The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sets out the core rules governing financial transactions with Iran, including how funds owed to Iran can be handled under sanctions and sanctions relief. While this public overview does not spell out every escrow arrangement, it is the primary regulatory framework that licenses or restricts the use of escrow-style accounts and foreign-held funds under Iran sanctions programs.

In several public statements since 2019, U.S. officials have described arrangements in which Iranian funds remain in restricted accounts abroad and can be used only for humanitarian trade, with the United States retaining oversight over how those funds are spent. These statements explain that the funds are not handed over directly to Iran but are kept under tight controls and monitored through mechanisms agreed with the foreign bank and government involved.

“The United States granted SREs to eight countries—China, Greece, India, Italy, Japan, South Korea, Taiwan and Turkey—which exempt financial institutions in these countries from U.S. sanctions for facilitating significant financial transactions related to the purchase of oil from Iran.” It adds: “Importantly, foreign financial institutions and persons in countries who obtained an SRE 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.” The alert notes Secretary Pompeo’s statement that “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.

Treasury’s statement on Significant Reduction Exceptions explains that countries receiving waivers to keep importing Iranian oil must ensure that "payments to Iran for oil" are retained in restricted accounts in the importing country and may be used only for non-sanctioned trade, typically humanitarian items. The statement makes clear that the funds remain under strict conditions and are not freely available to Iran, describing them as being held in controlled accounts overseas rather than transferred directly to Iranian-controlled accounts.

The analysis of General License X states that "GL X gives Iran the ability to fund its rearmament without any oversight by the United States." It specifies: "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 purchasers, vessels, insurers, intermediaries, payment routes, or financial institutions involved." The criticism is that, in this case, there is *no* escrow mechanism and therefore no U.S.-controlled escrow account associated with these particular sanctions relief funds.

Discussing post-2018 oil waivers, ECFR writes: "However, revenues from Iran’s oil sales will be held in escrow accounts and can only be used for trade in humanitarian goods or other non-sanctioned products." It adds that the administration insisted these waivers were consistent with the aim that Iran’s government have "zero oil revenue" available for malign activity. The article frames these as escrow accounts where Iranian oil revenue is restricted and earmarked for humanitarian or non‑sanctioned trade, but does not describe them as being physically in the United States or directly operated by U.S. banks.

Reporting on the new 60-day license, the article notes that it "enhances Iran's access to U.S. currency by permitting the nation to engage in oil transactions in U.S. dollars" and allows American importers to buy Iranian crude and petrochemical products. The piece focuses on the scope of the relief and its market impact and does not describe any requirement that proceeds from these transactions be placed into a U.S.-controlled escrow account, highlighting instead the broadened access to dollar-based trade.

Reporting on former President Donald Trump's remarks about a contemporary Iran deal, NDTV quotes his Truth Social post: "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." NDTV explains 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." These are statements describing how Trump claimed unfrozen or sanctions‑relief funds would be handled under that deal.

Summarizing OFAC’s 2016 JCPOA-related FAQs, the firm notes that non‑U.S. financial institutions "may process transactions denominated in US dollars or maintain US dollar denominated accounts that involve Iran" provided they do not involve the U.S. financial system or U.S. persons unless authorized. It emphasizes that "non-US financial institutions are still prohibited from clearing US dollar transactions involving Iran through the US financial system" unless authorized by OFAC. The discussion focuses on non‑U.S. dollar clearing and correspondent relationships, and does not describe a general rule that sanctions‑relief funds are deposited into U.S.-controlled escrow accounts; instead, it details how non‑U.S. banks may handle Iran-related funds under sanctions relief.

Among the FAQs implementing Executive Order 13599 and the Iran Transactions and Sanctions Regulations, OFAC states that "U.S. persons in possession of property or interests in property" of certain Iranian parties "are obligated to block the property and report the blocking to OFAC within 10 days of blocking." It notes that blocked funds must be "held in interest-bearing accounts" and that U.S. depository institutions may process licensed transfers to or from Iran if they are incident to an authorized underlying transaction and "does not involve debiting or crediting an Iranian account" under 31 CFR 560.516(a). These FAQs describe obligations to block or license Iranian-related funds in U.S. hands; they do not set out a standing requirement that sanctions‑relief funds be placed into a U.S.-controlled escrow account, but do show that when funds are blocked they are maintained in restricted accounts under U.S. jurisdiction.

In a news segment on a Trump‑era arrangement with Iran, PBS reports: "The Treasury Department temporarily waived sanctions on Iranian oil on Monday as part of the Trump administration's deal with Tehran to end ..." and explains that "The Treasury issued a general license that allows Iran to produce, deliver, and sell its crude oil and other petroleum products until August 21st." The discussion centers on a general license waiving certain oil sanctions; it does not state that proceeds are funneled into a U.S.-controlled escrow account, but rather that sanctions on oil sales were temporarily relaxed.

Hindustan Times reports: "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 article reproduces Trump’s Truth Social message: "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." It also notes Iran’s claim that "$12 billion of its frozen funds are set to be released as part of ongoing talks" and that the U.S. Treasury temporarily eased sanctions on Iran’s crude oil sector through August 21, in the context of negotiations.

The policy brief discusses mechanisms used to restrict Iran’s access to funds, including escrow arrangements tied to oil sales: it refers to keeping "oil revenues in escrow accounts in foreign banks" so Iran can only use them for humanitarian trade and non-sanctioned goods, reflecting the post-2018 model described by U.S. officials. The brief frames these accounts as part of a strategy to "reduce the flow of funds to the Iranian regime" while allowing some controlled, humanitarian use, and treats them as foreign-held accounts subject to U.S. conditions rather than freely accessible state funds.

The overview of U.S. sanctions against Iran explains that, under previous U.S. waivers, "funds owed to Iran for oil purchases" were often held in restricted or escrow-type accounts in the buying country, usable only for limited purposes such as humanitarian trade. It also notes more recent measures, including Treasury actions in 2025 and 2026 targeting Iranian networks and seizing assets, reflecting that a mix of restricted accounts abroad and asset seizures have been used rather than a single U.S.-based escrow model.

Across multiple Iran sanctions relief arrangements since the 2010s, funds have typically been held in restricted or escrow-style accounts in banks located in third countries (such as South Korea, Japan, India, or Qatar). The United States generally conditions waivers on these accounts remaining outside Iran, with withdrawals limited to humanitarian or other non-sanctioned trade and subject to U.S. oversight or approval. These mechanisms are often described in official statements as foreign-held restricted accounts, not as U.S. domestic escrow accounts fully controlled by the U.S. Treasury.

In a public post discussing the claim about Iran sanctions relief, Eric Brewer writes: "Given that there's zero evidence that Iranian funds from sanctions relief are going into escrow accounts controlled by the U.S., and that..." He argues there is no publicly available evidence that the specific funds referenced in recent political rhetoric are held in a U.S.-controlled escrow account, contrasting this with the established practice of foreign escrow accounts under significant reduction exceptions.

The post reports: "Trump announces unfrozen Iran funds will go into a US-controlled escrow account for humanitarian aid, exclusively for US food and medical supplies." It describes a claimed arrangement in which Iran would not receive the funds directly but they would be placed in an escrow account under U.S. control to pay U.S. suppliers for approved humanitarian exports.

Commenting on the Treasury general license waiving Iranian oil sanctions, the author writes: "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 ..." In context, the thread argues that the particular Trump‑era general license for Iranian oil sales does *not* set up an escrow mechanism and imposes no specific restrictions on Iran’s use of sale proceeds, contrasting it with earlier sanctions frameworks that held oil revenues in escrow accounts for humanitarian trade.

The Punch’s social post summarizes: "Unfrozen Iran funds to go into US-run escrow account - Trump. Trump announces unfrozen Iran funds will go into a US-controlled escrow account for humanitarian aid, exclusively for US food and medical supplies.... No shishi for Iranian regime and even the money for rebuilding Iran will still be in US coffers." This reflects the political framing that the funds, while nominally sanctions relief, would remain in an escrow arrangement overseen by the United States.

Examining a 30‑day OFAC waiver, the author notes that the waiver "is expected to unlock around **140 million barrels of stranded Iranian oil** for global markets" and that Treasury’s Office of Foreign Assets Control "issued a **30-day general license/waiver**" to permit these transactions. The discussion focuses on the volume of oil and oil‑market effects and does not describe the proceeds as being deposited into a U.S.-run escrow account; instead it implies that, under this particular waiver, the funds are **not subject to traditional escrow restrictions** that characterised earlier sanctions-relief frameworks.

The post reports that "Iran says the US will release $12bn in frozen funds, as talks progress in Switzerland. It follows the temporary easing of sanctions to allow the production, sale and delivery of crude oil and related products." This reflects Iran’s claim about the scale of funds involved in sanctions relief negotiations, but does not specify that the released funds would be placed in U.S.-controlled escrow, focusing instead on the overall amount and the easing of oil-related sanctions.

The caption states that "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" and used for humanitarian purposes. This social media post attributes to Trump a policy claim that unfrozen Iranian funds would not be handed over directly but routed into an escrow mechanism controlled by the United States.

A post summarizing Donald Trump's comments states: "Donald Trump says any Iranian funds released through sanctions relief will be placed in a Washington-controlled escrow account for food and medicine purchases." It paraphrases his claim that such funds "will be placed in a Washington-controlled escrow account" and restricted to humanitarian uses. This reflects how some commentators describe the arrangement, based on Trump’s own characterization, rather than a detailed Treasury regulation.