12OCT

OFAC issues no Iran sanctions waiver

3 min read

10:59UTC

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.

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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 only⁠¹. 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 drafted⁠³.

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 back⁠⁴. 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

Source Landscape

This story draws on neutral-leaning sources from United States

United States

Primary parallel: Under the 2015 Joint Comprehensive Plan of Action (JCPOA), OFAC sanctions were embedded in multiple executive orders and congressional legislation including CISADA and IFCA, requiring simultaneous regulatory action across layers that could not be resolved in a single announcement. OFAC's first Iran SDN delisting came six months after the JCPOA's signing in July 2015. Iran's negotiators had experienced that gap firsthand and expected faster delivery this time.

Counter-parallel: The 2013 Geneva interim agreement (JPOA) produced immediate, narrow OFAC waivers within days of signature, specifically for auto parts and precious metals. That precedent set Iranian expectations that Washington could act quickly when it chose to. the MOU's structure reverses the JPOA model: oil waivers are immediate, but broader relief is expressly deferred, a sequencing Iran will have difficulty accepting after the JPOA experience.

The approximately $100 billion in frozen Iranian assets and the broader secondary-sanctions architecture represent the primary economic leverage the US holds in Phase 2. Keeping them intact through 18 June preserves Washington's negotiating position but ensures Iranian oil revenue recovery remains minimal in the near term.

Oil-transaction waivers are the only channel opened immediately under the MOU. If issued, Iranian crude can in principle reach buyers without secondary-sanctions risk, but the Hormuz mine and insurer closure means no additional physical barrels move regardless of waiver status. The sanctions structure and physical supply reality have decoupled completely as of 18 June.

Consensus view: OFAC's silence on 18 June was structural, not a delay. the MOU text published on 17 June explicitly deferred full sanctions relief to a final agreement 'on a schedule to be agreed upon,' meaning no waiver could lawfully be issued without a further signed instrument. Rubio's 2 June testimony aligned precisely with that structure: the US was not offering sanctions relief for reopening alone.

Counter-view: Critical Threats (AEI) analysis noted that Iran's IRGC had already conditioned Phase 2 cooperation on evidence of real sanctions movement. From Tehran's perspective, OFAC inaction through 18 June constituted the first test of US good faith under the MOU, and Washington failed it within 24 hours of signing.

The IRGC's Ahmad Vahidi had demanded that any released assets fund military spending, suggesting the IRGC reads sanctions relief as a prerequisite for continued compliance rather than a Phase 2 reward.

Key tension: Whether Iran treats the MOU's oil-waiver-only structure as a reasonable sequencing or as evidence that Washington never intended to deliver meaningful relief, making Phase 2 negotiations structurally contested before they begin.

Sources:US Treasury (OFAC) / Congressional record·US Treasury (OFAC) / Congressional record·ABC News

Mentions:Marco Rubio →Islamabad Memorandum of Understanding →United States →Iran →Geneva →Ahmad Vahidi →US Treasury →Cuba →Washington →United Nations →Tehran →OFAC →Critical Threats →Federal Register →

First Reported In

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

US Treasury (OFAC) / Congressional record· 19 Jun 2026

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Causes and effects

Caused by

Iran deal published, Treasury record blank

The published MOU text (ID:4307) confirmed OFAC sanctions relief was contingent on a future final agreement, explaining why no waiver was issued through 18 June.

Occurred 17 Jun 2026

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This Event

OFAC issues no Iran sanctions waiver

The deal was announced as sanctions coming off, but its own schedule language defers relief to a phase that does not yet exist.

Led to

Treasury hit Hezbollah, not Iran relief

The OFAC Hezbollah designation on 18 June was the only US sanctions instrument to fire around deal-day; no Iran relief accompanied it, consistent with ID:4353.

Occurred 18 Jun 2026

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OFAC hits Oman as Iran relief stalls

OFAC's continued non-action on Iran sanctions relief through 21 June is the same pattern as the 18 June non-action, with Globe International designated under counter-terrorism rather than Iran relief.

Occurred 18 Jun 2026

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The oil licence Trump finally signed

OFAC's silence through 18 June is reversed by GL X on 22 June, the first Iran oil sanctions instrument of the conflict.

Occurred 22 Jun 2026

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Different Perspectives

Government of Latvia

Latvia abstained on 22 September when the EU renewed its individual sanctions for 36 months at the price of delisting Alisher Usmanov and Mikhail Fridman, and promised national sanctions of its own. Riga's abstention marks how far a frontline member state will go to keep listed names listed.

India's Ministry of External Affairs

After the House passed the Graham bill on 16 September, India's foreign ministry said it would keep buying energy on market terms and protect its trade. Russia supplied 30.3% of India's crude imports in fiscal 2026, so the tariff decision due around 18 October falls directly on New Delhi.

Kaja Kallas, EU foreign policy chief

Kallas answered the US licence on 10 October by saying Europe would not ease pressure, and EU ministers adopted a 22nd package of nearly 1,600 listings two days later. Brussels is tightening as Washington loosens, though TASS reported the package adds no significant new trade restrictions.

Donald Trump and the US Treasury

The Treasury licensed Russian diesel imports until 7 April 2027 on the day of Trump's call with Putin, and Trump then told reporters Ukraine should find a new leader. Washington is trading sanctions relief for fuel supply while pressing Kyiv to halt the refinery strikes behind the shortage.

Kremlin and Deputy Prime Minister Alexander Novak

After the 9 October call the Kremlin said Russia was ready to supply oil and petroleum products to American and global markets, and Novak brought forward the end of diesel export curbs. Moscow is selling the shortage back as goodwill, with volumes that Decree No. 686 now hides from outside checks.

Volodymyr Zelenskyy, President of Ukraine

Zelenskyy called GL 135 an investment in prolonging the war and offered to stop striking Russian refineries if Russia stops destroying Ukraine's energy system. Answering Trump's call for a new leader, he set a total 60-day ceasefire as the condition for elections, which puts the next move on Moscow.