📅 30 October 2026 • US Treasury / OFAC
OFAC General License FF-1 extends the wind-down window for Iraq Development Bank transactions to 12:01 a.m. EST on 1 December 2026
What OFAC issued
On 29 October 2026 OFAC issued Iran General License FF-1. It authorizes the wind-down of transactions with International Development Bank for Investment and Finance, a.k.a. Iraq Development Bank, and any entity 50 percent or more owned by it directly or indirectly, under the ITSR at 31 CFR part 560.
The expiry clock
The authorization runs out at 12:01 a.m. EST on 1 December 2026. Institutions have about a month from publication to unwind contracts, invoices and standing payment instructions touching the bank or its majority-owned subsidiaries. FF-1 replaces General License FF of 15 October 2026, whose window closed on 30 October 2026.
Blocked-account handling
FF-1 frees up no funds by itself. Any payment to a blocked person must be made into a blocked account under the ITSR, with the required records and reports kept. Files prepared before publication should be re-checked against the expiry moment.
Ownership, not names
A counterparty can be blocked even with no name match on a sanctions list, since the license covers majority-owned entities and aggregated holdings across blocked persons. Name-only screening understates this exposure.
IMPACT
Who is affected: correspondent and retail banks, payment institutions, money service businesses and corporate treasurers with exposure to the bank or its subsidiaries. What changes: after the expiry, qualifying payments go into a blocked account and new dealings fall outside FF-1.
Timelines: publication 29 October 2026, expiry 1 December 2026, after the wider Iran package of 21 October 2026. Risks: paying after expiry outside a blocked account, missing a majority-owned subsidiary in screening, and treating FF-1 as continuing authority.
Sources
ofac.treasury.gov/recent-actions/20261029, ofac.treasury.gov/media/937311/download, ecfr.gov/current/title-31/subtitle-B/chapter-V/part-560
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