Skip to content
You can now search across every topic, entity and event.What's new
Iran Conflict 2026
23JUL

OFAC issues no Iran sanctions waiver

3 min read
19:27UTC

The US Treasury's sanctions office issued no Iran waiver, licence or delisting through 18 June; the MOU text ties full relief to a final agreement nobody has written.

ConflictDeveloping
Key takeaway

The MOU promised sanctions relief on a schedule to be agreed, which is no schedule at all.

The Office of Foreign Assets Control (OFAC), the US Treasury arm that administers sanctions, issued no Iran waiver, general licence or delisting through 18 June. Its updates that day touched Counter-Terrorism and Cuba designations only 1. The published text of the US-Iran memorandum explains the silence rather than contradicting it : full sanctions relief, including the United Nations Security Council resolutions, is tied to a "final agreement" on "a schedule to be agreed", and only oil-transaction waivers apply "immediately upon signing" 2.

That distinction matters because an OFAC licence is a mechanical instrument, not a statement. Its absence settles the question in a way a podium denial cannot. Roughly $100bn in frozen Iranian assets and a $300bn reconstruction plan are both contingent on a deal that has not been drafted 3.

Secretary of State Marco Rubio told Congress on 2 June the United States "is not discussing, nor has it offered, sanctions relief for Tehran", and he has not walked that back 4. One US official called the 14-point text a "gentleman's agreement". The structure follows the position Washington held before signing: the MOU defers relief because the administration had not conceded it. For Iran's hardliners, the empty register is evidence the deal delivers nothing now, strengthening the Paydari and IRGC case against it.

Deep Analysis

In plain English

The United States has a powerful tool called sanctions. These are legal rules that forbid US companies and anyone using US dollars from doing business with Iran. Most of Iran's money, roughly $100 billion, has been frozen in foreign banks because of them. After the deal was signed, Iran expected Washington to start loosening these rules. But OFAC, the US Treasury sanctions bureau, issued no Iran waiver on 18 June. The deal's text explains why: the main sanctions relief comes only after a bigger, future final agreement is signed. The $100 billion stays frozen. Iran cannot access it through any existing legal channel under the MOU as written.

Deep Analysis
Root Causes

The OFAC gap has three structural roots. First, the MOU was deliberately drafted to make sanctions relief conditional on a final agreement rather than the interim framework. Republican Senate pressure from Thune and others who would not back the deal without its text made immediate relief politically acute.

Second, Rubio's 2 June congressional testimony created a public record that the US had not offered Iran sanctions relief. No such reversal was issued through 18 June, meaning OFAC action would have directly contradicted the Secretary of State's testimony.

Third, OFAC's sanctions architecture spans multiple executive orders and congressional statutes. Issuing a comprehensive Iran general licence without congressional notification would create legal exposure that Treasury was unwilling to accept without a final deal in hand.

Escalation

OFAC inaction through 18 June is the first concrete data point for Iranian hardliners arguing that the MOU produced no real benefit. If Iran's IRGC or parliament uses the sanctions gap to argue that Phase 2 is futile, the escalation risk rises significantly before talks even begin.

What could happen next?
  • Risk

    The OFAC sanctions gap gives Iran's IRGC concrete evidence to present domestically that the MOU delivered nothing material, potentially undermining Pezeshkian's political position before Phase 2 begins.

    Short term · Assessed
  • Consequence

    Iran's roughly $100 billion in frozen assets remain inaccessible under the MOU structure, preventing any significant economic recovery or reconstruction spending until a final agreement is signed.

    Medium term · Assessed
  • Precedent

    The MOU's oil-waiver-only structure sets a precedent for future Iran negotiations that economic normalisation is a Phase 3 outcome, not a Phase 2 incentive, which may complicate the next negotiating round.

    Long term · Assessed
First Reported In

Update #132 · Trump lifted the blockade, not the strait

US Treasury (OFAC) / Congressional record· 19 Jun 2026
Read original
Different Perspectives
India
India
India buys more Saudi crude than any other country and has 2.5 million nationals working in the kingdom, so a $100 Brent and a live strike on Saudi tankers reach New Delhi through both fuel bills and remittance risk. Neither channel has an alternative route the way Saudi Arabia's own pipeline does.
Qatar
Qatar
Qatar co-authored the four-mediator ten-day ceasefire proposal alongside Egypt, Pakistan and Oman, centred on resuming Hormuz navigation, while separately pursuing its dated compensation claim against Iran at the UN Security Council filed on 21 July. Doha is mediating and litigating in the same week.
Israel
Israel
Israeli intelligence, reported by the Wall Street Journal, assesses Iran moved thousands of centrifuges and part of its roughly 440kg enriched-uranium stock into Pickaxe Mountain after the June 2025 strikes on its three main nuclear sites. Some of the US refuelling aircraft now deploying to the region are bound for Israeli bases and Ramon Airport.
Houthis
Houthis
Yahya Saree announced the missile and drone strikes on the Encelia and Layla on 22 July as enforcement of the embargo his forces had declared by radio warning alone two days earlier. Six vessels already turned back on the broadcast; the strike shows Houthi forces will use weapons once warnings stop working.
Saudi Arabia
Saudi Arabia
Saudi Arabia's state news agency confirmed only a fire on the Encelia's bow, with the crew safe; the Layla strike remains unconfirmed by Riyadh. The kingdom built its Petroline pipeline specifically to bypass Hormuz through the Red Sea, so the tanker fire lands on the route Riyadh had already spent billions escaping.
United States
United States
Washington is weighing both ten-day proposals but wants a longer truce than either offers, and moved F-16 and F-35 jets plus refuelling aircraft into the region while it decides. That deployment, not Trump's Pickaxe Mountain remarks, is the measurable US action, buying options for the day talks fail rather than betting on them.