Possible U.S.-Iran Agreement: INARA and U.S. Sanctions

June 17, 2026

Possible U.S.-Iran Agreement: INARA and U.S. Sanctions

In June 2026, after months of diplomatic engagement,

President Trump announced that a “Deal with the Islamic

Republic of Iran is now complete.” No mutually agreed

upon text of an agreement has been publicly released as of

June 17, 2026, and U.S. and Iranian accounts of its contents

have differed. Media reports indicate that, as part of the

agreement, the two countries are to enter a 60-day period of

negotiations related to Iran’s nuclear program and U.S.

sanctions on Iran. Pursuant to the Iran Nuclear Agreement

Review Act (INARA, P.L. 114-17), Congress has authority

related to oversight of any potential agreements related to

Iran’s nuclear program.

nonproliferation goals and associated risk to the United

States.

State of U.S.-Iran Negotiations

During the initial review period, the President “may not

waive, suspend, reduce, provide relief from, or otherwise

limit the application of statutory sanctions with respect to

Iran under any provision of law or refrain from applying

any such sanctions pursuant to [the] agreement.”

Under the second Trump Administration, the United States

and Iran (which do not maintain diplomatic relations) twice

engaged in talks related to the future of Iran’s nuclear

program. In both cases, those talks were interrupted by U.S.

and/or Israeli military action against Iran (in June 2025 and

February 2026).

After the declaration of an April 2026 ceasefire, the two

sides again engaged diplomatically. Negotiations proceeded

amid continued conflict between Israel and Hezbollah in

Lebanon; Iran’s attempts to bring about the de facto closure

of the Strait of Hormuz; a retaliatory U.S. blockade of

Iranian shipping; and periodic missile and air strikes

involving Iran, Israel, and the United States. Without

disclosing additional details, both Iranian and U.S. leaders

have stated that an initial agreement will be formally signed

on June 19, with further talks to follow.

Iran Nuclear Agreement Review Act

Congress’s 2015 passage of INARA mandates

congressional oversight of agreements related to Iran’s

nuclear program. Although INARA was drafted to give

Congress a role in oversight of the 2015 Joint

Comprehensive Plan of Action (JCPOA), it does not have a

sunset date and did not expire when the first Trump

Administration ceased U.S. participation in the JCPOA.

INARA requires the President to submit to Congress the

text of any “agreement related to the nuclear program of

Iran” involving the United States regardless of “the form it

takes” or whether such agreement is legally binding.

Process

According to INARA, within five days of reaching an

agreement with Iran related to its nuclear program, the

President must submit the text of the agreement together

with all related materials and annexes, a verification

assessment report by the Secretary of State, and a

presidential certification regarding the appropriateness of

terms and measures to be taken in light of the U.S.

In addition to requiring these transmittal documents,

INARA provides a 30-day congressional review period

during which Congress can pass a joint resolution of

disapproval stating it “does not favor the agreement.”

Alternatively, if Congress takes no action on the agreement,

the President may, after the review period has expired,

waive sanctions to the extent permitted by law. Congress

can also cut the review period short by passing a joint

resolution to express approval of the agreement.

INARA does not provide any special procedural

mechanisms for consideration of a joint resolution

disapproving or approving the agreement. Such a resolution

would be subject to regular procedures in each chamber and

a potential presidential veto. If enacted, a resolution of

disapproval would not invalidate the agreement itself, but it

would preclude the President from providing sanctions

relief pursuant to the agreement as permitted by law.

Options for Congress Under INARA

INARA affects only an “action involving any measure of

statutory sanctions relief by the United States” that includes

“waiver, suspension, reduction, or other effort to provide

relief from, or otherwise limit the application of statutory

sanctions with respect to, Iran under any provision of law or

any other effort to refrain from applying any such sanctions.”

INARA provides three options for Congress:

•

Disapprove: If enacted, the President may not take

sanctions action.

•

Approve: If enacted, the President may take sanctions

action.

•

No Action: The President may take sanctions action.

In any event, INARA does not permit the President to

terminate or revoke sanctions except as provided by statute.

Agreement Related to Iran’s Nuclear Program

INARA requires submission to Congress of any agreement

that is “related to the nuclear program of Iran,” “includes

the United States,” and “commits the United States to take

action” or to agree to take action. Any agreement with Iran

to end the conflict between it and the United States would

necessarily include the United States as a party and would

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Possible U.S.-Iran Agreement: INARA and U.S. Sanctions

likely commit the United States to take or refrain from

some action. Depending on the terms of any agreement, it

may not be clear whether it “relat[es] to the nuclear

program of Iran,” a phrase INARA does not define.

The review process outlined in the section above is

triggered by the submission to Congress of:

[the] agreement … regardless of the form it takes,

whether a political commitment or otherwise, and

regardless of whether it is legally binding or not …

and any additional materials related thereto,

including annexes, appendices, codicils, side

agreements, implementing materials, documents,

and guidance, technical or other understandings,

and any related agreements, whether entered into or

implemented prior to the agreement or to be entered

into or implemented in the future.

“Nuclear Program of Iran”

INARA’s definition of agreement does not include an

Iranian commitment to take or refrain from any action.

INARA’s certification and verification assessment

requirements, however, suggest that Congress expects any

such agreement to have verifiable Iranian commitments that

it will refrain from activities “to further any nuclear-related

military or nuclear explosive purpose, including for any

research on or development of any nuclear explosive device

or any other nuclear-related military purpose.” The

verification assessment report must also evaluate factors

such as “the capacity and capability of the International

Atomic Energy Agency to effectively implement the

verification regime required by or related to the

agreement.” It may be reasonable to conclude that the

“nuclear program of Iran” is intended to refer to a program

with potential for advancing Iran’s nuclear-related military

purpose or weapons development.

An agreement with Iran that does not address the

development of Iran’s nuclear weapons production capacity

in any way, even if it touches on some aspect of nonmilitary nuclear facilities, arguably might not require

transmission to Congress and would not trigger the 30-day

congressional review period described above.

“Agreement Relating To”

INARA does not specify benchmarks for determining

whether an agreement relates sufficiently to Iran’s nuclear

program to require submission for review. An agreement

that mentions nonproliferation safeguards regarding Iran’s

nuclear program but does not contain any obligations that

can be verified or assessed could plausibly be regarded as

insufficiently related to the program to meet the definition.

For example, if an agreement contains a promise by Iran to

negotiate an agreement in the future to limit its ability to

enrich uranium—at most what could be called an

“agreement to agree”—it may be possible to argue the

agreement need not be submitted for review. On the other

hand, Congress may have intended such an agreement be

submitted to exercise its prerogative to review the

advisability of providing sanctions relief in such a case.

Non-submission of Agreement Under

INARA

Should the Trump Administration determine that INARA

does not require the submission of an agreement it has

reached with Iran to Congress, the status quo prevails.

Absent enactment of legislation providing otherwise, the

Administration would be permitted to waive sanctions

against Iran to the extent provided by statute without

awaiting the end of any congressional review period. Once

such agreement takes effect, the Administration would not

be obligated to submit periodic reports on compliance or a

report of a major breach under INARA as written.

INARA’s “snap-back” provision, under which Congress

could prohibit the United States from taking any action to

facilitate the release of funds under the agreement, would

also be unavailable.

U.S. Sanctions and Iranian Assets

The U.S. government has for decades sought to limit the

Iranian government’s financial resources in an effort to

deprive the government of the ability to fund its nuclear

program and other objectionable activities. These efforts

have included sanctions directly on Iranian government

assets and Iranian entities, as well as secondary sanctions to

deter third parties from engaging in transactions with or for

the benefit of the government of Iran.

INARA provides a mechanism for Congress to block

sanctions relief as part of a covered agreement, including

U.S. government actions “to facilitate the release of funds

or assets to Iran pursuant to such an agreement.” The

question of Iran’s access to funds abroad has received

particular attention since 2011, when Congress first passed

legislation to sanction foreign financial institutions that

engage in transactions with designated Iranian financial

institutions (with an exception for the financial institutions

of countries determined to be significantly reducing their

imports of Iranian petroleum).

This exception permitted Iran to sell some petroleum

products abroad. Congress required excepted foreign buyers

to deposit payments for petroleum imports in financial

institutions located in the purchasing country, rather than

remitting such funds to Iran, to avoid sanctions. Iran’s

access to the funds is restricted by foreign financial

institutions seeking to comply with the U.S. Iran sanctions

program and avoid U.S. secondary sanctions. The President

may waive those sanctions for a renewable 120-day period

upon submitting a report and certification to Congress.

There is media reporting on the potential amounts and

locations of Iranian funds abroad (including the $6 billion

in Iranian oil proceeds transferred from South Korea to

Qatar in 2023), but there does not appear to be a

comprehensive, authoritative public list of such funds. The

House, in the 118th Congress, passed a measure (H.R. 5826)

that would have required annual reports with an “itemized

list of any identifiable assets … belonging to Iranian

individuals and entities that are or have been blocked or

otherwise frozen pursuant to any sanctions program.” In

April 2025, the House Foreign Affairs Committee ordered

to be reported H.R. 2619, which would require annual

reports on certain Iranian assets “blocked or otherwise

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Possible U.S.-Iran Agreement: INARA and U.S. Sanctions

frozen pursuant to any sanctions program under any

jurisdiction globally.”

Jennifer K. Elsea, Legislative Attorney

IF13247

Clayton Thomas, Specialist in Middle Eastern Affairs

Disclaimer

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