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

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

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

June 17, 2026 (IF13247)

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.

State of U.S.-Iran Negotiations

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. nonproliferation goals and associated risk to the United States.

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.

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."

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 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 non-military 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 frozen pursuant to any sanctions program under any jurisdiction globally."