Skip to content
You can now search across every topic, entity and event.What's new
Iran Conflict 2026
19MAY

The sanctions that need no signature

3 min read
17:44UTC

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.

ConflictDeveloping
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.

First Reported In

Update #143 · Diplomacy pauses for a funeral under threat

US Department of the Treasury· 2 Jul 2026
Read original
Different Perspectives
Oil market and P&I insurers
Oil market and P&I insurers
Brent cleared $87 intraday only once CENTCOM's blockade became physical rather than declared, even though P&I Clubs had already excluded Hormuz war risk a week earlier on 7 July: capital hedged ahead of enforcement, but prices moved only after it.
UAE reporting
UAE reporting
UAE reporting placed the Omani tanker deaths at one seafarer against the International Maritime Agency's count of two, the first time in this war that a Gulf state's casualty figures have diverged from an international monitor's.
Jordan
Jordan
Iranian strikes reached Jordan again on 14 July as part of the Gulf-wide retaliation for the Hormuz blockade, extending the conflict's geographic footprint to a state with no direct stake in the strait itself.
Bahrain
Bahrain
Bahrain sounded air-raid sirens on 14 July during Iran's Gulf-wide retaliation, the same day CENTCOM's blockade order and fourth night of strikes pushed the conflict's physical reach into the wider Gulf littoral.
Kuwait
Kuwait
Kuwait intercepted Iranian missiles and drones on 14 July as Tehran's blockade retaliation reached Gulf states beyond Iran's immediate shoreline, confirming Kuwaiti airspace now sits inside Iran's retaliatory envelope.
Oman
Oman
Oman absorbed the war's first tanker casualties in its own waters on 14 July, with two supertankers disabled and seafarers killed, putting the sultanate's shipping lanes directly in the path of the blockade fight for the first time.