Full Breakdown
Trump Administration Reverses Decades of Iran Sanctions Amid New Ceasefire Deal
6/29/2026, 4:58:47 AM
Background & Sanctions History
Since the 1979 revolution, the United States layered sanctions on Iran’s nuclear program and militia support. The 2015 JCPOA eased many restrictions, but the Trump administration withdrew in 2018 and reinstated the full regime. The 2015 Iran Nuclear Agreement Review Act requires congressional review of any nuclear-related deal, and the 2012 Iran Threat Reduction and Syria Human Rights Act forces listed U.S. companies to report Iran-related activity to the SEC.
June 2026 MoU and Immediate Actions
On June 17, President Donald Trump and Iranian President Masoud Pezeshkian signed a 14-point memorandum of understanding promising “the removal of all U.S. sanctions on Iran on an agreed-upon schedule.” The deal orders 60-day waivers for existing sanctions while details are negotiated. Treasury issued General License X on June 22, allowing oil sales in U.S.-dollar funds, and Treasury Secretary Scott Bessent confirmed Iran will invoice oil sales in dollars.
Timeline
June 17 – MoU signed; June 22 – General License X issued; June 24 – Bessent announces dollar invoicing; June 26 – Trump accuses Iran of ceasefire violations and U.S. forces strike.
Financial and Legal Challenges
The 60-day waiver window forces banks to process dollar-denominated oil payments with guidance. Firms seek “comfort letters” and fact sheets. Some advisers propose U.S.-controlled escrow accounts or restricting funds to U.S. farm goods—options not in the MoU and rejected by Iran. Banks cite past penalties, such as BNP Paribas’s near-$1 billion settlement, and demand clear compliance rules.
Official Statements
Bessent said Iran will invoice oil sales in U.S. dollars. The MoU states all sanctions will be removed on an agreed schedule, with 60-day waivers bridging the transition.
Criticism & Opposition
Former Treasury officials warn banks may avoid transactions that could breach lingering sanctions. Hawkish lawmakers argue the administration could sidestep the Iran Nuclear Agreement Review Act by labeling the MoU non-nuclear, exposing firms to liability under the 2012 Iran Threat Reduction and Syria Human Rights Act.
Verbatim Quotes
- “You want to be 100 per cent sure that you’re within compliance,” — Adam Smith, former senior adviser to the OFAC director
- “One-off transactions that close within the 60 days could work, but there may be challenges finding banks and other intermediaries willing to process transactions.” — Adam Smith
- “Financial institutions are typically more risk adverse than are their clients when we see sanctions programmes unwind,” — Michael Huneke, trade and national security lawyer, Morgan, Lewis & Bockius
- “General License X is unprecedented in the relief it offers Iran,” — Chris Kennedy, economic statecraft lead, Bloomberg Economics
Conflicting Reports & Gaps
Sources differ on whether escrow and U.S. farm-goods ideas are formal MoU components; Trump’s public proposals are absent from the signed text, and Iran has mocked them. Detailed compliance guidance remains pending.
What’s Next
The Treasury will issue detailed guidance for oil traders within a week, and congressional committees will review the MoU’s compatibility with the Iran Nuclear Agreement Review Act.
