Between 21 September and 23 October 2026 OFAC issued no licence, rule or delisting that eases the Iran airline sanctions: its recent actions page has no action after 21 October, and the Federal Register shows only republished oil licences X and X1 and wind-down licences for other targets.
Hunch. Both past reversals came out of a trade deal with China, while here the US and Iran are at war and OFAC has set a presumption of denial, so a Trump and Xi meeting on 24 September is the only visible opening.
The easing market resolves on OFAC recent actions and the Federal Register API: YES if between 21 September and 23 October 2026 OFAC issues a licence or rule that authorises dealings with an Iranian airline, restores any of the three suspended permissions, or removes one of the 27 airlines from the list. A specific licence granted privately for a safety case does not count.
Since 2018 we found eight US deadlines like this one. In each, the US government named a future date for a ban or limit on a country's planes or ships, in a published legal text. In seven, the ban started on the day named, with no delay, extension or withdrawal. Many cases come from Donald Trump's two terms. The one miss and the one later pause both came out of talks with China.