The June 17 memorandum of understanding between Trump and Iranian President Masoud Pezeshkian commits the U.S. to removing all sanctions on “an agreed upon schedule,” directing Treasury to issue 60-day waivers on existing sanctions while technical negotiations continue. The waivers are real. The compliance clarity isn’t.
Adam Smith, former senior adviser to OFAC’s director, put the bank calculus plainly: “You want to be 100% sure that you’re within compliance.” One-off transactions closing inside the 60-day window could technically work, he said, but finding banks and intermediaries willing to process them is a separate problem entirely.
Michael Huneke at Morgan, Lewis & Bockius adds that financial institutions tend to run more risk-averse than their clients when sanctions programs unwind. Caution is the default posture, he said. That’s doubly true without a final deal behind the 60-day authorization.
That caution has a price tag in living memory. BNP Paribas paid a nearly $1 billion settlement to U.S. authorities in 2014 for processing Iranian and Sudanese transactions in apparent violation of the Iranian Transactions and Sanctions Regulations. A compliance committee pricing deals today has to price 2028 enforcement risk, not just August 16.
The structural signal is this: OFAC’s general license creates a technical window, not a political guarantee. The next administration retains authority to contest what this one permitted. Banks calibrating to BNP’s experience read that history correctly.
The clock runs to August 16. Worth auditing your OFAC escalation protocols and correspondent-bank procedures before then: “we will endeavor to review” won’t satisfy an examiner if the final deal collapses.
Rebecca Lauren