US Provides Temporary Iran Sanctions Relief With The Potential For More To Come

On June 17, 2026, the US and Iran signed a Memorandum of Understanding (the “Iran MOU”) containing the terms of their ceasefire and putting at least a temporary end to a four-month conflict. The Iran MOU includes the potential for expansive sanctions relief for Iran after decades of comprehensive US sanctions targeting the country.

The Iran MOU contains the framework for a potential final agreement as part of a broader peace plan, with terms addressing Iran’s nuclear program, $300 billion for the reconstruction and economic development of Iran, and the termination of “all types of sanctions against the Islamic Republic of Iran, including the United Nations Security Council resolutions, IAEA Board of Governors resolutions and all unilateral U.S. sanctions, primary and secondary, in an agreed upon schedule.”

The parties have committed to negotiating such a final agreement within 60 days, subject to extension by mutual consent.

If implemented in full, the Iran MOU could have significant implications for the current US sanctions framework targeting Iran. As detailed below, the Trump administration has begun implementing certain sanctions relief measures contained in the Iran MOU by issuing a broad general license allowing the sale of Iranian oil, subject to certain limitations.

Key Provisions 

Measures Taking Effect Upon Signing 

The Iran MOU contemplates several steps that would take effect immediately.

Point 9 establishes a “status quo” commitment during the 60-day negotiation period (or any extension by mutual consent of the United States and Iran), under which Iran will maintain its current nuclear posture and the United States agrees not to impose new sanctions or otherwise escalate economic pressure. This provision effectively pauses further sanctions tightening while negotiations are ongoing.

Point 10 provides 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.” 

This provision in Point 10 has now been operationalized through the issuance of a new OFAC general license (“GL”), Iran GL X, which authorizes transactions “ordinarily incident and necessary to the production, sale, delivery, or offloading” of Iranian-origin crude oil, petrochemical products, and petroleum products through August 21, 2026. The authorization is broad and includes related services such as vessel operations, insurance, transportation, and other logistical support, and permits US dollar-denominated payments in connection with covered transactions. Notably, the authorization applies even to transactions involving certain otherwise blocked vessels and allows for importation into the United States of Iranian oil where such “importation is ordinarily incident and necessary to the sale, delivery, or offloading of such crude oil, petrochemical products, or petroleum products authorized by this general license.”

Iran GL X does not authorize transactions involving certain jurisdictions, including North Korea, Cuba, Covered Regions of Ukraine as defined by EO 14065, Crimea, or any entities owned or controlled by such persons or in a joint venture with such persons.

Measures Contingent on Progress Toward a Final Agreement

Point 11 states that, during the negotiations, the United States will begin releasing certain frozen or restricted Iranian assets, which will be made available for use “for payment to any ultimate beneficiary designated by Central Bank of Iran.” The MOU provides that the United States will “issue all necessary permits and licenses” to facilitate such release and unfreezing.

Point 13 further conditions the negotiation of a final agreement on assurances that certain key provisions, including those relating to sanctions waivers and asset releases found in Points 10 and 11, are being implemented. This effectively links continued negotiations to the ongoing execution of the interim measures.

Measures Tied to a Final Agreement

The most significant sanctions-related changes are reserved for a final, fully negotiated agreement, the contours of which remain uncertain.

Point 7 contemplates that, on a schedule to be agreed upon as part of the final agreement, the United States would lift allsanctions currently imposed on Iran, including primary and secondary sanctions as well as relevant United Nations Security Council and IAEA restrictions. The scope of this commitment suggests the potential for a substantial shift in the Iran sanctions framework, although significant uncertainty remains as negotiations are ongoing.

Point 6 outlines a framework for a large-scale reconstruction and economic development plan for Iran—valued at least $300 billion—with the United States committing to provide the licenses, waivers, and permissions necessary to facilitate related financial transactions.

Implications 

The Iran MOU signals a potentially groundbreaking shift in the US sanctions framework targeting Iran. However, the durability and scope of sanctions relief remains unclear. The current GL is time-limited and potentially subject to change, and the scope of additional, future relief remains uncertain at this time. Any breakdown in talks could result in the re-imposition or tightening of restrictions.

There are also potential issues related to the implementation of sanctions relief as the Iran MOU may implicate the Iran Nuclear Agreement Review Act of 2015 (“INARA”), which generally requires the President to submit agreements related to Iran’s nuclear program to Congress and provides for a review period during which certain sanctions relief may be restricted. It is unclear if the administration or Congressional leadership view INARA as applicable to the current deal, and even if it were, there may be limited avenues for effective legal challenge.