On October 29, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Iran General License FF-1 under the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), authorizing the wind-down of transactions involving International Development Bank for Investment and Finance, also known as Iraq Development Bank. Paragraph (c) replaces General License No. FF, dated October 15, 2026, in its entirety, effective October 29, 2026. The authorization runs through 12:01 a.m. eastern standard time on December 1, 2026.
US banks and USD correspondent banks with payment chains involving International Development Bank for Investment and Finance (Iraq Development Bank), US persons with outstanding contracts or transactions with that bank, US persons dealing with entities in which Iraq Development Bank owns 50 percent or more, and non-US banks closing USD transactions with that bank under the Iranian Transactions and Sanctions Regulations must wind down transactions ordinarily incident and necessary to those dealings by December 1, 2026, and make any payment to a blocked person into a blocked account under 31 CFR part 560, or after December 1, 2026 the authorization in Iran General License FF-1 ends, so transactions prohibited by the ITSR involving that bank are again barred and can draw OFAC civil penalties under the International Emergency Economic Powers Act and 31 CFR part 501.
What does Iran General License FF-1 authorize through December 1, 2026?
Paragraph (a) authorizes, except as paragraph (b) provides, all transactions prohibited by the ITSR that are ordinarily incident and necessary to the wind down of any transaction involving International Development Bank for Investment and Finance, a.k.a. Iraq Development Bank, or any entity in which Iraq Development Bank owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. eastern standard time on December 1, 2026. Any payment to a blocked person must be made into a blocked account in accordance with the ITSR. The operative text is the Iran General License FF-1 PDF, posted on OFAC's October 29, 2026 recent-actions page.
Paragraph (c) states only that, effective October 29, 2026, General License No. FF, dated October 15, 2026, is replaced and superseded in its entirety. FF-1 does not state when that earlier license ended. The wind-down end paragraph (a) states is 12:01 a.m. eastern standard time on December 1, 2026.
| Point | General License FF | General License FF-1 |
|---|---|---|
| License date | October 15, 2026 | October 29, 2026 |
| Wind-down end stated in FF-1 | Not stated in FF-1 | 12:01 a.m. eastern standard time, December 1, 2026 |
| Status from October 29, 2026 | Replaced and superseded in its entirety | Operative text; blocked-person payments go to a blocked account under the ITSR |
Who must wind down dealings with Iraq Development Bank?
The actors inside the remaining window are US banks and USD correspondent banks whose payment chains touch International Development Bank for Investment and Finance (Iraq Development Bank), US persons with outstanding contracts or transactions with that bank, US persons dealing with entities in which Iraq Development Bank owns 50 percent or more, and non-US banks that close USD transactions with that bank under the ITSR.
Paragraph (a) covers Iraq Development Bank and any entity in which it owns, directly or indirectly, a 50 percent or greater interest. Those are the blocked persons the license describes. An entity below that line, or any other person blocked under the ITSR, stays outside paragraph (a) unless a separate license applies.
What must be finished before December 1, 2026?
Those actors must complete only transactions ordinarily incident and necessary to the wind-down, and place any payment to a blocked person into a blocked account under 31 CFR part 560, before 12:01 a.m. eastern standard time on December 1, 2026.
- List open contracts, correspondent chains, and unpaid items naming the bank or an entity it owns at 50 percent or more.
- Decline anything that is not ordinarily incident and necessary to the wind-down. Paragraph (b) leaves every other ITSR prohibition unauthorized unless a separate license exists.
- Pay a blocked person only into a blocked account in accordance with the ITSR.
- Treat General License FF as replaced. Paragraph (c) superseded that license in its entirety, effective October 29, 2026.
What stays prohibited after the FF-1 window?
Paragraph (b) does not authorize any transaction otherwise prohibited by the ITSR, including transactions involving any person blocked pursuant to the ITSR other than the blocked persons described in paragraph (a), unless separately authorized. After December 1, 2026 those dealings are again barred and can draw OFAC civil penalties under the International Emergency Economic Powers Act, 50 U.S.C. 1701-1706, and 31 CFR part 501. The license states no further window past 12:01 a.m. eastern standard time on December 1, 2026.
Obsidian follows OFAC license amendments of this kind as they are issued.
Confirm the chains, contracts, and 50 percent-owned entities still inside paragraph (a), route any remaining payment to a blocked account, and brief payments and sanctions on the December 1, 2026 cutoff.
