World & Conflict · The Record
Sanctions alone cannot topple Iran's government, former US Treasury official says; US oil licence lasted 16 days
The claim is that numbers do not measure whether sanctions work. Three records - one of them read through law firms' analyses - show a February 2025 White House memorandum making a number the objective, a June 2026 licence for Iranian crude revoked 16 days later, and a watchdog report numbered GAO-08-58 finding the government did not measure impact at all.
Iran International published in mid-August 2026 an interview with a person the outlet describes only as a former US Treasury official, whose case ran against the way sanctions are usually judged in Washington and in Tehran alike. "Sanctions can't topple a regime on their own. That's not what they're for," the former official told the outlet. The point was not that sanctions fail. It was that collapse is the wrong test - and that the wrong test is applied by the people who defend the policy and by the people who dismiss it.
The argument, as the quotations on file record it, is mechanical rather than triumphal. Sanctions are intended to increase pressure. They make what a targeted government wants slower, dearer and harder to obtain. They raise the cost of procuring parts and components and push buyers toward worse ones, so that the finished weapons work less well. Their purpose, in the former official's phrase, is to set conditions for something else to happen. In that account the something else is not delivered by Treasury at all: it is the Iranian people who have to use the pressure.
Then comes the line that makes the whole argument checkable. "Numbers are not a good measure of the impact of sanctions and whether they are important," the former official said. Designating thousands of individuals and entities across Russia, Iran and North Korea is not, on this account, the answer; the aim is to change behaviour, and behaviour is not a count. Enforcement has to be kept up and kept visible - the interview's warning is that without follow-through, people simply keep doing what they want to do. Iran, the former official said, runs a sanctions evasion operation that works well, and most evasion connected to Iran runs through China.
The record: a memorandum that made a number the objective
The document that most directly tests the numbers claim is NSPM-2, the national security presidential memorandum published by the White House at an address that dates it to February 2025. It instructs the Secretary of State, working with the Secretary of the Treasury and other agencies, to run a continual campaign "to drive Iran's export of oil to zero, including exports of Iranian crude to the People's Republic of China." A parallel paragraph directs a continual sanctions enforcement campaign to deny the government in Tehran and its proxies access to revenue.
Zero is a number. Written US policy, on the face of that memorandum, set a counted outcome as the objective - the precise kind of measure the former official told Iran International is a poor guide to whether sanctions matter. Nothing on file establishes whether the memorandum still governs, and the record that follows shows the same government licensing, for a period, the exports it had ordered driven to zero.
The something else, and how long it lasted
What the something else looked like in practice is on the record for the summer of 2026, though not from Treasury's own pages. Norton Rose Fulbright, reading the notice for clients, states that the Office of Foreign Assets Control issued Iran-related General License X on 21 June 2026, authorising the production, sale, delivery and offloading of crude oil, petrochemical and petroleum products of Iranian origin through 12:01 am Eastern Daylight Time on 21 August 2026. The firm ties the licence to paragraph 10 of a reported 17 June 2026 US-Iran memorandum of understanding, and notes that the authorisation extended to importing Iranian-origin crude into the United States.
It reached further than cargo. The licence "authorizes transactions involving vessels that are blocked under the listed sanctions authorities," the firm writes, and its analysis calls that provision significant because hundreds of tankers already designated on OFAC's Specially Designated Nationals list for their part in Iran's petroleum trade could take part in that trade during the licence period. Designations assembled over years were set aside in a paragraph.
They were reinstated almost as quickly. Foley & Lardner records that General License X1 "replaces GL X in its entirety," revoking and winding down the June authorisation after three tankers were reported struck by unknown projectiles near the Strait of Hormuz at the beginning of July. X1 allowed only a 10-day buffer, running through 17 July, which places the revocation on 7 July. Relief written to run two months ran 16 days.
What nobody counted
The strongest support for the measurement half of the claim comes from the US government's own auditor, and it is old. A Government Accountability Office report on Iran sanctions, numbered GAO-08-58 and dated by that number to 2008, found that "U.S. agencies do not systematically collect or analyze data demonstrating the overall impact and results of their sanctioning and enforcement actions." Officials and experts told the auditors that sanctions were having specific impacts; the extent of those impacts, the report states, was difficult to determine. Whether the sanctions furthered US objectives, it concluded, "is unclear."
On that dating the finding is 18 years old, and nothing in the material assembled here shows it resolved. A former Treasury official arguing that impact cannot be counted and an auditor finding that the agencies never built the means to count it are not the same statement: the first is a claim about what sanctions are for, the second a finding about what the government does. Set side by side, they describe a policy whose success has been asserted for nearly two decades without a measurement system standing behind the assertion.
Read as analysis, on the cited documents alone: the interview and the record disagree about what sanctions are, not about whether they bite. The former official describes an instrument whose worth cannot be read off a tally. The written US policy of February 2025 made a tally - zero barrels - the objective, and the summer's licensing shows the same government trading that objective away inside a negotiation and then taking the trade back 16 days later, after events at sea it did not control. Both cannot be the operating theory at once.
There is a date to watch, and it is close. GL X carried its own expiry at 12:01 am Eastern Daylight Time on 21 August 2026 - four days from publication. On the record as it stands, that date arrives with the authorisation already revoked and nothing in its place; if a general licence restoring any part of the June terms appears before then, the arrangement survived the strikes and this reading was wrong. Either way it settles in public on a fixed date, which is more than the impact question has managed since 2008.