$300 Billion Iran Fund Faces Sanctions Hurdles Under Trump-Iran Framework

by Emmitt Barry, Worthy News Washington D.C. Bureau Chief

(Worthy News) – A proposed $300 billion investment fund for Iran included in the U.S.–Iran memorandum of understanding may face serious legal obstacles under existing U.S. sanctions law, raising questions about whether one of the agreement’s central economic promises can realistically be carried out.

The memorandum, digitally signed last Wednesday by President Donald Trump and Iranian President Masoud Pezeshkian, is aimed at ending the war and restoring traffic through the Strait of Hormuz. The 14-point framework includes sanctions relief, expanded Iranian oil revenue, and renewed access to parts of the international banking system.

But the proposed investment fund for Iran’s reconstruction and development may collide with a longstanding U.S. determination that Iran’s construction sector is controlled directly or indirectly by the Islamic Revolutionary Guard Corps.

The State Department made that determination in 2020 and reaffirmed it in May 2025. Under the Iran Freedom and Counter-Proliferation Act, companies or individuals doing business in Iran’s construction sector could face sanctions risk.

Miad Maleki, a senior fellow at the Foundation for Defense of Democracies and former Treasury Office of Foreign Assets Control executive, told Fox News Digital that Congress would likely be unavoidable for any durable investment structure.

“Technically, the fund could be switched on through some kind of an executive action plan alone, but it would be on paper and it would have to be renewed every 180 days,” Maleki said.

He warned that short-term waivers would be unlikely to reassure investors considering long-term construction or infrastructure projects in Iran.

“These projects are not like 180-day projects,” Maleki said.

The fund could also become a flashpoint in Congress, since IFCA waivers tied to IRGC-controlled sectors require regular justification. Critics say the structure may allow Tehran to receive economic relief while leaving unresolved questions over its nuclear program, missile arsenal, and regional proxy network.

A separate dispute is already emerging over frozen Iranian assets. Iran says it expects access to $6 billion held in Qatar, while broader estimates of frozen Iranian assets range from roughly $100 billion to $120 billion. U.S. officials have indicated any release would be conditional and monitored, with an initial tranche reportedly focused on humanitarian purchases such as food and medicine.

Alex Vatanka, a senior fellow at the Middle East Institute, told Fox News Digital that the dispute is about more than money.

“Releasing frozen assets is not simply an economic question,” Vatanka said. “It is one of the central political tests of trust between Tehran and Washington.”

John Hannah, a senior fellow at the Jewish Institute for National Security of America and a former national security adviser to Vice President Dick Cheney, warned that any major economic windfall could help the IRGC rebuild.

“It’s almost certain that the IRGC will use any economic windfall granted by this MOU to reconstitute as much of their conventional military as possible as fast as possible,” Hannah told Fox News Digital.

Maleki said the United States had gained rare leverage over Iran through sanctions, military pressure, and the blockade of Hormuz, but may now be giving much of it away.

“We reached a point that we had leverage that no U.S. president has ever had with Iran,” he said. “Yet we gave that away for this, for the opening of the Strait of Hormuz.”

He added that Iran is likely to delay rather than rush toward a final deal.

“Iran is going to go back to its playbook of dragging, buying time with the sanctions relief-type incentives that I’m seeing in this package,” Maleki said.

For the Trump administration, the memorandum may offer a path to reopen the Strait of Hormuz and reduce immediate military pressure. But the $300 billion fund raises a deeper question: whether Washington can offer Iran massive reconstruction relief without empowering the IRGC and Tehran’s regional ambitions.

Copyright 1999-2026 Worthy News. This article was originally published on Worthy News and was reproduced with permission.


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