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Iran Conflict 2026
26JUL

The sanctions that need no signature

3 min read
12:01UTC

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
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Different Perspectives
Hormuz shipping and insurance market
Kpler, Lloyd's List and S&P Global each independently put Strait of Hormuz transits at a seventh to a sixth of pre-war levels, against CENTCOM's own position that the strait remains open for transit. War-risk premiums rose from 0.25% to 3-10% of hull value in mid-July and have held steady since.
Pakistan (with China)
Pakistan (with China)
Iran's interior minister met Pakistan's army chief in Islamabad on 25 July, his second visit in ten days, with China separately pushing the same track; Islamabad's stated precondition, a halt to Gulf attacks, broke within hours when the Houthis struck Yanbu and Jazan. The channel inherits Baghdad's opening without yet fixing what broke it.
Saudi Arabia
Saudi Arabia
Saudi Arabia absorbed Houthi strikes on Aramco-linked sites at Jazan and Yanbu on 25 July without confirming them, while holding a 30-year civil nuclear agreement Trump made conditional on joining the Abraham Accords two days after signing it. Riyadh is fighting on one front while being asked to concede on another.
Iran (state security leadership)
Iran (state security leadership)
Iran's security chief said strikes continue until the enemy's "total surrender", and no IRNA, Tasnim or Fars report carries any stand-down language to match Washington's pause. Tehran reads the halt as "strategic decision-making fatigue", not a restraint it needs to reciprocate.
Washington (Pentagon and White House)
Washington (Pentagon and White House)
A Defense Department source called the bombing halt "on a hold", Pentagon spokesman Sean Parnell insisted the US "retains a deep arsenal of capabilities", and the White House credited "successful sanctions" and thirteen days of strikes for the same pause. Three explanations from one government suggest none of them is the whole one.
Oil traders
Oil traders
Sent Brent down 2.29 per cent to $98.38 a barrel on reports that mediation was reviving, moving the price on CENTCOM's quiet night rather than on Trump's same-day promise of a bigger operation with no deadline attached.