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

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URL: https://www.frixlaw.com/law-library/documents/crs%3AIF13247

## Record

- **Collection:** Congressional research report
- **Document type:** In Focus
- **Published:** June 17, 2026
- **Citation:** IF13247

## Text

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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https://crsreports.congress.gov | IF13247 · VERSION 1 · NEW

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/crs%3AIF13247. Public record. Not legal advice.
