ing the Antiterrorism and Effective Death Penalty Act of 1996, which provides for criminal penalties for per - sons who knowingly provide “material support” to a designated FTO, and the Antiterrorism Act (ATA),
which permits victims of acts of terrorism carried out by an FTO to bring civil lawsuits against persons who have provided substantial assistance to that FTO. Many US-linked companies and financial institutions will still likely decline to engage in Iranian oil trade due to these risks, particularly given the IRGC’s significant involvement in Iran’s oil and gas trade and its role as a de facto administrator of the Strait of Hormuz. Furthermore, uncertainty about the viability of the MOU and the future of the US-Iran conflict, as well as the need for congressional support for extensions of longer-term sanctions relief, means companies must be prepared for potentially rapid shifts in US sanc - tions policy towards Iran going forward. These factors complicate the business decision-making process for both US and foreign firms considering relying on any new GLs. In the lead-up to the most recent military hostilities and the implementation of GL X, OFAC and the US Department of State had published multiple rounds of designations targeting Iran. In February 2026, OFAC sanctioned over 30 individuals, entities and vessels enabling illicit Iranian petroleum sales and Iran’s ballis - tic missile and advanced conventional weapons pro - duction. In April 2026, OFAC targeted approximately 40 shipping firms and vessels operating as part of Iran’s shadow fleet, including the first designation of a major Chinese refinery directly purchasing Ira - nian crude, which marked a significant escalation in secondary sanctions risk for Chinese entities. OFAC also designated 35 entities and individuals overseeing Iran’s broader shadow-banking architecture in April 2026, targeting entities facilitating the movement of tens of billions of dollars tied to sanctions evasion. In May 2026, the Department of State designated addi - tional entities in connection with trade in Iranian-origin petrochemical products. Cuba: Escalation and Secondary Sanctions On 1 May 2026, President Trump issued EO 14404 to authorise sanctions against a broad range of targets related to Cuba, including companies in key sectors of the Cuban economy and foreign financial institu - tions (FFIs) that process significant transactions with such blocked persons. Issued pursuant to the Inter - national Emergency Economic Powers Act (IEEPA),
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