13MAY

The sanctions that need no signature

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20:00UTC

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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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.

Source Landscape

This story draws on neutral-leaning sources from United States

United States

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Primary parallel: Sanctions relief under the 2015 JCPOA needed the opposite mechanism to Economic Fury: the US president had to actively sign a waiver roughly every four months to keep sanctions suspended, until Donald Trump declined to renew that waiver in May 2018, triggering an automatic snapback.

Counter-parallel: The Cuban embargo, imposed under the Trading with the Enemy Act in 1962, has run on delegated authority regardless of who has occupied The White House since, surviving even the Obama-era normalisation attempt, evidence that once sanctions run on standing authority they rarely reverse without a deliberate presidential act.

Immediate impact: Economic Fury has frozen close to $500 million in Iranian assets and disrupted tens of billions of dollars in revenue, according to Treasury, concentrated in cryptocurrency exchanges, shadow-banking networks and now the Persian Gulf Strait Authority itself, the body Iran created to collect Hormuz tolls.

Structural effect: designating the toll authority under counterterrorism rather than trade-sanctions statute means any government or shipping line paying an Iranian Hormuz fee risks its own dollar transactions, a legal deterrent that outlasts any single round of Doha talks.

Consensus view: The Foundation for Defense of Democracies assesses that delegated authority under National Security Presidential Memorandum 2 lets Treasury keep degrading Iran's Hormuz-toll and IRGC-procurement networks without needing a new signature, preserving leverage regardless of how the Doha talks proceed, as shown by the 27 May Persian Gulf Strait Authority and 10 June China and Hong Kong designations.

Counter-view: Bourse & Bazaar Media, which tracks Iran's economy closely, argues designations continuing on pre-war executive authority while zero new Iran filings appeared in the Federal Register between 29 June and 2 July shows Washington's enforcement machinery has become disconnected from its own diplomacy, an autopilot that can undercut negotiators' credibility if Tehran reads it as bad faith mid-talks.

Key tension: Whether delegated sanctions authority preserves US leverage, or undermines trust in the parallel diplomatic track by running independently of it.

First Reported In

Update #143 · Diplomacy pauses for a funeral under threat

US Department of the Treasury· 2 Jul 2026

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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

Turkey

Turkey, a major buyer of Russian diesel cargoes, loses that access under Moscow's first producer-binding export ban, in force from 8 July to 31 July. Ankara hosted the same week's NATO summit pledging EUR 70bn to Ukraine, sitting on both sides of the fuel-and-alliance ledger.

NATO

NATO leaders meeting in Ankara on 7 and 8 July pledged EUR 70bn in equipment, assistance and training for Ukraine across 2026, with a 2027 sustainment commitment and a $40bn Drone Edge counter-drone initiative. European allies now fund the vast majority of that package, filling the gap left by Washington's idled crude waiver.

India

India's state refiners continued buying discounted Urals crude as June's price fell to $63.18 a barrel, insulating New Delhi from the OFAC waiver gap still constraining Western buyers. Indian refiners could pick up diesel-export share as Russia's producer-binding ban shuts out its former customers.

China

China's independent refiners kept importing discounted Urals crude through June as the price fell to $63.18 a barrel, down 26% month-on-month per CREA. Beijing has said nothing on Moscow's new diesel ban, leaving Chinese refiners a likely beneficiary if Turkish and Brazilian buyers seek replacement cargoes.

United States

No successor licence has been issued since General License 134C lapsed on 17 June, leaving a 26-day gap, the longest of the war, in the Russian crude waiver. Washington's silence is tightening the channel without any stated decision, as Treasury weighs whether to let it die.

Ukraine

Ukraine's long-range strike campaign shifted from refineries to seaborne fuel tankers crossing the Sea of Azov, cutting tracked vessel traffic 55% between 30 June and 11 July, per Starboard Maritime Intelligence. The shift targets Russia's export revenue directly rather than just domestic supply, adding pressure alongside the collapsing Urals price.