JCPOA Again? What The New U.S.–Iran MOU Does (And Doesn’t) Mean For Sanctions

This week delivered the kind of headline that had international trade compliance practitioners’ heads swimming: a 14‑point Memorandum of Understanding (“MOU”) between the United States and Iran, aimed at ending hostilities, reopening the Strait of Hormuz, and setting a 60‑day clock for negotiating a final deal on Iran’s nuclear program and broader sanctions relief.

The signing itself had some flair: President Trump put pen to paper on June 17 at the Palace of Versailles, mid-dinner with French President Macron on the margins of the G7 summit, while President Pezeshkian signed separately and electronically from Tehran. Versailles has hosted history-making documents before; but this one comes with rather more modest aims.

CNN released the official 14‑point text on Wednesday.¹ Of those fourteen points, the one that has our practice’s keen attention is Point 10, which provides:

“The United States of America undertakes that immediately upon the signing of this MOU and until the termination of sanctions, the U.S. Department of Treasury will issue waivers for the export of Iranian crude oil, petroleum products and derivatives, and all associated services, including banking transactions, insurances, transportation, etc.”

That is a lot of relief (on paper)! Not just oil exports, but the banking, insurance, and transportation activity that moves those exports. Point 11 adds that frozen or restricted Iranian funds and assets are to be unfrozen and licensed accordingly. Meanwhile, Point 7 goes further still (I mean, all the way, at least in theory) committing the U.S. to eventually terminating “all unilateral U.S. sanctions, primary and secondary” (!) However, the commitment is tempered somewhat by the caveat that it will be done only “in an agreed‑upon schedule as part of the final deal.” In other words: someday, not today.

Still, OFAC did not wait long to put the proposal into action. On June 22 — five days after the Versailles signing — Treasury issued General License X (“GL X”), effective immediately and running through August 21, 2026. Point 10’s promise of “waivers for the export of Iranian crude oil, petroleum products and derivatives, and all associated services” now has its first implementing instrument.

What GL X actually authorizes is broad in scope: all transactions ordinarily incident and necessary to the production, purchase, sale, transportation, delivery, offloading, financing, and payment for Iranian-origin crude oil, petroleum products, and petrochemicals. That covers not just the cargo itself, but the full ecosystem around it — vessel chartering, port calls, docking and anchoring, storage, transshipment, vessel management, crewing, bunkering, pilotage, insurance, classification, registration, flagging, salvage, and emergency repairs. Payments in U.S. dollars to Iran, the Government of Iran, or blocked Iranian persons for authorized purchases are also expressly permitted. Previously blocked vessels are covered too.

However, the license is subject to three important limits. First, GL X is time-limited: it expires at 12:01 a.m. EDT on August 21, 2026 — the outer edge of the MOU’s 60-day negotiating window. Whether it gets extended depends on how the final deal negotiations go. Second, GL X covers Iranian-origin petroleum only. Transactions involving Azerbaijani, Kazakh, Russian, or other non-Iranian origin oil are not authorized, even if they move on the same supply chain. Third, GL X does not authorize dealings involving North Korea, Cuba, or the Russian-occupied regions of Ukraine covered by Executive Orders 14065 and 13685, including any entities owned, controlled by, or in a joint venture with persons in those jurisdictions. Nor does it waive sanctions imposed under authorities not listed in the license — which means a range of Iran-related designation programs remain fully operative.

Bottom line: GL X is a meaningful, immediate authorization for petroleum-sector activity involving Iranian-origin oil. It is not a blanket sanctions suspension, and it is not permanent. Parties with exposure — shipping, trading, banking, insurance — should review their specific arrangements against the license’s scope and carve-outs before transacting, and keep a close eye on the August 21 expiration date.

We are monitoring developments closely and will provide further updates as the final-deal negotiations progress.

Footnote

1. Available at: https://edition.cnn.com/2026/06/17/politics/us-iran-memo-annotated-intl-vis.