Executive Order 12276 is titled "Direction Relating to Establishment of Escrow Accounts" and concerns the establishment of escrow accounts in connection with Iranian assets following the 1981 Algiers Accords resolving the Iran hostage crisis. It directed the establishment of escrow arrangements to manage Iranian assets and claims, with U.S. oversight over the process, but the funds themselves were held in designated escrow accounts at specified banks rather than a single generic U.S. Treasury escrow account.

The Iranian Transactions and Sanctions Regulations (ITSR) authorize U.S. depository institutions to process transfers of funds to or from Iran, or for the direct or indirect benefit of persons in Iran or the Government of Iran, if the transfer arises from an underlying transaction that has been authorized by a specific or general license and does not involve debiting or crediting an Iranian account. A "SPECIAL PURPOSE ACCOUNT" is an account set up with conditions and safeguards that require the account to be used only for bilateral trade in goods or services between Iran and the country with primary jurisdiction over the foreign financial institution, and for sales made under the Humanitarian Exception. Under the National Defense Authorization Act's significant reduction exception, funds withdrawn from the RECIPIENT ACCOUNT or SPECIAL PURPOSE ACCOUNT may only be used to pay for bilateral trade or purchases relating to the Humanitarian Exception, implying that such accounts are controlled through conditions but are typically at foreign, not U.S., banks.

On November 5, 2018, the United States fully re-imposed the sanctions on Iran that had been lifted or waived under the JCPOA. After November 5, 2018, OFAC expects that any sanctionable transactions related to Iran that were previously undertaken pursuant to the sanctions relief under the JCPOA will have been wound down. Earlier guidance on Significant Reduction Exceptions (SREs) required that payments to Iran for oil exports be kept in restricted accounts in the importing country and used only for trade in non-sanctioned goods, rather than being freely accessible to Iran.

Regarding post–JCPOA reimposed sanctions, the analysis explains that countries receiving Significant Reduction Exceptions (SREs) for importing Iranian oil "must still ensure that funds owed to Iran for the purchase of petroleum products be credited to an escrow-style account located in the country that was granted the exception and are not repatriated to Iran." It quotes then–Secretary of State Mike Pompeo on November 5, 2018: "100 percent of the revenue Iran receives from the sale of oil will be held in foreign accounts, and Iran can only use this money for humanitarian trade or bilateral non-sanctioned goods." These escrow-style accounts are in the jurisdiction of the importing country’s banks, not in a U.S.-domiciled, U.S.-bank escrow account, though they are structured under U.S. sanctions rules.

The Treasury Department on Monday issued a 60-day license allowing the production, delivery and sale of Iranian oil as part of the administration’s effort to coax Tehran back into nuclear talks. The new license, set to expire on Aug. 21, enhances Iran’s access to U.S. currency by permitting the nation to engage in oil transactions in U.S. dollars. A senior administration official said the proceeds would be monitored but acknowledged that the license does not require that the money be placed in a U.S.-controlled escrow account, instead relying on banking partners and existing sanctions rules to limit misuse.

Executive Order 13599, issued February 5, 2012, directs the blocking of U.S.-based assets of entities determined to be “owned or controlled by the Iranian government.” The order requires that any U.S.-based assets of the Central Bank of Iran, or of any Iranian government‑controlled entity, be blocked by U.S. banks. In discussing sanctions relief and Iranian assets, the CRS report notes that under a 2016 settlement related to the pre‑1979 arms purchase, “the United States sent Iran the $400 million balance in Trust Fund plus $1.3 billion in accrued interest, paid from the Department of the Treasury’s ‘Judgment Fund.’ In order not to violate U.S. regulations barring direct U.S. dollar transfers to Iranian banks, the funds were remitted to Iran in late January and early February 2016 in foreign hard currency from the central banks of the Netherlands and of Switzerland.” The report also describes blocked Iranian assets such as $1.9 billion in bonds belonging to Iran’s Central Bank frozen in a Citibank account, but does not state that current sanctions‑relief funds are placed in new U.S.-controlled escrow accounts; instead, it focuses on blocked assets and past settlements.

On June 22, 2026, OFAC published General License (GL) X authorizing, for a 60-day period, transactions ordinarily incident to the production, sale, delivery or offloading of Iranian crude oil, petrochemical products or petroleum products. GL X allows buyers to pay Iran directly in U.S. dollars for these authorized transactions. Critically, the analysis notes that "there is no requirement that buyers pay into a blocked or escrow account – an arrangement sometimes used to allow sanctioned countries to sell petroleum products while limiting their ability to access the resulting revenues." The brief emphasizes that GL X does not require the use of blocked or escrow accounts for the authorized oil sales revenues.

OFAC guidance on Iran-related sanctions relief under the JCPOA stresses that third-country financial institutions "may not route Iran-related transactions through U.S. financial institutions or in any other way involve U.S. persons in Iran-related transactions unless authorized by OFAC." It advises that third-country financial institutions should have controls to ensure they do not route Iran-related transactions through U.S. financial institutions. This indicates that, as a rule, permitted Iran funds for sanctions relief are handled via foreign banks and not typically deposited into U.S.-based accounts, even when the United States structures or supervises the relief through licensing.

Reporting on the new sanctions relief, CNBC notes that the U.S. Treasury issued a wide-ranging 60-day exemption, known as General License X, permitting Iran to produce and sell crude oil, petrochemicals, and petroleum products in U.S. dollars. The article states that "the new exemption permits Iran to receive oil revenues directly into its central bank, thus lowering transaction costs that were previously incurred by utilizing shadow banking intermediaries." The description of GL X does not mention a requirement that funds be deposited into a U.S.-controlled escrow account; instead, it indicates that Iran’s central bank can receive the revenues directly.

The OFAC Iran sanctions program overview notes that U.S. sanctions are administered through regulations and licensing, and that certain executive orders, including Executive Order 12276, involved escrow accounts for Iranian assets as part of the 1981 hostage crisis settlement. However, current sanctions relief structures under statutes like the NDAA rely on foreign "recipient" or "special purpose" accounts in the jurisdiction of oil importers, subject to U.S. conditions about how funds can be used, rather than generic escrow accounts at U.S. financial institutions.

Discussing Treasury’s June 22 issuance of General License (GL) X authorizing certain Iranian oil sales, the analysis criticizes that "GL X gives Iran the ability to fund its rearmament without any oversight by the United States." It states: "This is because the license contains no escrow mechanism; no restrictions on Iran’s use of the proceeds; no cap on the volume or value of authorized sales; no approved list of buyers or participating banks; and no transaction-specific reporting requirement that would provide Treasury or Congress with insight" into the flows. The critique is based on the absence of an escrow mechanism in this particular sanctions relief step, indicating that not all modern sanctions relief for Iran is structured through escrow accounts, let alone U.S.-controlled ones.

A Senate Banking Committee minority press release recounts that Senator Tim Scott’s "Revoke Iranian Funding Act" would "revoke Treasury’s sanctions licensing ability for Iranian accounts in Qatar" and permanently freeze $6 billion that had been released by the Biden administration to Iran. The release criticizes a sanctions waiver "potentially worth billions of dollars" that allegedly makes sanctioned Iranian funds more accessible, and calls on Treasury to block Iran’s access to funds and to account for high-value assets. The text refers to Iranian accounts in Qatar rather than U.S.-based escrow accounts, suggesting that at least some recent sanctions relief involved foreign-held accounts subject to U.S. licensing rather than U.S.-bank escrow accounts.

US President Donald Trump on Tuesday said that any Iranian funds released under sanctions relief would be placed in a US‑controlled escrow account and could only be used to buy food and medical supplies from the United States. “The Money and/or Sanctions that the US Treasury is releasing goes into escrow, controlled by the USA, and will be used for the purchase of food and medical supplies, exclusively from the United States, including Corn, Wheat, and Soybeans from our great American Farmers,” Trump posted on his Truth Social platform. The report explains that as part of ongoing talks, Iran is expected to receive some sanctions relief and gain access to frozen assets, and that the U.S. Treasury Department said it was temporarily easing sanctions to allow production, sale and delivery of Iranian crude oil through August 21; Trump’s statement describes his proposed handling of unfrozen funds via U.S.-controlled escrow accounts.

In a broader historical overview of U.S. sanctions on Iran, the entry notes that U.S. sanctions are administered by the Office of Foreign Assets Control (OFAC) of the Department of the Treasury and that over time, mechanisms such as escrow accounts in third countries have been used to hold proceeds from Iranian oil sales under sanctions. For example, after the 2012–2013 period, oil-importing countries were required by U.S. law to place payments into local escrow accounts that Iran could only tap for approved bilateral trade and humanitarian purposes, rather than freely receiving the funds or having them deposited into U.S. accounts.

President Donald Trump said on Tuesday that any Iranian funds unfrozen through sanctions relief or released by the US Treasury would go into a Washington-controlled escrow account, which Tehran could tap to purchase US food and medical supplies. “The Money and/or Sanctions that the US Treasury is releasing goes into escrow, controlled by the USA, and will be used for the purchase of food and medical supplies, exclusively from the United States, including Corn, Wheat, and Soybeans from our great American Farmers,” Trump posted on his Truth Social platform. The Treasury waiver grants Tehran access to around $10 billion in frozen funds, but the administration has not yet detailed the implementing mechanisms for the proposed escrow system.

Any Iranian funds released by the US Treasury will remain under strict American oversight and can only be used to purchase humanitarian goods from the United States, US President Donald Trump said. In a post on Truth Social on Tuesday, Trump said the funds would be placed in escrow accounts controlled by Washington and restricted to food and medical supplies. “The money and/or sanctions that the U.S. Treasury is releasing goes into escrow, controlled by the U.S.A., and will be used for the purchase of food and medical supplies, exclusively from the United States,” Trump wrote. TRT World reports that Trump’s comments followed a temporary 60‑day license allowing Iranian oil sales under a new nuclear framework; the article frames the escrow arrangement as part of his administration’s proposed sanctions‑relief structure but does not cite independent Treasury documentation of such escrow accounts.

President Donald Trump said on Tuesday that any Iranian funds unfrozen through sanctions relief or released by the US Treasury would go into a Washington-controlled escrow account, which Tehran could tap to purchase US food and medical supplies. “The Money and/or Sanctions that the US Treasury is releasing goes into escrow, controlled by the USA, and will be used for the purchase of food and medical supplies, exclusively from the United States,” Trump wrote on Truth Social. His comments refer to a sanctions waiver granting Tehran access to frozen funds, but he did not specify whether current Treasury licenses already mandate a U.S.-controlled escrow or if this is a proposed condition.

Furthermore, foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for such designated persons risk exposure to U.S. correspondent account or payable-through account sanctions. Earlier OFAC guidance on the Iranian financial and petroleum sectors required that funds owed to Iran for the purchase of petroleum products be credited to restricted accounts in the purchasing country and not repatriated to Iran. These mechanisms are structured accounts under foreign control, subject to U.S. sanctions, rather than escrow accounts directly controlled by the U.S. government.

A viral post summarizing remarks attributed to Donald Trump asserts that "unfrozen Iran funds will go into a US-controlled escrow account for humanitarian aid, exclusively for US food and medical supplies." The post claims that the waiver grants Tehran access to around $10 billion in frozen funds and that those funds will be placed in a U.S.-run escrow account, framing this as a safeguard to ensure the money is used only for humanitarian trade. The statement reflects a political characterization rather than an official Treasury legal description of the account’s jurisdiction or bank location.

Donald Trump said that any Iranian funds unfrozen through sanctions relief or released by the US Treasury would be placed in a US-controlled escrow account, which Iran could access only to purchase food and medicine from American suppliers. In his post, Trump emphasized that the money would not be given to Iran in cash but held under U.S. control to ensure its use for humanitarian purposes. The statement outlines a proposed escrow arrangement but does not itself constitute an official Treasury regulation or license text.

A short video commentary discusses "conflicting claims on Iranian funds and sanctions relief," highlighting that political figures have described Iranian funds as being placed in U.S.-controlled escrow accounts for humanitarian purposes, while critics and some policy experts argue that in practice many of these funds are held in foreign banks under local jurisdiction, albeit subject to U.S. licensing and conditions, and that some recent licenses lack escrow or oversight provisions.

President Donald Trump dismissed reports of a U.S.-backed $300 billion Iranian reconstruction fund as "fake news," asserting American taxpayers would not finance such a plan. He instead announced that unfrozen Iranian funds will be placed into a US‑controlled escrow account. The money will be restricted to humanitarian purposes, including food and medical supplies from US companies. The Instagram post summarises Trump’s statement about the escrow arrangement for unfrozen Iranian funds, emphasizing U.S. control and restriction to humanitarian trade, but does not provide independent verification from Treasury regulations or agreements.

Across various rounds of sanctions and relief, U.S. policy has often required that payments owed to Iran, particularly for oil, be deposited into restricted accounts or escrow-like mechanisms in third countries, from which Iran may draw only for specified humanitarian or bilateral trade purposes. These structures are frequently described in public debate as "U.S.-controlled" because the United States, through OFAC licensing and statutory conditions, determines what uses are allowed and threatens secondary sanctions against banks that deviate, even though the accounts themselves are at foreign banks and not physically inside the United States.

Given that there's zero evidence that Iranian funds from sanctions relief are going into escrow accounts controlled by the U.S., and that Trump is lying about it being used only for humanitarian aid, journalists need to press the Treasury Department for clarity. The post argues that existing public information does not support Trump’s assertion that sanctions‑relief funds are placed into U.S.-controlled escrow accounts, and calls for more documentation or confirmation from Treasury regarding how such funds are actually handled. This represents a skeptical viewpoint on the claim and highlights the lack of corroborating evidence in official releases at the time of the comment.