Sanctions Impact: U.S. and Iran enter into MOU, expressing their intentions to end military operations and immediately address sanctions issues

According to public reporting, the U.S. has released further details of a joint agreement reached between the U.S. and Iran, titled the Islamabad Memorandum of Understanding between the United States of America and the Islamic Republic of Iran (“MOU”).

The MOU, which was announced by the U.S. government on June 17, 2026, articulates a framework to end military operations between the U.S. and Iran. The MOU stands to significantly alter U.S. sanctions on Iran and could have significant implications for businesses around the world.   

As announced, paragraph 7 of the MOU envisions the termination of “all types of” sanctions by the U.S. against Iran as part of a final deal, with the parties acknowledging “the critical importance of the sanctions termination issue.”  These sanctions include all unilateral U.S. sanctions, both primary and secondary, as well as United Nations Security Council resolutions and International Atomic Energy Association Board of Governors resolutions.    

In addition:  

• Pending the final deal, Iran agrees to maintain the current status quo of its nuclear program, and the U.S. will neither impose any new sanctions, nor deploy additional forces in the region (Paragraph 9);
• Pending the final termination of sanctions, the U.S. Department of Treasury will begin issuing waivers for the export of Iranian crude oil, petroleum products and derivatives, and all associated services, including banking transactions, insurance and transportation (Paragraph 10); and
• Upon implementation of the MOU, the U.S. will undertake to make fully available frozen or restricted funds and assets of Iran.  The U.S. and Iran will mutually agree upon procedures related to the release of the funds during negotiations, with the U.S. undertaking to issue all necessary licenses and authorizations (Paragraph 11).  

The interim export and services waivers, the lifting of restrictions on funds and assets, and all forthcoming actions, are likely to have a significant impact on various sectors, including those operating in the energy and maritime industries.  

The MOU, however, is only the starting point for a final deal between the two countries. The U.S. and Iran have committed to negotiating and achieving a final deal under the MOU within 60 days, which may be extended by mutual consent. Further, as of this writing, the signed MOU has not been formally published by the U.S. Government. We will continue to monitor developments and expect to publish additional insights into the impact of the MOU on U.S. sanctions in the coming days.