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19 Jun 2026, 13:47

The former official related to Iran sanctions on the "300 billion dollar fund": Its prerequisite is the lifting of all sanctions, which does not have an on/off switch.

Miad Maleki, the former director of the "Office of Sanctions Targeting at the U.S. Treasury," writes in a note about the "300 billion dollar fund" for Iran, which many experts have expressed doubts about: Setting aside the issue of oil exemptions/permits and concerns regarding the lack of new sanctions, considering the requirements for the actual implementation of Clause 6 (the 300 billion dollar reconstruction fund) and Clause 7 (lifting all sanctions), we conclude that the American negotiators either knew that a final agreement was impossible, or this memorandum of understanding merely postpones decision-making to the future.

Maleki, who himself played a role in designing sanctions against the Iranian government, writes in this note: This is what "full implementation" practically requires, beyond nuclear concessions:
Clause 6 — The 300 billion dollar fund:
Issuance of a presidential exemption from mandatory sanctions on Iran's construction sector under Section 1245 of the IFCA (180-day renewable exemptions that require notification to Congress each period).
Removing the IRGC from the list of Foreign Terrorist Organizations (FTO), as otherwise, investors would face the risk of criminal liability due to "material support," and no permit would resolve this issue.
Utilizing a national interest-based exemption under the ISA (Iran Sanctions Act) for investment in the energy and oil sector.
As a result, no investment entity is willing to commit billions of dollars based on renewable six-month exemptions.

Clause 7 — Lifting all sanctions:
Section 104 of the CISADA (Comprehensive Iran Sanctions, Accountability, and Divestment Act) does not grant the President exemption authority; sanctions are mandatory, and their lifting requires the passage of new legislation in Congress.
Section 1245 of the NDAA (National Defense Authorization Act) provides for 120-day renewable exemptions that require mandatory reporting to Congress each period.
Designating Iran's financial sector as a "money laundering concern" under Section 311 of the Patriot Act: This requires separate regulation by the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) and cannot be resolved solely through the Office of Foreign Assets Control (OFAC).
Sanctions related to terrorism, human rights, and overlaps with the Russia case: Each requires independent and separate legal actions.
Maleki continues: "Lifting all sanctions" is not an on/off switch, but a multi-year project in the realm of legislation and regulation, and Congress also has a vote in this matter. The question arises as to how to compel the European Union to lift the restrictions related to Iran that were imposed in the context of the Russia cases.
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