UMVA has learned that a proposed $300 billion investment fund for Iran, included in a recent U.S.–Iran agreement, may face significant legal hurdles under existing U.S. sanctions law, casting doubt on the plan's feasibility.
The agreement, digitally signed by President Donald Trump and Iranian President Masoud Pezeshkian, aims to end the war and restore traffic through the Strait of Hormuz. As part of the 14-point plan, the U.S. agreed to lift sanctions on Iran, allow Tehran to increase its oil revenue, and regain access to parts of the international banking system.
However, the proposed $300 billion private investment fund for Iran's reconstruction and development may conflict with a longstanding U.S. determination that Iran's construction sector is controlled directly or indirectly by the Islamic Revolutionary Guard Corps. This raises questions about whether one of the central economic promises of the Trump-Iran framework can realistically be executed under current U.S. law.
Experts warn that if the $300 billion fund depends on investment in sectors Washington has already identified as IRGC-controlled, the administration may be forced to rely on temporary waivers or new licenses. This legal structure could make long-term investors wary and complicate any final deal.
A senior fellow at a prominent think tank, who previously worked at the Treasury Office of Foreign Assets Control, told UMVA that the legal and sanctions-related problems surrounding the fund are more complicated than simply asking whether Congress would have to approve it. "I think Congress is unavoidable for a durable version of that investment," he said.
The expert noted that while the president has meaningful unilateral authority to begin easing restrictions, it does not mean the fund would be durable enough to attract serious investors. "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," he said.
This creates uncertainty and risk for investors, particularly in Iran, where they would face sanctions uncertainty, political risk, and an unreliable partner. The concern raises a broader question about whether negotiators were truly expecting the memorandum to mature into a final, durable agreement.
The issue could become a congressional flashpoint, as any long-term investment framework for Iran could force the administration to repeatedly defend why sanctions tied to an IRGC-controlled sector should be suspended. Critics warn that the pact gives Iran major economic benefits while leaving some of the most difficult nuclear and security questions for future negotiations.
A former national security adviser warned that any economic windfall from the agreement 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," he said.
UMVA can exclusively reveal that the Treasury Department and Iranian officials are under pressure to address these concerns, but it remains to be seen how the issue will be resolved. The situation is being closely watched by experts and policymakers, who are questioning the feasibility of the proposed investment fund.
