United Against Nuclear Iran (UANI) Issues Advisory to Oil Purchasing Countries to Ensure Strict Domestic Ringfencing of Money Used in Purchase of Iranian Oil

(New York, NY; Washington, D.C.)—United Against Nuclear Iran (UANI) today issued an advisory note to the governing authorities, finance ministries, and central banks of any and all countries that may seek to utilize the recent U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) waiver permitting the continued delivery of otherwise sanctioned Iranian oil currently at sea through April 19. Those countries are likely to include India, Japan, and South Korea.

In 2018, following the U.S. withdrawal from the Joint Comprehensive Plan of Action (JCPOA), six month waivers – known as Significant Reduction Exceptions (SREs) – were granted to a limited number of importing countries: China, India, Japan, South Korea, Turkey, Italy, Greece, and Taiwan. 

Under the SRE arrangement, those waivers did not permit unrestricted financial transfers to the Iranian regime. A strict ringfencing framework was operative. Payments were deposited into locally held, domestically denominated, restricted accounts within the purchasing countries’ financial systems. These funds remained under the jurisdiction and control of the host country and were not freely transferable to Iran. Access by Iran was both “complex and convoluted” and very limited—typically to humanitarian trade.

Secretary of the Treasury Scott Bessent has confirmed that the United States aims to ensure Iran will have similarly restricted access to oil-related revenues in this instance. President Trump echoed Secretary Bessent’s comment this morning, noting that “it is very hard for [Iran] to get [that money]”. Accordingly, UANI calls on all governments and central banking authorities to adhere to the same principles.

Failure to do so risks enabling Iran’s access to hard currency, the use of opaque offshore financial channels, and the expansion of sanctions evasion networks through front companies and deceptive practices. It also undermines financial controls through commingling of funds and misuse of humanitarian exceptions. FFIs may be exposed to significant enforcement risk – including potential loss of access to the U.S. financial system – and serious reputational harm.

Jeb Bush, Chairman of UANI, said:
“The international community has successfully implemented these safeguards before. They must do so again here. Responsible governments must ensure that limited transactional flexibility does not translate into financial relief for the Iranian regime.”

UANI CEO Ambassador Mark D. Wallace said:
“Governments and financial institutions should be under no illusion. This waiver is narrow, temporary, and rooted in precedent that strictly denied Iran access to usable funds. Any effort to bypass or dilute established ringfencing mechanisms risks enabling sanctions evasion and will invite serious consequences.”

Joining UANI in this call is former senior counselor for the White House National Energy Dominance Council and Foundation for the Defense of Democracies Senior Advisor Richard Goldberg, who added:

“At this moment, in this context, Iranian barrels of oil at sea can be our friend in making more supply available to the market, but the revenue generated through the sale of those barrels remains a potential threat in the wrong hands. Treasury knows how to handle this responsibly, and so do most former customers of Iranian crude. Release the oil, trap the revenue, and you’ll have pulled off Sec. Bessent’s full jujitsu.”

Vigilance in the design and operation of payment mechanisms will be essential to ensuring that limited transactional allowances do not translate into meaningful financial access for Iran.