Reinstitute and expand Trump-era sanctions on Iran

Research notes

• NSPM-2 is not in the Federal Register (national security memoranda are not published there); the whitehouse.gov page is the Primary source.
• Treasury/OFAC designation rounds under NSPM-2 (from February 2025) and State’s October 2025 “Supporting Snapback of UN Sanctions on Iran with Additional Sanctions and Export Controls” (https://www.state.gov/releases/office-of-the-spokesperson/2025/10/supporting-snapback-of-un-sanctions-on-iran-with-additional-sanctions-and-export-controls/) and the August 2026 “Operation Economic Outcast” fact sheet surfaced in search and were not opened — leads that would add designations to the record, not change the Status.
• The national-emergency continuations (2025-03-07, 2025-11-05, 2026-03-02) are routine and not cited.
• The Mandate’s second clause (security assistance for regional partners) is not tracked here.
• Checked for a reversal 2026-09-10; closed in review 2026-09-11. OFAC’s final rule Iranian Transactions and Sanctions Regulations (FR 2026-18461, 91 FR 57511, 2026-09-10; stay of effectiveness from 2026-09-08) is “indefinitely suspending three general licenses and one licensing policy … to align with changes in the foreign policy of the United States towards Iran”. We read the full text on federalregister.gov. All four suspended authorities authorized something: 31 CFR 560.522 (payments for overflights of Iranian airspace), 560.528 (the licensing policy: the issuance of specific licenses for transactions related to aircraft safety), 560.529 (bunkering and emergency repairs) and Iran General License J-1 (reexport of civil aircraft to Iran on temporary sojourn). The rule gives its reasons as Iran’s “reconstitution of its conventional and nuclear weapons programs, efforts to monetize the Strait of Hormuz, and continued support to terrorist proxies”. Every suspension narrows what is permitted, so the rule is one more instrument in the ask’s direction and not a reversal. Like the designation rounds above it is not cited, and the Status holds at done. Our search of new Federal Register documents had not linked this rule to this item.
• Checked 2026-09-11, closed in review the same day: Iran general licenses CC and DD. OFAC, Publication of Iran-Related Web General Licenses CC and DD, FR 2026-18576, 91 FR 57795, published 2026-09-11. At first we had only our stored copy of the document’s record, and the question was whether either license relieves a sanction. We read the text on federalregister.gov, and both are wind-down licenses that follow a tightening. GL CC (EO 13902, issued 2026-09-04) authorizes, through 2026-09-19, only the transactions “ordinarily incident and necessary to the wind down” of dealings with three Golden Global entities blocked that day, with payments into blocked accounts. The designations themselves run in the ask’s direction. GL DD (31 CFR part 560, issued 2026-09-08) does the same, through 2026-09-23, for transactions previously authorized under 560.522, 560.529 and GL J-1, the licenses suspended by the 2026-09-08 stay recorded above. Neither relieves a first-term or maximum-pressure sanction. Like the designation rounds, neither is cited, and the Status holds at done. Our search of new Federal Register documents had not linked them to this item.

Public Law 119-111 (checked and closed in review 2026-09-24): it extends the Iran Sanctions Act, and that is its only Iran provision. At first we knew the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (H.R. 5334, signed 2026-09-18) only by its title, and left the question open. The Public Law page was not yet posted at govinfo on 2026-09-24 (its address, PLAW-119publ111, redirects to govinfo’s not-found page). We read the enrolled bill (https://www.govinfo.gov/content/pkg/BILLS-119hr5334enr/html/BILLS-119hr5334enr.htm), and govinfo’s bill-status record confirms it “Became Public Law No: 119-111” on 2026-09-18, after the House agreed to the Senate amendments 262–159 on 2026-09-16 (Roll no. 308). The open questions have these answers:

• What it does to Iran. Division A has two titles. Title I (secs. 101–117) is Russia only: sanctions on persons, financial institutions and state-owned entities, bans on investment, energy and sovereign debt, a uranium import ban, higher duties on Russian goods, and secondary duties on countries that buy Russian oil or gas. Sec. 201 is the only Iran provision. It amends sec. 13(b) of the Iran Sanctions Act of 1996 by striking “2026” and inserting “2031”, so the ISA’s sunset moves from 2026-12-31 to 2031-12-31. It imposes no new Iran sanction and codifies nothing this item’s events record (not NSPM-2, not the snapback, not EO 14382).
• Constraints on relief. Title I’s waiver (sec. 115) and termination-with-congressional-review (sec. 117) provisions apply only to “this title”, which is Russia. Nothing in the Act limits the President’s power to relieve Iran sanctions.
• Sunset. Sec. 203 ends Division A after five years “other than section 201”, so the ISA extension is not caught by the Act’s own sunset. The date to watch for a later downward move is now the ISA’s own 2031 expiry, not 2026.
• The vehicle. Division B is unrelated. It widens the educator expense deduction in 26 U.S.C. 62(d)(1) to early childhood educators. That runs against Chapter 22’s #1936 (Repeal deductions for educational expenses), which is not this chapter’s to record.

Assessment: no event, and the Status holds at done. Keeping a 1996 statute alive, which the first term used and which would otherwise have lapsed on 2026-12-31, is continuation. It is not reinstatement or expansion. So it is recorded here like the designation rounds and the OFAC licenses above. If the ISA had been allowed to lapse, that would have been a candidate for a downward move. Its extension removes that risk until 2031.

Iran general licenses Y and Z (checked and closed in review 2026-09-24). OFAC, Publication of Iran-Related Web General Licenses Y and Z, FR 2026-19424, 2026-09-23, read in full at govinfo. Both are wind-down licenses after designations, like CC and DD. GL Y (issued 2026-07-10, under the Global Terrorism Sanctions Regulations and EO 13876) authorized only the wind down of transactions with Smart Global Limited, through 2026-08-09. GL Z (issued 2026-07-14, under EO 13902) authorized wind down, safe docking, crew safety, emergency repairs and cargo offloading for persons and vessels blocked on 2026-07-14, through 2026-09-12. It excluded ports in Iran or Russia and all ITSR-prohibited transactions. Both licenses had expired before they were published. Neither relieves a sanction, so neither is cited, and the Status holds at done.