The memorandum and the implementation framework

The Islamabad Memorandum of Understanding between the United States and Iran, the interim fourteen paragraph framework reached in mid June 2026, commits the parties to negotiate a final deal within a maximum of 60 days, extendable by mutual consent, with that final deal to be endorsed by a binding United Nations Security Council resolution. No date has been fixed for either the final deal or the resolution. Following the signing, the mediating states, Qatar and Pakistan, announced an implementation architecture comprising a High Level Committee to provide political oversight, working groups addressing the nuclear file, sanctions, and monitoring and dispute resolution, a communication line between the parties for the safe passage of commercial vessels under paragraph 5, and a deconfliction cell for the Lebanon track. Technical talks were continuing at Bürgenstock in Switzerland, and United States officials reported that Iran had agreed to readmit International Atomic Energy Agency inspectors. The United States Secretary of State was reported to be travelling to the United Arab Emirates, Kuwait and Bahrain between 23 and 25 June to address the memorandum and Strait transit.

Oil and sanctions

On 22 June 2026 the United States Office of Foreign Assets Control issued Iran General License X, authorising transactions ordinarily incident and necessary to the production, sale, delivery and offloading of crude oil, petrochemical products and petroleum products of Iranian origin, including transactions involving blocked vessels, through 21 August 2026, with payment permitted in United States dollars. The licence gives effect to paragraph 10 of the memorandum, under which the United States Treasury undertook to issue waivers for the export of Iranian crude oil, petroleum products and derivatives and all associated services, including banking, insurance and transportation, and the Treasury described it as a temporary 60 day authorisation. General License X is a measure of United States law and does not amend the European Union or United Kingdom Iranian sanctions measures, which remain in force, a point external counsel has underlined in relation to parties without a US nexus seeking to rely on it. The memorandum separately records an undertaking to terminate all sanctions, including United Nations measures and unilateral United States primary and secondary measures, on a schedule to be agreed as part of the final deal.

Status of the Strait of Hormuz

The operational position remains contested. Iran maintains that transit requires approval from its Persian Gulf Strait Authority, an entity designated by OFAC, and has linked full implementation of the memorandum to the Lebanon track, where Israel has stated it will remain in a security zone in southern Lebanon. On 20 June Iran declared the Strait closed, citing Israeli strikes in Lebanon, and transit volumes fell sharply over the following day before resuming. United States Central Command disputed that the Strait was closed and reported continuing flows, including some seventeen million barrels passing on 20 June.

Figures show transit running at roughly ten per cent of prewar levels, against a prewar daily average on the order of 138 transits of all types. The vessels still moving are predominantly Iranian tonnage and vessels assessed as aligned with Iranian interests, including dark fleet vessels, a significant proportion operating with their automatic identification systems switched off, a profile one maritime intelligence firm characterised as resembling the late blockade pattern rather than a functioning open strait. Daily counts have been volatile, with an information centre recording 28 transits on 20 June, the highest since the conflict began, before numbers fell back sharply over the weekend during the renewed closure dispute.

As at the morning of 23 June, commercial intelligence reporting recorded no new maritime incidents in the preceding 24 hours while maintaining existing risk ratings pending confirmation of full implementation, and assessed that prewar freedom of navigation is not expected to return during this period. The IMO Traffic Separation Scheme remains affected by a confirmed mine threat, with clearance operations reported to be under way.

Resumption of oil flows

Iranian oil exports have resumed rapidly. Maritime intelligence reporting records on the order of twenty six tankers carrying Iranian crude and petrochemicals, estimated at around thirty three million barrels, departing the Gulf of Oman since 14 June, a number of loadings since 17 June including from Kharg Island, and Iranian flagged vessels resuming routine movements and broadcasting their automatic identification systems, with China expected to remain the principal destination. These figures are third party estimates.

Transit fees and timing

Under the memorandum, passage is without charge for the 60 day period, after which the future administration of the Strait and any maritime service or insurance fees are to be determined in discussions between Iran, Oman and other littoral states. United States officials have described the Strait as toll free and have indicated that payments to Iranian authorities may carry sanctions risk, the Persian Gulf Strait Authority being designated by OFAC. Both the memorandum’s period of free passage, running 60 days from mid June, and the authorisation under General License X, expiring on 21 August 2026, fall due in the second half of August 2026.

War risk market

The Persian Gulf, the Strait of Hormuz and the Gulf of Oman remain designated areas for war risk purposes, and cover for transits remains elevated relative to levels seen before the war.

The Club’s position

For the Club’s purposes this position is unchanged for the present. The memorandum and General License X are recent and time limited, full implementation has not been confirmed, and neither alters the European Union and United Kingdom restrictions against which the Club assesses its own exposure as a service provider. The Club’s approach therefore remains as before pending confirmation that the reopening, the demining and the safe passage arrangements are operative and durable.

Sources

Islamabad Memorandum of Understanding between the Islamic Republic of Iran and the United States of America, full text, provided this session. OFAC Iran General License X, Office of Foreign Assets Control, 22 June 2026, ofac.treasury.gov, verified this session. Joint statement of the mediating states, Qatar and Pakistan, 22 June 2026. United States Treasury and administration statements, 22 June 2026. Ambrey, Regional Risk Assessment, Arabian/Persian Gulf, Gulf of Oman and North Arabian Sea, 23 June 2026, and the preceding edition of 22 June 2026. Ocean Security Dialogues, Middle East situation report on merchant shipping, 18 June 2026. United Against Nuclear Iran, situation report and statement compilation, 22 June 2026. Reuters, Bloomberg, CNBC, Al Jazeera and Lloyd’s List reporting on Strait of Hormuz transit volumes, 20 to 23 June 2026, including Kpler, Windward and JMIC data. Joint War Committee listed areas, Lloyd’s Market Association.

---

Prepared by Lucie Ryan, Senior Sanctions Specialist, Anti-Financial Crime, The Swedish Club.