By Noah Rothman
Thursday, June 18, 2026
Donald Trump indicated at the G-7 summit in France on
Wednesday that the deluge of criticisms his MOU has received may be getting to
him. “No, it’s not final,” Trump insisted when asked if the document was still
revisable. “And if I don’t like it, we’ll go back to shooting at them, dropping
bombs on their head.”
That is not a credible threat. In pursuit of his deal,
Trump abandoned each of the red lines that brought him to war with Iran in the
first place. His willingness to look beyond the many Iranian violations of the
cease-fire he negotiated in April suggests that nothing will dissuade him from
coming to terms with Iran, even if those terms are awful.
Critics of the deal got some good news this week from the Congress-watchers at Punchbowl.
Maybe, just maybe, the preventative measures Republicans took in the wake of
Barack Obama’s Iran deal to prevent a similar usurpation of congressional
authority will stop Trump from giving away the store, too.
In 2024, Congress passed legislation that included a
provision compelling the State Department to provide the legislature with
reports every 180 days indicating whether Iran had launched drone attacks on
U.S. service personnel or assets in that period. If the Islamic Revolutionary
Guards Corps is involved in those attacks — and if Iranians are attacking
Americans, the IRGC is involved — then the president is forbidden by law from
de-listing the organization as a Foreign Terrorist Organization (FTO).
“Lifting the IRGC’s FTO designation would almost
certainly be required to implement the broad sanctions relief the admin has
outlined under the MOU,” Punchbowl’s Andrew
Desiderio reported. If he were so inclined, the statute gives the president
authority to waive the entire provision in the interests of national security.
Even if he did that, though, the IRGC would still retain its terrorist
designation. “But loosening IRGC sanctions by arguing they should be removed
from the FTO list would be [a] tough sell” for congressional Republicans, Desiderio
concluded.
That backstop will make it difficult for the president to
secure the sanctions relief for Iran envisioned in the MOU, and it would
probably scuttle the $300 billion Gulf-region-backed reconstruction fund
reported in Article 6 of the document. After all, Trump isn’t going to
go so far as to strip the IRGC of its designation as a terrorist organization,
right?
In fact, that’s exactly what he might have to do.
The provision at issue was slipped into a 2024
supplemental designed to secure additional support for Ukraine’s defense. The
legislative legwork on the provision began back in 2022, as Biden’s negotiators
were doing their best to exhume Obama’s JCPOA from the grave to which Donald
Trump had consigned it.
It was in February of that year that the administration provided Congress with “sensitive but
classified” material revealing that the State Department was spending millions
to protect former Trump administration officials Mike Pompeo and Brian Hook
from credible threats against them issued by the IRGC.
Those threats “have been discusses [sic] in the
nuclear talks in Vienna, where Iran is demanding the removal of all Trump-era
sanctions,” the AP’s Matt Lee reported. “Those sanctions include a “foreign
terrorist organization” designation of Iran’s Islamic Revolutionary Guard Corps
that Pompeo and Hook were instrumental in approving.”
The previous Sunday, March 6, 2022, CBS News host Margaret Brennan asked then-Secretary of State Antony Blinken
about the Iranian threat to the lives of American civil servants. What are the
prospects for a new nuclear deal if Iran continues to hold American hostages
and actively seeks the murder of Iranian dissidents on U.S. soil as well as
U.S. government officials, she asked? Blinken “sidestepped the question,”
according to CBS News’ analysis.
Blinken’s caginess caused a stir. Clearly, de-listing the
IRGC as a terrorist enterprise was on the table in Vienna. Indeed, it seems to
have been one of the Iranian regime’s primary preconditions for a new nuclear
agreement. And the Biden administration may have seriously considered giving in
to Iran’s demand.
In a subsequent interview, NBC News’ Andrea Mitchell
helped Blinken clean up the mess he’d made on CBS. “Quick question on Iran
before I let you go,” she asked the secretary at the end of an April 6, 2022,
interview. “Is Iran’s Revolutionary Guard — which has attacked Americans and
our allies — a terrorist organization?” Blinken agreed that “they are.” But
“will they continue to be?” Mitchell inquired. Once again, Blinken hemmed and
hawed.
Two days later, Biden administration officials finally
put the issue to rest by telling Washington Post columnist David Ignatius that the president would not revoke the
IRGC’s designation as a terrorist organization. “This might largely be a
symbolic issue, but the IRGC needs to earn its way off the list,” Ignatius
wrote.
After this, nuclear talks in Vienna stalled before
ultimately collapsing in the fall of that year. Even as a prerequisite to
revive the Iran nuclear deal, stripping the IRGC of its FTO status was a bridge
too far for Biden.
So, will that also be too much for Trump to bear? Not if
he sticks with the terms of the MOU.
Yes, Trump has the authority to suspend the State
Department’s reporting requirements unilaterally, but that would not remove the
IRGC’s FTO designation. The IRGC will, however, be primarily responsible for
administering the “rehabilitation and economic development” funds envisioned in
the MOU’s Article 6. After all, the IRGC has its hands around every critical
industry inside Iran, including construction.
If the MOU is “finalized” within 60 days — a very tall
order — there can be no “final deal,” unless the IRGC is stripped of its
terrorist designation. Why? Because Gulf region governments and private
enterprises cannot do visible business with a U.S.-designated terrorist
organization. “The President can waive, but only 180 days at a time,” Foundation
for Defense of Democracies senior fellow Miad Maleki observed. “No serious
investor commits billions on a rolling six-month waiver cycle.”
Perhaps Trump will ultimately balk at giving the Islamic
Republic a gift so valuable that even Joe Biden withheld it. But the
alternative is to allow the deal to collapse. That would almost certainly
trigger a new crisis in the region. Iran isn’t going to be deterred by Trump’s
threats.
And why wouldn’t Trump give in to Iran’s demands? He’s
already punted the nuclear issue over the horizon. The MOU makes no mention of
Iran’s support for its terrorist proxies. In Europe, he’s even defended the existence of Iran’s missile arsenal —
the development of which was one of the primary causes of the war in the first place.
“In other words, they must have missiles to some degree,
because others have them,” the president
said of Iran. If Trump has talked himself out of neutralizing the Iranian
threat in all its many manifestations, it’s not hard to imagine him rewarding
an organization that has sought the deaths of thousands of Americans — including himself and his family.
Maybe the president didn’t fully understand the scope of
the national humiliation that he’s engineered for us all, but he’s about to
find out.
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