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European Oil Markets
31JUL

The sanctions that need no signature

3 min read
09:33UTC

The US Treasury has kept sanctioning Iran throughout the war under a pre-war memorandum, freezing nearly half a billion dollars while Trump has signed no new order of his own.

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EconomicDeveloping
Key takeaway

US sanctions on Iran keep firing on pre-war authority; only sanctions relief needs a new signature.

The US Treasury has run a named, continuous sanctions campaign against Iran throughout the war, even as the White House has signed no new Iran measure. Treasury calls the campaign Economic Fury, and it operates under National Security Presidential Memorandum 2 (NSPM-2), a pre-war order that delegates designation power to the department rather than requiring a fresh presidential signature 1.

On 27 May the Office of Foreign Assets Control (OFAC), Treasury's sanctions arm, designated Iran's Persian Gulf Strait Authority for extorting Hormuz shipping tolls; on 10 June it blacklisted nine China and Hong Kong entities for arming the Islamic Revolutionary Guard Corps (IRGC) 2. Treasury says the campaign has frozen "nearly half a billion" dollars and disrupted "tens of billions" in regime-linked revenue 3. A direct query of the Federal Register returned zero new Iran filings between 29 June and 2 July 4.

The gap between an empty signing record and live enforcement has a mechanism. NSPM-2 delegates designation authority to OFAC through executive orders that predate the conflict, so Treasury can keep naming targets while any genuinely new instrument stalls. The one Iran action that did need a fresh signature, General Licence X, loosened sanctions rather than tightening them, and its missing escrow and reporting caps handed Chinese buyers a 60-day safe harbour . Relief requires a pen; pressure does not.

Donald Trump's public words and Washington's actions point in opposite directions. On 30 June he demanded cheap petrol on Truth Social and signed nothing ; on 1 July he called the denuclearisation of Iran "moving along well" 5. His earlier order for a Justice Department oil-gouging probe sits in the same column: enforcement motion that does not require settling the war.

Deep Analysis

In plain English

The US Treasury has been sanctioning parts of Iran's economy continuously since before the war even started, under a standing campaign called Economic Fury. It does not need the president to sign anything new each time: officials can add names to the sanctions list on autopilot. In the past six weeks alone, Treasury sanctioned the Iranian body that tries to collect tolls from ships in the Strait of Hormuz, and nine companies in China and Hong Kong accused of helping arm the IRGC, Iran's most powerful military force. Even though no new sanctions appeared in the official US government record for four straight days, that gap does not mean enforcement stopped.

Deep Analysis
Root Causes

Economic Fury runs on National Security Presidential Memorandum 2, a delegation of designation authority to Treasury that predates the war and requires no fresh presidential signature to continue. That is structurally different from General License X, the one Iran sanctions instrument that did need Scott Bessent's active signature to authorise oil sales and dollar payments .

The zero-filing gap between 29 June and 2 July does not mean enforcement paused: OFAC's designation pipeline runs independently of both the Doha talks and the Federal Register's publication cycle, so a quiet week in the public record does not mean a quiet week inside Treasury.

What could happen next?
  • Consequence

    Continued designations during the funeral pause keep economic pressure on Iran even while every diplomatic channel is closed.

  • Risk

    If Tehran reads ongoing designations as evidence Washington is not serious about a deal, it hands hardliners in the Assembly of Experts and IRGC ammunition against the negotiators.

Sources:US Department of the Treasury·US Department of the Treasury·Federal Register (National Archives)
Mentions:US Treasury →OFAC →Economic Fury →Persian Gulf Strait Authority →China →Federal Register →General License X →Donald Trump →White House →Islamic Revolutionary Guard Corps (IRGC) →Iran →Strait of Hormuz →Tehran →Truth Social →Persian Gulf →Washington →Foundation for Defense of Democracies →Doha →NSPM-2 →Hong Kong →
First Reported In

Update #143 · Diplomacy pauses for a funeral under threat

US Department of the Treasury· 2 Jul 2026
Read original →
Causes and effects
Caused by
FDD: oil licence has no enforcement
General License X is the one Iran sanctions exception needing a fresh signature, unlike Economic Fury.
Occurred 23 Jun 2026
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Trump orders a DOJ oil-gouging probe
Trump's DOJ oil-gouging probe sits alongside Economic Fury as motion not requiring settling the war.
Occurred 24 Jun 2026
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This Event
The sanctions that need no signature
The pressure that actually costs Iran money runs on delegated authority, so it continues no matter what Doha produces.
Led to
Japan reopens Iran oil talks after 2019
Treasury's use of pre-war delegated sanctions authority is the same waiver framework Japanese buyers are now testing.
Occurred 3 Jul 2026
Read story →
Different Perspectives
Sanctions compliance officer reviewing a Lukoil International GmbH bid
Sanctions compliance officer reviewing a Lukoil International GmbH bid
OFAC's amended FAQ 1224 gives a compliance desk its first published standard: full severance from Lukoil and a US-jurisdiction blocked account for sale proceeds. The conditions name neither ISAB nor Italy, so a Priolo Gargallo-linked bid answers a different question than a Neftochim Burgas or Petrotel Ploiesti one.
Managed-money funds on Brent Last Day
Managed-money funds on Brent Last Day
CFTC data for the week to 21 July showed managed money flipping 74,400 contracts to a net long of 15,665 against 1,410 short on the Brent Last Day contract, code 06765T. A fund that held that short through July has now covered it, and the spent short base raises the bar for the next leg higher.
Saudi crude exporters
Saudi crude exporters
Saudi-linked tanker transits through Bab el-Mandeb fell to about 7.5 a day after the 24 July underwriting withdrawal, pushing more barrels onto the longer route round the Cape or through the Yanbu terminal. Every diverted barrel ties up a ship for longer, and a fleet that turns slower charges more.
Tanker owners on the Bab el-Mandeb route
Tanker owners on the Bab el-Mandeb route
Lloyd's-market syndicates withdrew war-risk cover from Saudi-linked hulls on 24 July, leaving owners of that class of vessel to sail Bab el-Mandeb uninsured or not at all. Tanker transits on the route fell to roughly 7.5 a day, and cover, once withdrawn, does not return on a shipowner's timetable.
Eni
Eni
Eni's board approved second-quarter results on 29 July, swinging refining EBIT to a EUR0.08bn profit from a year-earlier loss even as group profit doubled, and named Red Sea freight cost as a cap on that improvement. A refiner absorbing higher shipping costs on Saudi-linked crude while its numbers improve treats the freight line as a drag, not a crisis.
Asian buyers (India, Japan, China, South Korea)
Asian buyers (India, Japan, China, South Korea)
Asian refiners are absorbing 62% of Yanbu's 3.75m b/d flow, the bulk of Saudi Arabia's rerouted crude now clearing east rather than into the Atlantic basin. That destination split leaves Asian buyers more exposed to any single Yanbu-specific disruption than under the kingdom's normal multi-terminal export pattern.