On June 18, 2026, President Donald J. Trump and Iranian President Masoud Pezeshkian signed the U.S.-Iran Memorandum of Understanding (MOU). The MOU starts a 60-day clock during which the United States and Iran are to negotiate specifics of a final agreement, with a tentative August 17 deadline that is extendable by mutual consent.
Several of the MOU’s central provisions directly implicate statutory sanctions and other authorities that belong to the legislative branch. Over the next 60 days, lawmakers should press the administration to ensure that any deal verifiably and permanently denies the Islamic Republic any pathway to a nuclear weapons capability; keeps reconstruction, relief, and other funds out of the regime’s terror and ballistic missile apparatuses; and prevents Tehran from holding freedom of navigation in the Strait of Hormuz hostage.
🚨 Latest (morning of June 22): The first round of talks under the MOU concluded today in Switzerland. Negotiators established communication channels to avoid incidences like Iran’s temporary threat to close the Strait of Hormuz over the weekend from derailing talks. A key outcome from Switzerland is Iran’s commitment to allow IAEA inspectors back into the country. In Washington, Treasury issued General License X that allows Iran to produce, ship, and sell its oil for 60 days (more analysis below).
FDD Action Expert Analysis
“Congress has 60 days to conduct oversight and lay down guardrails for a potential final agreement. America’s hard-won leverage from Operation Epic Fury should not be surrendered without enforceable conditions. Congressional authority over statutory sanctions is clear and must be respected throughout this process. A regime that has spent decades pursuing a nuclear weapon, financing terrorism, and murdering Americans and its own citizens does not deserve the benefit of the doubt.”
– Alexandria Paolozzi Moore, Senior Director of Government Relations at FDD Action
Congress Is Not a Bystander
Several of the MOU’s core provisions touch directly on authorities reserved to the legislative branch: congressionally enacted sanctions, appropriated funds, and treaty obligations. Submitting the agreement for review is not an optional courtesy; it is a statutory requirement. Any agreement with Iran touching its nuclear program must be submitted to Congress for review under the Iran Nuclear Agreement Review Act (INARA). No statutory sanctions relief should be offered until the review period established in INARA has ended. Lawmakers from both parties built INARA precisely so no president could unilaterally waive sanctions and implement a nuclear agreement with Iran over the objections of the people’s representatives.
A Contradiction at the Top
The administration is sending two contradictory messages. At the G-7 summit in France, President Trump said that he would submit the MOU to Congress: “I never thought about sending—never thought about it—but I will.” Yet at a White House press conference that same week, Vice President JD Vance said that the administration was “quite confident that we can temporarily lift those sanctions without going to Congress and seeking their approval,” citing an opinion from the Department of Justice that has not been made public. Congress should resolve that contradiction before any relief flows—not after.
Enacted in 2015 and codified at 42 U.S.C. 2160e, INARA establishes a mechanism for congressional review of any U.S. agreement relating to Iran’s nuclear program. President Obama signed it into law on May 22, 2015, and the Senate had approved it by a near-unanimous 99-1 vote.
Within five calendar days of reaching an agreement, INARA requires the President to transmit to Congress the full text, all related materials and annexes, a verification assessment report by the Secretary of State, and a certification addressing the agreement’s terms.
The statute also directs the foreign relations committees to hold hearings and briefings and provides for expedited consideration of a joint resolution of disapproval during the review period.
Crucially, INARA prohibits the President from waiving, suspending, reducing, or otherwise relieving statutory sanctions on Iran during the review period. Providing relief beforehand—including unfreezing Central Bank of Iran funds and assets tied to the IRGC—would circumvent the statute and undermine the legitimacy of any sanctions relief.
In May 2025, Secretary of State Marco Rubio reaffirmed Congress’ role in the review process, referencing INARA. Because the MOU initiates nuclear talks and ties sanctions relief to nuclear performance, it is precisely the kind of nuclear-related arrangement Congress intended INARA to capture.
Essential Questions Policymakers Must Ask
Q: Will the administration transmit the MOU and all required materials under INARA to Congress for review and make materials public unless doing so would threaten national security? Will the Administration submit any final agreement as a treaty or under INARA for congressional review?
- INARA bars the President from delivering statutory sanctions relief to Tehran before Congress has had its say. Waiving that role on the most consequential Iran agreement in a decade would set a precedent that any president can sideline the legislature at will.
- Paragraph 9 of the 14-point MOU has Iran affirm that it will maintain the “status quo” of its nuclear program and will not “procure or develop nuclear weapons.” That language makes the MOU itself a binding agreement—distinct from any final agreement—and squarely within INARA’s scope.
- Because an executive agreement can be reversed by the next president — as President Trump did to the JCPOA in 2018 — only a treaty ratified by a two-thirds Senate vote can give a deal of this magnitude the durability and democratic legitimacy to bind both Washington and Tehran beyond a single administration.
Q: Which sanctions will be waived, on what timeline, and under what conditions, and how will the $300 billion fund “for the reconstruction and economic development of the Islamic Republic of Iran” be controlled? Are there any guardrails in place to prevent oil proceeds from funding terrorism or repression of the Iranian people?
- Sanctions relief
- Upon the signing of the MOU, the U.S. commits to “issue waivers for the export of Iranian crude oil, petroleum products, and derivatives, and all associated services, including banking transactions, insurances, transportation.”
- On Monday, June 22, the U.S. Department of the Treasury issued General License X to implement this commitment. It allows Iran to produce, ship, and sell its oil for 60 days and allows direct payments to the Government of Iran in U.S. dollars. This is a significant concession that creates a sustained reopening of Iran’s most important revenue stream.
- This general license will give Iran at least 60 days to sell the reserves that were shuttered through the U.S. blockade. Congress should ask the Administration whether it plans to rescind the general license after the 60-day window and how the Administration will ensure this sanctions relief does not flow to the IRGC or Iranian proxies like Hezbollah, the Houthi, and militias in Iraq.
- $300 billion fund
- The MOU commits the U.S. to developing a plan of $300 billion for Iran’s reconstruction and economic development. It also pledges to grant “all required licenses, waivers, and permissions needed for the relevant financial transactions.” Even if no U.S. taxpayer dollars reach Iran directly, the regime’s documented record of diverting economic resources to the Islamic Revolutionary Guard Corps and its terrorist proxies makes this both a fiscal and a national security question.
- Vice President Vance confirmed that Iran could access the fund, describing it as “funded by the Gulf Coast coalition [sic], so long as they honor their end of the obligation” and insisting that “not a single cent of American money goes to Iran.” But money is fungible.
- During Operation Epic Fury, the regime imposed its longest internet blackout on record—reportedly 88 days—at an estimated cost of tens of millions of dollars per day to its own economy. This regime, which has been willing to inflict damage on its own people and economy to silence dissent, has demonstrated clearly what it would do with the billions of dollars in sanctions relief that is set to soon come its way.
Q: Does the agreement end Iran’s support for terrorism? Does Hezbollah have a veto over the process?
- As written, the Lebanon element of the MOU effectively gives Iran’s terror proxy a veto: Hezbollah need only reject a ceasefire to hold the entire agreement hostage. Any deal that ignores the financial pipelines funding Hezbollah, the Houthis, and IRGC operations is, in practice, funding the next conflict.
- The Lebanon element of the MOU is a legally executed commitment built on an unresolved interpretive dispute between the two parties who didn’t sign it. Iran and Hezbollah are already threatening the agreement as a path to Israeli withdrawal, while Israel asserts that it is not bound by the agreement—a gap that the United States will be left to fill.
- At the White House, the Vice President said, “No one could withdraw from another country their right to self-defense. Israel has the right to defend itself,” while then adding that Israel must “respect this peace process.”
- Congress should seek clarification on whether sanctions relief will be conditioned on verifiable Iranian restraint of Hezbollah, and an assurance that no economic benefits flow to Tehran while its primary Lebanese proxy remains armed and ready to resume hostilities.
Q: Does the agreement permanently and verifiably strip Iran of its remaining nuclear capabilities?
- Strikes by the United States and Israel set back Iran’s enrichment timeline, but they did not eliminate Iran’s nuclear knowledge, its surviving enriched material, its intact deep-facility infrastructure at Fordow, or its capacity to reconstitute. A pledge on paper is not dismantlement.
- The Vice President asserted that Iran’s nuclear program has “been completely destroyed,” yet the MOU does not require Iran to open its damaged sites to IAEA inspection, disclose the location of its enriched stockpile, or accept any verification before sanctions relief begins to flow. As FDD’s Andrea Stricker warns, “Without verifiably dismantling and destroying all of Iran’s fundamental nuclear capabilities — nuclear material, facilities, centrifuges, manufacturing capabilities, equipment, documentation, and weaponization capacities, and ensuring scientists are redirected to civilian work — Iran’s pledge on paper is meaningless.”
- Congress must insist that no statutory sanctions are waived and no economic benefits are extended until there is a credible verification regime in place and a plan to address Iran’s nuclear material.
Q: Does the agreement impose any restrictions on Iran’s ballistic missile program?
- Iran’s ballistic missiles are the primary delivery system for any future nuclear weapon and have already demonstrated the range to reach Israel and U.S. bases across the Middle East.
- An agreement that constrains enrichment while leaving missiles untouched removes one threat but preserves another. The MOU does not contain provisions addressing Iran’s ballistic missile program.
- In late 2024 and early 2025, Iran accelerated missile production to volumes that strained the defenses of Israel and its neighbors. U.S. strikes damaged but did not eliminate that capability or the production infrastructure behind it.
- Congress should require the administration to certify that no sanctions relief will flow to Tehran until Iran agrees to verifiable restrictions on its ballistic missile development, testing, and transfer of missiles to its regional proxies.
Q: Will the Trump Administration commit to providing maximum support for the Iranian people, who have courageously stood against the Islamic Republic’s brutal repression?
- The MOU contains no provisions supporting the Iranian people, no accountability for the regime’s violent suppression of its own citizens, and no conditions requiring political reform as a prerequisite for sanctions relief or economic benefit.
- Iranian security forces have killed thousands of protesters demanding basic freedoms. Economic relief without conditions risks strengthening the very sources used to suppress dissent.
- Congress should ensure any final agreement includes provisions barring sanctions relief from those implicated in human rights abuses and require the administration to report on how economic benefits will be prevented from reaching those responsible for murdering Iranian citizens.
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