On 21 October 2026, the US Treasury's Office of Foreign Assets Control announced Iran-related designations involving individuals, entities and vessels. At the same time, OFAC issued General Licences GG and HH. The licences address different activities and must be read separately.
General Licence GG: winding down Karnakis-related transactions
General Licence GG authorises transactions otherwise prohibited by the Iranian Transactions and Sanctions Regulations that are ordinarily incident and necessary to wind down a transaction involving Karnakis and Karnakis, or an entity it owns by 50 per cent or more. The authorisation runs through 12:01 a.m. eastern standard time on 20 November 2026.
The licence also covers transactions involving blocked individuals acting solely in an official capacity for those entities where the activity is ordinarily incident and necessary to the authorised wind-down. Payments to a blocked person must be made into a blocked account in accordance with the regulations.
GG does not authorise other transactions prohibited by the Iranian Transactions and Sanctions Regulations, including transactions involving other blocked persons, unless separately authorised.
General Licence HH: specified vessels and limited activities
General Licence HH applies to the blocked persons and vessels listed in its annex. Through the same 20 November end time, and subject to its conditions, it authorises specified wind-down financial transactions, vessel safety and environmental activities, and certain cargo delivery and offloading.
The cargo provision is bounded. The cargo must not be of Iranian origin, must have been loaded on or before 21 October 2026, and cannot be delivered or offloaded at a port in Iran or the Russian Federation or under either government's control. The licence also permits specified services supporting authorised activity, including vessel management, crewing, bunkering, piloting, insurance, classification and salvage.
HH does not authorise new commercial contracts involving blocked property outside its express permission. It also does not authorise other activity prohibited by the Iranian Transactions and Sanctions Regulations, including otherwise prohibited transactions involving Iran, the Government of Iran or Iranian-origin goods or services.
What the designation announcement does and does not establish
Treasury attributes the designation rationale and the description of the maritime network to its own investigation. A designation is an administrative sanctions action. This article does not treat it as a criminal conviction or an adjudicated finding, and it does not reproduce the identifying records in OFAC's list.
The two licences provide time-limited pathways for specified activity involving designated persons or vessels. They do not establish that every payment connected with a named party is permitted. The relevant licence, the purpose and timing of the activity, the parties, the handling of blocked funds and any other applicable sanctions authorities all remain important.
Status and limitations
General Licences GG and HH are dated 21 October 2026 and currently run through 12:01 a.m. eastern standard time on 20 November 2026. OFAC may amend or replace its materials, so the current texts and sanctions-list information should be checked before any reliance.
This article provides general information. It does not assess a particular customer, vessel, payment or transaction and is not legal advice.