Skip to content
Welcome, thoughtbot's Giant Robots listeners!Start here
Iran Conflict 2026
3JUN

The sanctions that need no signature

3 min read
09:04UTC

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 signature⁠1.

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 revenue⁠3. A direct query of the Federal Register returned zero new Iran filings between 29 June and 2 July⁠4.

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
International Energy Agency
International Energy Agency
G7 members agreed on 2 October to release up to 100 million barrels through the IEA over four months, front-loading diesel.
China
China
China signed the 15 October text reaffirming the Resolution 2216 arms embargo on the Houthis. The Wall Street Journal reported that Conflict Armament Research found Chinese parts in a Houthi copy of Iran's Kheibarshekan missile.
Russia
Russia
Russia joined the 15 October consensus condemning the Houthis, a month after vetoing a mandate for a UN panel of experts on Iran sanctions on 17 September. One Western official told Bloomberg that Moscow is providing Iran with missiles, and the White House rejected the assessment.
India
India
National Security Adviser Ajit Doval raised seafarer safety with Mohsen Rezaei on 12 October, after a drone hit the Petro Dolphin with 11 Indians aboard at Sohar. External Affairs Minister S. Jaishankar urged that attacks on commercial shipping and seafarers be avoided.
Lebanon
Lebanon
President Joseph Aoun met UN peacekeeping chief Jean-Pierre Lacroix in Beirut on 14 October as UNIFIL winds down before its mandate ends on 31 December. Two days later Qatar's prime minister pledged in Beirut to fund a solar plant for Lebanon.
Kataib Hezbollah
Kataib Hezbollah
The militia announced a halt to operations except against "hostile aircraft" and denied any disarmament deal with Prime Minister Ali al-Zaidi. A day later Quds Force chief Esmail Qaani urged eliminating "remaining traces of the US presence in other arenas".

Written with AI from Lowdown's published reporting. Not individually reviewed by an editor. Editorial standards.