Trump designated the IRGC, through the Secretary of State, as a foreign terrorist organization in his first term. Under the law, that makes all transactions with the IRGC a crime. The IRGC runs Iran, so none of the sanctions relief in the MOU is legal unless Trump removes the FTO designation. Only the Secretary of State has the authority to delist an FTO. Since that’s not going to happen, the administration must ignore the law to make this deal.