Archive

TreasuryPosts by

The Second 60-Day Clock: Treasury’s Temporary License for Iranian Oil

The deal now runs on two 60-day clocks. The first is the strait’s no-toll window. The second started this week: Treasury issued a temporary 60-day general license authorizing Iranian oil sales, freeing ~67M stranded barrels. It is the buyer-leg counterpart to the no-toll window, and it has the same shape: relieve the emergency now, defer the institution. A general license is a revocable waiver carved out of a standing prohibition, not the permanent settlement durable commerce requires. This post reads the second clock.

Read more →

Sanctioning the Collector: The OFAC Designation of the PGSA

On 27 May 2026, OFAC added the Persian Gulf Strait Authority to the SDN list, framing it as an IRGC instrument and warning shippers, insurers, financiers, and charterers of sanctions exposure regardless of payment method. Designating the collector itself is the institutional crux — and it collides directly with a reopening deal that would route global shipping through that very body. This post reads the collision and what an acceptable collector looks like.

Read more →

China’s May 2 Blocking Rules Order: The Buyer Leg Hardens

On 2 May 2026, China’s Ministry of Commerce issued the first formal prohibition order under the 2021 Blocking Rules, barring compliance inside China with US sanctions on five Chinese refineries buying Iranian crude. The order hardens the buyer leg of the four-leg toll architecture against further OFAC erosion. This post reads what changes, what doesn’t, and why a treaty-backed transit authority can coexist with the bifurcated buyer-side legal environment by design.

Read more →