UANI Statement on Temporary Sanctions Waiver on Iranian Oil Exports

(New York, NY)—Today’s OFAC announcement provides for a one-month waiver permitting the continued delivery of otherwise sanctioned Iranian oil, which is stranded at sea. Observant Iran-watchers will recall that following the U.S. withdrawal from the flawed JCPOA in 2018, similar waivers known as Significant Reduction Exceptions (SREs) were granted on a temporary basis to a limited number of importing countries: China, India, Japan, South Korea, Turkey, Italy, Greece, and Taiwan. Significantly, those waivers did not extend to unrestricted financial transfers to the Iranian regime.

Rather, strict ringfencing was imposed. Payments for Iranian oil were required to be deposited into local, domestically denominated, and restricted accounts within the purchasing countries’ own banking systems. These funds remained under the jurisdiction 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.

Substantial balances accumulated over time in these accounts but were cut off from the regime. It was designed to allow limited oil flows while denying Iran access to hard currency.

Today’s waiver should be understood as operating within the same framework. Payments arising from any renewed oil transactions should again be channelled into local, purchasing-state bank accounts, denominated in local currency and subject to the same strict principles.

The only notable exception to the foregoing remains the issuance of a general license applicable to U.S. persons.