Iran Sanctions

Changes from November 18, 2020 to April 6, 2021

This page shows textual changes in the document between the two versions indicated in the dates above. Textual matter removed in the later version is indicated with ~~red strikethrough~~ and textual matter added in the later version is indicated with blue.

Iran Sanctions
~~November 18, 2020~~April 6, 2021
Successive Administrations and Congresses have used economic sanctions to try to Successive Administrations and Congresses have used economic sanctions to try to
change Iran’s behavior. U.S. sanctions on Iranchange Iran’s behavior. U.S. sanctions on Iran~~, which are primarily “secondary~~—primarily “secondary sanctions” on
Kenneth Katzman
~~sanctions” on~~ firms that conduct certain transactions with Iranfirms that conduct certain transactions with Iran, —have adversely affected have adversely affected
Iran’s Specialist in Middle Specialist in Middle
~~Iran’s~~ economy but have arguably not, to date, altered Iran’s pursuit of core strategic economy but have arguably not, to date, altered Iran’s pursuit of core strategic
Eastern Affairs Eastern Affairs
objectives including its support for regional armed factions and its development of objectives including its support for regional armed factions and its development of

missiles. missiles. Sanctions did contribute to Iran’s decision to enter into a 2015 agreement that Sanctions did contribute to Iran’s decision to enter into a 2015 agreement that

put limits on its nuclear program—the Joint Comprehensive Plan of Action (JCPOA). put limits on its nuclear program—the Joint Comprehensive Plan of Action (JCPOA).
During 2011-2015, During 2011-2015, in implementation of deliberate U.S. policy, global economic sanctions contributed to the shrinking of Iran’s economy as its crude oil global economic sanctions contributed to the shrinking of Iran’s economy as its crude oil
exports fell by more than 50% and it could not access its foreign exchange assets abroad. exports fell by more than 50% and it could not access its foreign exchange assets abroad. ~~In accordance with the~~
Upon Iran’s implementation of nuclear program restrictions stipulated by the JCPOA, the Obama Administration eased the relevant sanctions and U.N. and European Union sanctions were JCPOA, the Obama Administration eased the relevant sanctions and U.N. and European Union sanctions were
lifted as well. Remaining in place were U.S. sanctions on direct trade with Iran and on Iran’s support for regional lifted as well. Remaining in place were U.S. sanctions on direct trade with Iran and on Iran’s support for regional
armed factions, its human rights abuses, and on its efforts to acquire missile and advanced conventional weapons armed factions, its human rights abuses, and on its efforts to acquire missile and advanced conventional weapons
technology. U.N. Security Council Resolution 2231, which endorsed the JCPOA, kept in place an existing ban on technology. U.N. Security Council Resolution 2231, which endorsed the JCPOA, kept in place an existing ban on
its importation or exportation of arms (its importation or exportation of arms (~~until~~which expired on October 18, 2020) and a October 18, 2020) and a ~~non-binding~~nonbinding restriction on Iran’s restriction on Iran’s
development of nuclear-capable ballistic missiles (until October 18, 2023). The sanctions relief enabled Iran’s development of nuclear-capable ballistic missiles (until October 18, 2023). The sanctions relief enabled Iran’s
economy to return to growth and allowed Iran to order some new passenger aircraft. economy to return to growth and allowed Iran to order some new passenger aircraft.
On May 8, 2018, President Trump ended U.S. participation in the JCPOA and reimposed all secondary sanctions On May 8, 2018, President Trump ended U.S. participation in the JCPOA and reimposed all secondary sanctions
(by November 6, 2018by November 6, 2018). The . The ~~re-imposed~~reimposed sanctions, and additional sanctions imposed sanctions, and additional sanctions imposed ~~since, have been~~subsequently, were at the core at the core
of Trump Administration policy to apply “maximum pressure” on Iran, with the stated purpose of compelling Iran of Trump Administration policy to apply “maximum pressure” on Iran, with the stated purpose of compelling Iran
to negotiate a revised JCPOA that takes into account U.S. concerns beyond Iran’s nuclear program. The policy to negotiate a revised JCPOA that takes into account U.S. concerns beyond Iran’s nuclear program. The policy ~~has~~
caused Iran’s economy to fall into caused Iran’s economy to fall into ~~severe recession. Iran’s oil exports have decreased dramatically, particularly~~
~~after the Administration in May 2019 ended sanctions exceptions for the purchase of Iranian oil. The~~
~~Administration has~~significant recession as a result, in part, of reduced sales of oil and isolation from the international financial system. The Trump Administration also sanctioned several senior Iranian officials as well as figures in regional pro-Iranian also sanctioned several senior Iranian officials as well as figures in regional pro-Iranian
factions and militias. factions and militias. ~~Despite the sanctions~~Yet, Iran , Iran ~~has~~ continued to develop its missile capabilities continued to develop its missile capabilities ~~force~~ and to and to
provide arms and support to a broad array of armed factions operating throughout the region, while refusing to provide arms and support to a broad array of armed factions operating throughout the region, while refusing to
begin talks with the United States on a begin talks with the United States on a more expansive, revised JCPOA. The European Union and other countries have sought, revised JCPOA. The European Union and other countries have sought,
unsuccessfully, to keep the economic benefits of the JCPOA flowing to Iran in order to persuade Iran to remain in unsuccessfully, to keep the economic benefits of the JCPOA flowing to Iran in order to persuade Iran to remain in
the nuclear accord. Since mid-2019, Iran has responded to the increasing sanctions by decreasing its compliance the nuclear accord. Since mid-2019, Iran has responded to the increasing sanctions by decreasing its compliance
with the nuclear commitments of the JCPOA and by conducting provocations in the Persian Gulf and in Iraq.with the nuclear commitments of the JCPOA and by conducting provocations in the Persian Gulf and in Iraq. ~~The~~
~~presumptive winner of the 2020 presidential election, former Vice~~ Since taking office, President Joseph Biden President Joseph Biden~~, has stated in a~~
~~September 2020 an intent to rejoin the JCPOA if elected, a step that would require revoking those sanctions re-~~
~~imposed and imposed since 2018.~~
~~The COVID-19 pandemic has prompted international criticism, including from some in Congress, that U.S.~~
~~sanctions on Iran might be hindering Iran’s response to the outbreak. Iran has reported more cases and more~~
~~deaths from the illness than any other country in the region. Numerous accounts indicate that sanctions have~~
~~hindered Iran’s ability to finance the purchase of medical equipment, even though U.S. sanctions do not apply to~~
~~humanitarian transactions. In March 2020, the Administration revised public sanctions guidance to prompt foreign~~
~~companies to proceed with sales of humanitarian items to Iran, and it has offered assistance to help Iran deal with~~
~~COVID-19, but Iran has refused the U.S. aid~~ has sought to implement a stated intent to rejoin the JCPOA, including welcoming talks with Iran toward that end. Administration officials have acknowledged that a U.S. return to the agreement would entail an easing of the stipulated U.S. economic sanctions. .
See also CRS Report R43333, See also CRS Report R43333, Iran Nuclear Agreement and U.S. Exit, by Paul K. Kerr and Kenneth Katzman; and , by Paul K. Kerr and Kenneth Katzman; and
CRS Report R43311, CRS Report R43311, Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions, by Dianne E. , by Dianne E.
Rennack. Rennack.
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link to page link to page 9897 Iran Sanctions

Contacts
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Iran Sanctions

Overview
Sanctions have been a significant component of U.S. Iran policy since Iran’s 1979 Islamic Sanctions have been a significant component of U.S. Iran policy since Iran’s 1979 Islamic
Revolution that toppled the Shah of Iran, a U.S. ally. In the 1980s and 1990s, U.S. sanctions were Revolution that toppled the Shah of Iran, a U.S. ally. In the 1980s and 1990s, U.S. sanctions were
intended to try to compel Iran to cease supporting acts of terrorism and to limit Iran’s strategic intended to try to compel Iran to cease supporting acts of terrorism and to limit Iran’s strategic
power in the Middle East more generally. After the mid-2000s, U.S. and international sanctions power in the Middle East more generally. After the mid-2000s, U.S. and international sanctions
focused largely on trying to persuade Iran to agree to limits to its nuclear program. Still, sanctions focused largely on trying to persuade Iran to agree to limits to its nuclear program. Still, sanctions
have had multiple objectives and sought to address multiple threats from Iran simultaneously. have had multiple objectives and sought to address multiple threats from Iran simultaneously.
This report analyzes U.S. and international sanctions against Iran. CRS cannot independently This report analyzes U.S. and international sanctions against Iran. CRS cannot independently
corroborate whether any individual or other entity might be in violation of U.S. or international corroborate whether any individual or other entity might be in violation of U.S. or international
sanctions against Iran. sanctions against Iran. ~~The report tracks implementation of the various U.S. laws and executive~~
~~orders, some of which~~Some of the laws and orders analyzed in this report require the blocking of U.S.-based property of sanctioned entities. No require the blocking of U.S.-based property of sanctioned entities. No
information has been released from the executive branch indicating the extent, if any, to which information has been released from the executive branch indicating the extent, if any, to which
any such property is currently blocked. any such property is currently blocked.
The sections below are grouped by function, in the chronological order in which these themes The sections below are grouped by function, in the chronological order in which these themes
have emerged. have emerged.
Blocked Iranian Property and Assets
Post-JCPOA Status: Iranian Assets Still Frozen, but Some Issues Resolved
U.S. sanctions on Iran were first imposed during the U.S.-Iran hostage crisis of 1979-1981, in the U.S. sanctions on Iran were first imposed during the U.S.-Iran hostage crisis of 1979-1981, in the
form of executive orders issued by President Jimmy Carter blocking nearly all Iranian assets held form of executive orders issued by President Jimmy Carter blocking nearly all Iranian assets held
in the United States.1 in the United States.1
U.S.-Iran Claims Tribunal
The Algiers Accords that resolved the U.S.-Iran hostage crisis established a “U.S.-Iran Claims The Algiers Accords that resolved the U.S.-Iran hostage crisis established a “U.S.-Iran Claims
Tribunal” at the Hague that continues to arbitrate government-to-government cases resulting from Tribunal” at the Hague that continues to arbitrate government-to-government cases resulting from
the 1980 break in relations and freezing of some of Iran’s assets. All of the 4,700 private U.S. the 1980 break in relations and freezing of some of Iran’s assets. All of the 4,700 private U.S.
claims against Iran were resolved in the first 20 years of the Tribunal, resulting in $2.5 billion in claims against Iran were resolved in the first 20 years of the Tribunal, resulting in $2.5 billion in
awards to U.S. nationals and firms. The major government-to-government cases involve Iranian awards to U.S. nationals and firms. The major government-to-government cases involve Iranian
claims for compensation for hundreds of foreign military sales (FMS) cases that were halted in claims for compensation for hundreds of foreign military sales (FMS) cases that were halted in
concert with the rift in U.S.-Iran relations when the Shah’s government fell in 1979. concert with the rift in U.S.-Iran relations when the Shah’s government fell in 1979.
On January 17, 2016 (coincident with JCPOA taking effect), the United States announced it had On January 17, 2016 (coincident with JCPOA taking effect), the United States announced it had
settled with Iran on additional FMS cases that were frozen when the Shah’s government fell. Iran settled with Iran on additional FMS cases that were frozen when the Shah’s government fell. Iran
had been depositing its FMS payments into a had been depositing its FMS payments into a ~~DoD~~DOD-managed “Iran FMS Trust Fund,” and, after -managed “Iran FMS Trust Fund,” and, after
1990, the Fund had a balance of about $400 million.2 Under the 2016 settlement, the United 1990, the Fund had a balance of about $400 million.2 Under the 2016 settlement, the United
States sent Iran the $400 million balance, plus $1.3 billion in accrued interest (paid from the States sent Iran the $400 million balance, plus $1.3 billion in accrued interest (paid from the
Department of the Treasury’s Judgment Fund.) In order not to violate U.S. regulations barring Department of the Treasury’s Judgment Fund.) In order not to violate U.S. regulations barring
direct U.S. dollar transfers to Iranian banks, the funds were remitted to Iran in foreign hard
1 The Orders included E.O. 12170 of November 14, 1979, blocking all Iranian government property in the United 1 The Orders included E.O. 12170 of November 14, 1979, blocking all Iranian government property in the United
States, and E.O 12205 (April 7, 1980) and E.O. 12211 (April 17, 1980) banning virtually all U.S. trade with Iran. The States, and E.O 12205 (April 7, 1980) and E.O. 12211 (April 17, 1980) banning virtually all U.S. trade with Iran. The
latter two orders were issued just prior to the failed April 24-25, 1980, U.S. effort to rescue the U.S. Embassy hostages latter two orders were issued just prior to the failed April 24-25, 1980, U.S. effort to rescue the U.S. Embassy hostages
held by Iran. President Jimmy Carter also broke diplomatic relations with Iran on April 7, 1980. The trade-related held by Iran. President Jimmy Carter also broke diplomatic relations with Iran on April 7, 1980. The trade-related
orders (12205 and 12211) were revoked by Executive Order 12282 of January 19, 1981, following the “Algiers orders (12205 and 12211) were revoked by Executive Order 12282 of January 19, 1981, following the “Algiers
Accords” (Accords” (~~hereafter:~~hereinafter, “Accords”) that resolved the U.S.-Iran hostage crisis. “Accords”) that resolved the U.S.-Iran hostage crisis.
2 In 1990, $200 million was paid from the Trust Fund to Iran to settle some FMS cases. In 1991, the United States paid 2 In 1990, $200 million was paid from the Trust Fund to Iran to settle some FMS cases. In 1991, the United States paid
$278 million from the separate Treasury Department Judgment Fund to settle some additional FMS cases. $278 million from the separate Treasury Department Judgment Fund to settle some additional FMS cases.
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~~direct U.S. dollar transfers to Iranian banks, the funds were remitted to Iran in foreign hard~~
currency from the central banks of the Netherlands and of Switzerland. Some remaining claims currency from the central banks of the Netherlands and of Switzerland. Some remaining claims
involving the FMS program with Iran remain under arbitration. involving the FMS program with Iran remain under arbitration.
Other Iranian Assets Frozen
Iranian assets in the United States remain blocked under several provisions, including Executive Iranian assets in the United States remain blocked under several provisions, including Executive
Order 13599 of February 2010. Order 13599 of February 2010.
  ~~About~~U.S. officials consider about $1.9 billion in $1.9 billion in ~~blocked Iranian assets are bonds belonging to Iran’s Central~~
~~Bank,~~Iranian Central Bank assets that were held in a Citibank account in New York in a Citibank account in New York ~~belonging to~~as subject to being blocked. The account was in the name of Clearstream, a Clearstream, a
Luxembourg-based securities firm. In Luxembourg-based securities firm. In ~~2008, Clearstream allegedly improperly~~
~~allowed those funds to access the U.S. financial system.~~ 2013, Clearstream transferred Clearstream transferred
$1.67 billion to its accounts in Luxembourg$1.67 billion to its accounts in Luxembourg ~~and those proceeds have been~~
~~deemed by Luxembourg courts as outside U.S. jurisdiction~~. In 2019, Luxembourg courts ruled that the funds were outside U.S. jurisdiction and could not be transferred back to U.S.-based banks and subjected to blockage. .
 About $50 million of Iran’s assets frozen in the United States consists of Iranian  About $50 million of Iran’s assets frozen in the United States consists of Iranian
diplomatic property and accounts, including the former Iranian embassy in diplomatic property and accounts, including the former Iranian embassy in
Washington, DC, and 10 other properties in several states, and related accounts.3 Washington, DC, and 10 other properties in several states, and related accounts.3
 Among other frozen Iranian assets are real estate holdings of the Assa Company,  Among other frozen Iranian assets are real estate holdings of the Assa Company,
a UK-chartered entity, which allegedly was maintaining the interests of Iran’s a UK-chartered entity, which allegedly was maintaining the interests of Iran’s
Bank Melli in a New York City office building and properties in Texas, Bank Melli in a New York City office building and properties in Texas,
California, Virginia, Maryland, and other parts of New York City. An Iranian California, Virginia, Maryland, and other parts of New York City. An Iranian
entity, the Alavi Foundation, is an investor in the properties. The U.S. Attorney entity, the Alavi Foundation, is an investor in the properties. The U.S. Attorney
for the Southern District of New York blocked these properties in 2009. The for the Southern District of New York blocked these properties in 2009. The
Department of the Treasury report avoids valuing real estate holdings. In June Department of the Treasury report avoids valuing real estate holdings. In June
2017, the United States won legal control over the New York office building. 2017, the United States won legal control over the New York office building.
Use of Iranian Assets to Compensate U.S. Victims of Iranian Terrorism4
Nearly $50 billion in court awards have been made to victims of Iranian terrorism. These include Nearly $50 billion in court awards have been made to victims of Iranian terrorism. These include
the families of the 241 U.S. soldiers killed in the October 23, 1983, bombing of the U.S. Marine the families of the 241 U.S. soldiers killed in the October 23, 1983, bombing of the U.S. Marine
barracks in Beirut. U.S. funds equivalent to the $400 million balance in the DOD account (see barracks in Beirut. U.S. funds equivalent to the $400 million balance in the DOD account (see
above) have been used to pay a small portion of these judgments. The Algiers Accords apparently above) have been used to pay a small portion of these judgments. The Algiers Accords apparently
precluded compensation for the 52 U.S. diplomats held hostage by Iran from November 1979 precluded compensation for the 52 U.S. diplomats held hostage by Iran from November 1979
until January 1981. The FY2016 Consolidated Appropriation (Section 404 of P.L. 114-113) set up until January 1981. The FY2016 Consolidated Appropriation (Section 404 of P.L. 114-113) set up
a mechanism for paying damages to the U.S. embassy hostages using settlements paid by various a mechanism for paying damages to the U.S. embassy hostages using settlements paid by various
banks for concealing Iran-related transactions, and proceeds from other Iranian frozen assetsbanks for concealing Iran-related transactions, and proceeds from other Iranian frozen assets, including those assets discussed above. .
Other past financial disputes include the errant U.S. shoot-down on July 3, 1988, of an Iranian Other past financial disputes include the errant U.S. shoot-down on July 3, 1988, of an Iranian
Airbus passenger jet (Iran Air flight 655), for which the United States paid Iran $61.8 million in Airbus passenger jet (Iran Air flight 655), for which the United States paid Iran $61.8 million in
compensation ($300,000 per wage-earning victim, $150,000 per non-wage earner) for the 248 compensation ($300,000 per wage-earning victim, $150,000 per non-wage earner) for the 248
Iranians killed. State Department officials told CRS in November 2012 that the United States Iranians killed. State Department officials told CRS in November 2012 that the United States
later arranged to provide a substitute used aircraft to Iran in lieu of paying Iran for the Airbus. later arranged to provide a substitute used aircraft to Iran in lieu of paying Iran for the Airbus.

3 http://www.treasury.gov/resource-center/sanctions/Documents/tar2010.pdf. 3 http://www.treasury.gov/resource-center/sanctions/Documents/tar2010.pdf.
4 For details on these issues, see CRS In Focus IF10341, 4 For details on these issues, see CRS In Focus IF10341, Justice for United States Victims of State Sponsored Terrorism
Act: Eligibility and Funding, by Jennifer K. Elsea; CRS Report RL31258, , by Jennifer K. Elsea; CRS Report RL31258, Suits Against Terrorist States by Victims of
Terrorism, by Jennifer K. Elsea; CRS Legal Sidebar LSB10104, , by Jennifer K. Elsea; CRS Legal Sidebar LSB10104, It Belongs in a Museum: Sovereign Immunity Shields
Iranian Antiquities Even When It Does Not Protect Iran, by Stephen P. Mulligan; and CRS Legal Sidebar LSB10140, , by Stephen P. Mulligan; and CRS Legal Sidebar LSB10140,
Iran’s Central Bank Asks Supreme Court to Consider Whether the Bank’s Assets Abroad are Immune from Attachment
to Satisfy Terror Judgments, by Jennifer K. Elsea. , by Jennifer K. Elsea.
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Executive Order 13599 Impounding Iran-Owned Assets
Executive Order 13599 (February 5, 2012) blocks U.S.-based assets of entities determined to be Executive Order 13599 (February 5, 2012) blocks U.S.-based assets of entities determined to be
“owned or controlled by the Iranian government.” The order was issued to implement Section “owned or controlled by the Iranian government.” The order was issued to implement Section
1245 of the FY2012 National Defense Authorization Act (P.L. 112-81) that imposed secondary 1245 of the FY2012 National Defense Authorization Act (P.L. 112-81) that imposed secondary
U.S. sanctions on Iran’s Central Bank. The order requires that U.S. banks block U.S.-based assets U.S. sanctions on Iran’s Central Bank. The order requires that U.S. banks block U.S.-based assets
of the Central Bank of Iran or any Iranian government-controlled entity. The order goes beyond of the Central Bank of Iran or any Iranian government-controlled entity. The order goes beyond
the regulations issued pursuant to the 1995 imposition of the U.S. trade ban with Iran, in which the regulations issued pursuant to the 1995 imposition of the U.S. trade ban with Iran, in which
U.S. banks are required to refuse such transactions. U.S. banks are required to refuse such transactions.
Numerous designations have been made under Executive Order 13599, including the June 4, Numerous designations have been made under Executive Order 13599, including the June 4,
2013, naming of 38 entities that are components of an Iranian entity called the “Execution of 2013, naming of 38 entities that are components of an Iranian entity called the “Execution of
Imam Khomeini’s Order” (EIKO).5 The Department of the Treasury characterizes EIKO as Imam Khomeini’s Order” (EIKO).5 The Department of the Treasury characterizes EIKO as
controlling “massive off-the-books investments.” controlling “massive off-the-books investments.”
Implementation of the JCPOA. To implement the JCPOA, many 13599-designated entities (in To implement the JCPOA, many 13599-designated entities (in
JCPOA “Attachment 3”) were “delisted” from U.S. secondary sanctions (no longer considered JCPOA “Attachment 3”) were “delisted” from U.S. secondary sanctions (no longer considered
“Specially Designated Nationals,” SDNs) in “Specially Designated Nationals,” SDNs) in ~~early~~ 2016 and instead referred to as “designees 2016 and instead referred to as “designees
blocked solely pursuant to E.O 13599,” a characterization that permits foreign entities to conduct blocked solely pursuant to E.O 13599,” a characterization that permits foreign entities to conduct
transactions with the listed entities but bars U.S. persons from such transactions. In concert with transactions with the listed entities but bars U.S. persons from such transactions. In concert with
the U.S. withdrawal from the JCPOA in 2018, virtually all of the 13599-designated entities were the U.S. withdrawal from the JCPOA in 2018, virtually all of the 13599-designated entities were
relistedrelisted as SDNs on November 5, 2018.6 on November 5, 2018.6
Civilian Nuclear Entity Exception. Among those entities “relisted” as Iranian owned entities were . Among those entities “relisted” as Iranian owned entities were
the Atomic Energy Organization of Iran (AEOI), and 23 of its subsidiaries. However, the the Atomic Energy Organization of Iran (AEOI), and 23 of its subsidiaries. However, the
Administration did not relist these entities as subject to secondary sanctions (SDNs) under E.O. Administration did not relist these entities as subject to secondary sanctions (SDNs) under E.O.
13382, in order to facilitate continued international work with Iran’s permitted civilian nuclear 13382, in order to facilitate continued international work with Iran’s permitted civilian nuclear
program.7 The subsequent ending of most sanctions waivers for nuclear technical assistance to program.7 The subsequent ending of most sanctions waivers for nuclear technical assistance to
Iran prohibits work almost all work with AEOI entities. Iran prohibits work almost all work with AEOI entities.
Sanctions for Iran’s ~~Regional~~Support for Armed Factions
After After ~~about five~~three years during which no U.S. sanctions were imposed on Iran, the United States years during which no U.S. sanctions were imposed on Iran, the United States
imposed sanctions for Iran’s support for imposed sanctions for Iran’s support for ~~regional groups committing~~groups conducting acts of terrorism. The acts of terrorism. The
Secretary of State designated Iran a “state sponsor of terrorism” on January 23, 1984, following Secretary of State designated Iran a “state sponsor of terrorism” on January 23, 1984, following
the October 23, 1983, bombing of the U.S. Marine barracks in Lebanon by elements that later the October 23, 1983, bombing of the U.S. Marine barracks in Lebanon by elements that later
established Lebanese Hezbollah. The designation triggers substantial sanctions. None of the laws established Lebanese Hezbollah. The designation triggers substantial sanctions. None of the laws
or executive orders in this section were waived or revoked to implement the JCPOA, and no or executive orders in this section were waived or revoked to implement the JCPOA, and no
entities discussed in this section were “delisted” from sanctionsentities discussed in this section were “delisted” from sanctions to implement the JCPOA..
Sanctions Triggered by Terrorism List Designation
The U.S. naming of Iran as a “state sponsor of terrorism”—commonly referred to as Iran’s The U.S. naming of Iran as a “state sponsor of terrorism”—commonly referred to as Iran’s
inclusion on the U.S. “terrorism list”—triggers several sanctions. The designation was made inclusion on the U.S. “terrorism list”—triggers several sanctions. The designation was made
under the authority of Section 6(j) of the Export Administration Act of 1979 (P.L. 96-72, as under the authority of Section 6(j) of the Export Administration Act of 1979 (P.L. 96-72, as
amended), sanctioning countries determined to have provided repeated support for acts of amended), sanctioning countries determined to have provided repeated support for acts of
international terrorism. The sanctions triggered by the designation are as follows: international terrorism. The sanctions triggered by the designation are as follows:

5 Department of Treasury. 5 Department of Treasury. Treasury Targets Assets of Iranian Leadership. June 4, 2013. . June 4, 2013.
6 For entities designated under E.O. 13599, see6 For entities designated under E.O. 13599, see: https://www.treasury.gov/ofac/downloads/13599/13599list.pdf. https://www.treasury.gov/ofac/downloads/13599/13599list.pdf.
7 U.S. diplomatic “non-paper” provided to CRS. 7 U.S. diplomatic “non-paper” provided to CRS.
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  Restrictions on sales of U.S. dual use items. The Export Administration Act, as . The Export Administration Act, as
superseded by the Export Control Reform Act of 2018 (in P.L. 115-232), requires superseded by the Export Control Reform Act of 2018 (in P.L. 115-232), requires
a presumption of denial of any license applications to sell dual use items to Iran. a presumption of denial of any license applications to sell dual use items to Iran.
Enforcement is through Export Administration Regulations (EARs) administered Enforcement is through Export Administration Regulations (EARs) administered
by the Bureau of Industry and Security (BIS) of the Commerce Department. by the Bureau of Industry and Security (BIS) of the Commerce Department.
  Ban on direct U.S. financial assistance and arms sales to Iran. Section 620A of . Section 620A of
the Foreign Assistance Act, FAA (P.L. 87-95) and Section 40 of the Arms Export the Foreign Assistance Act, FAA (P.L. 87-95) and Section 40 of the Arms Export
Control Act (P.L. 95-92, as amended) bar U.S. foreign assistance (U.S. Control Act (P.L. 95-92, as amended) bar U.S. foreign assistance (U.S.
government loans, credits, credit guarantees, and Ex-Im Bank loan guarantees) to government loans, credits, credit guarantees, and Ex-Im Bank loan guarantees) to
terrorism list countries. Successive foreign aid appropriations laws since the late terrorism list countries. Successive foreign aid appropriations laws since the late
1980s have banned direct assistance to Iran, with no waiver provisions. Under the 1980s have banned direct assistance to Iran, with no waiver provisions. Under the
FY2012 foreign operations appropriation (Section 7041(c)(2) of P.L. 112-74), the FY2012 foreign operations appropriation (Section 7041(c)(2) of P.L. 112-74), the
Ex-Im Bank cannot finance any entity sanctioned under the Iran Sanctions Act. Ex-Im Bank cannot finance any entity sanctioned under the Iran Sanctions Act.
  Requirement to oppose multilateral lending. U.S. officials are required to use the . U.S. officials are required to use the
country’s “voice and vote” to oppose multilateral lending to any terrorism list country’s “voice and vote” to oppose multilateral lending to any terrorism list
country by Section 1621 of the International Financial Institutions Act (P.L. 95-country by Section 1621 of the International Financial Institutions Act (P.L. 95-
118, as amended [added by Section 327 of the Anti-Terrorism and Effective 118, as amended [added by Section 327 of the Anti-Terrorism and Effective
Death Penalty Act of 1996 (P.L. 104-132)]). The law provides waiver authority, Death Penalty Act of 1996 (P.L. 104-132)]). The law provides waiver authority,
for example to support an international loan in humanitarian circumstances. for example to support an international loan in humanitarian circumstances.
  Withholding of U.S. foreign assistance to countries that assist or sell arms to
terrorism list countries. Under Sections 620G and 620H of the Foreign . Under Sections 620G and 620H of the Foreign
Assistance Act (FAA), as added by Sections 325 and 326 of the Anti-Terrorism Assistance Act (FAA), as added by Sections 325 and 326 of the Anti-Terrorism
and Effective Death Penalty Act of 1996 (P.L. 104-132), the President is required and Effective Death Penalty Act of 1996 (P.L. 104-132), the President is required
to withhold foreign aid from any country that aids or sells arms to a terrorism list to withhold foreign aid from any country that aids or sells arms to a terrorism list
country. Waiver authority is provided. Section 321 of P.L. 104-132 makes it a country. Waiver authority is provided. Section 321 of P.L. 104-132 makes it a
crime for a U.S. person to conduct transactions with terrorism list governments. crime for a U.S. person to conduct transactions with terrorism list governments.
  Withholding of U.S. Aid to Organizations That Assist Iran. Section 307 of the . Section 307 of the
FAA (added in 1985) names Iran as unable to benefit from U.S. contributions to FAA (added in 1985) names Iran as unable to benefit from U.S. contributions to
international organizations, and require proportionate cuts if these institutions international organizations, and require proportionate cuts if these institutions
work in Iran. For example, if an international organization spends 3% of its work in Iran. For example, if an international organization spends 3% of its
budget for programs in Iran, then the United States is required to withhold 3% of budget for programs in Iran, then the United States is required to withhold 3% of
its contribution to that international organization. No waiver option is provided. its contribution to that international organization. No waiver option is provided.

Requirements for Removal from Terrorism List
Terminating the sanctions triggered by Iran’s terrorism list designation would require Iran’s removal from the Terminating the sanctions triggered by Iran’s terrorism list designation would require Iran’s removal from the
terrorism list. The Arms Export Control Act defines two different requirements for a President to remove a terrorism list. The Arms Export Control Act defines two different requirements for a President to remove a
country from the list, depending on whether the country’s regime has changed. country from the list, depending on whether the country’s regime has changed.
If the country’s regime has changed: the President can remove a country from the list immediately by certifying that the President can remove a country from the list immediately by certifying that
regime change in a report to Congress. regime change in a report to Congress.
If the country’s regime has not changed: the President must report to Congress 45 days in advance of the effective the President must report to Congress 45 days in advance of the effective
date of removal. The President must certify that (1) the country has not supported international terrorism within date of removal. The President must certify that (1) the country has not supported international terrorism within
the preceding six months, and (2) the country has provided assurances it the preceding six months, and (2) the country has provided assurances it ~~wil~~ will not do so in the future. In this latter not do so in the future. In this latter
circumstance, Congress has the opportunity to block the removal by enacting a joint resolution to that effect. The circumstance, Congress has the opportunity to block the removal by enacting a joint resolution to that effect. The
President has the option of vetoing the joint resolution, and blocking the removal then requires a veto override. President has the option of vetoing the joint resolution, and blocking the removal then requires a veto override.
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Exception for U.S. Humanitarian Aid
The terrorism list designation, as well as virtually all other U.S. sanctions laws, do not bar U.S. The terrorism list designation, as well as virtually all other U.S. sanctions laws, do not bar U.S.
humanitarian aid to Iran. The United States donated $125,000, through relief agencies, to help humanitarian aid to Iran. The United States donated $125,000, through relief agencies, to help
victims of two earthquakes in Iran in 1997; $350,000 worth of aid to the victims of a June 2002, victims of two earthquakes in Iran in 1997; $350,000 worth of aid to the victims of a June 2002,
earthquake; and $5.7 million in assistance for victims of the December 2003 earthquake in Bam, earthquake; and $5.7 million in assistance for victims of the December 2003 earthquake in Bam,
Iran. The U.S. military flew 68,000 kilograms of supplies to Bam. The Trump Administration Iran. The U.S. military flew 68,000 kilograms of supplies to Bam. The Trump Administration ~~has~~
offered Iran assistance, via the World Health Organization, to help it battle the COVID-19 offered Iran assistance, via the World Health Organization, to help it battle the COVID-19
outbreak in early 2020, but, Iran refused the aid. outbreak in early 2020, but, Iran refused the aid.
Sanctions on States “Not Cooperating” Against Terrorism
Section 40A to the Arms Export Control Act (added by Section 330 of the Anti-Terrorism and Section 40A to the Arms Export Control Act (added by Section 330 of the Anti-Terrorism and
Effective Death Penalty Act [P.L. 104-132]) prohibits the sale or licensing of U.S. defense articles Effective Death Penalty Act [P.L. 104-132]) prohibits the sale or licensing of U.S. defense articles
and services to any country designated (by each May 15) as “not cooperating fully with U.S. anti-and services to any country designated (by each May 15) as “not cooperating fully with U.S. anti-
terrorism efforts.” The President can waive the provision upon determining that a defense sale is terrorism efforts.” The President can waive the provision upon determining that a defense sale is
“important to the national interests” of the United States. Every year since this provision was “important to the national interests” of the United States. Every year since this provision was
enacted (April 1996), Iran has been designated as a country that is “not fully cooperating” with enacted (April 1996), Iran has been designated as a country that is “not fully cooperating” with
U.S. antiterrorism efforts. However, the provision is largely redundant with other laws. U.S. antiterrorism efforts. However, the provision is largely redundant with other laws.
Executive Order 13224 Sanctioning Terrorism-Supporting Entities
Executive Order 13324 (September 23, 2001)8 mandates the freezing of the U.S.-based assets of, Executive Order 13324 (September 23, 2001)8 mandates the freezing of the U.S.-based assets of,
and a ban on U.S. transactions with, entities determined by the Administration to be supporting and a ban on U.S. transactions with, entities determined by the Administration to be supporting
international terrorism. E.O. 13224, issued after the September 11, 2001, attacks on the United international terrorism. E.O. 13224, issued after the September 11, 2001, attacks on the United
States, targeted Al Qaeda, but it has subsequently been used to sanction Iran. On September 10, States, targeted Al Qaeda, but it has subsequently been used to sanction Iran. On September 10,
2019, the 2019, the Trump Administration amended E.O. 13224 to authorize barring from the U.S. financial system Administration amended E.O. 13224 to authorize barring from the U.S. financial system
any foreign bank determined to have “conducted or facilitated any significant transaction” with any foreign bank determined to have “conducted or facilitated any significant transaction” with
~~any person or entity designated under the order.9~~
~~CAATSA Application to the Islamic Revolutionary Guard Corps (IRGC)~~
~~Section 105 of the Countering America’s Adversaries through Sanctions Act (CAATSA, P.L. 115-~~
~~44, August 2, 2017), mandates the imposition of E.O. 13324 penalties on the IRGC and its~~
~~officials, agents, and affiliates by October 30, 2017 (90 days after enactment). The Treasury~~
~~Department designated the IRGC under E.O. 13224 on October 13, 2017.~~
any person or entity designated under the order.9 Implementation of E.O. 13224
Successive Administrations have used the Successive Administrations have used the ~~Order~~order to sanction Iran-related entities, including to sanction Iran-related entities, including
members of Iran-allied organizations that finance or facilitate Iran’s regional interventions. The members of Iran-allied organizations that finance or facilitate Iran’s regional interventions. The
Trump Administration has used the Trump Administration has used the ~~Order~~order to sanction Iranian economic entities that furnish funds to sanction Iranian economic entities that furnish funds
for the Islamic Revolutionary Guard Corps (IRGC) and its regional activities. In part because of for the Islamic Revolutionary Guard Corps (IRGC) and its regional activities. In part because of
the inter-agency process required to conclude that an entity is no longer involved in terrorism, no the inter-agency process required to conclude that an entity is no longer involved in terrorism, no
entities designated under E.O. 13224 were delisted to implement the JCPOA. The Iran-related entities designated under E.O. 13224 were delisted to implement the JCPOA. The Iran-related
entities designated under the order are shown in the tables later in the report. entities designated under the order are shown in the tables later in the report.
CAATSA Application to the Islamic Revolutionary Guard Corps (IRGC) Section 105 of the Countering America’s Adversaries through Sanctions Act (CAATSA, P.L. 115-44, August 2, 2017), mandated the imposition of E.O. 13324 penalties on the IRGC and its officials, agents, and affiliates by October 30, 2017. The Treasury Department designated the IRGC under E.O. 13224 on October 13, 2017.
8 The Order was issued under the authority of the IEEPA, the National Emergencies Act, the U.N. Participation Act of 8 The Order was issued under the authority of the IEEPA, the National Emergencies Act, the U.N. Participation Act of
1945, and Section 301 of the U.S. Code. 1945, and Section 301 of the U.S. Code.
9 For text of the amendments to the Order, see https://www.whitehouse.gov/presidential-actions/executive-order- 9 For text of the amendments to the Order, see https://www.whitehouse.gov/presidential-actions/executive-order-
modernizing-sanctions-combat-terrorism/ modernizing-sanctions-combat-terrorism/
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Foreign Terrorist Organization (FTO) Designations
The State Department has authority under Section 219 of the Immigration and Nationality Act The State Department has authority under Section 219 of the Immigration and Nationality Act
(8.U.S.C. 1189) to designate an entity as a Foreign Terrorist Organization (FTO). The designation (8.U.S.C. 1189) to designate an entity as a Foreign Terrorist Organization (FTO). The designation
carries penalties similar to those of E.O. 13224, but also subjects any U.S. person (or person carries penalties similar to those of E.O. 13224, but also subjects any U.S. person (or person
under U.S. jurisdiction) who “knowingly provides material support or resources to an FTO, or under U.S. jurisdiction) who “knowingly provides material support or resources to an FTO, or
attempts or conspires to do so to “fine or up to 20 years in prison.” A bank that commits such a attempts or conspires to do so to “fine or up to 20 years in prison.” A bank that commits such a
violation is subject to fines. violation is subject to fines.
Implementation: The following organizations have been designated as FTOs for acts of terrorism The following organizations have been designated as FTOs for acts of terrorism
on behalf of Iran or are organizations assessed as funded and supported by Iran: on behalf of Iran or are organizations assessed as funded and supported by Iran:
  Islamic Revolutionary Guard Corps (IRGC). Designated April 8, 2019. On Designated April 8, 2019. On
April 22, 2019, the State Department guidelines for implementing the designation April 22, 2019, the State Department guidelines for implementing the designation
indicating that it would not penalize routine diplomatic or humanitarian-related indicating that it would not penalize routine diplomatic or humanitarian-related
dealings with the IRGC by U.S. partner countries or nongovernmental entities.10 dealings with the IRGC by U.S. partner countries or nongovernmental entities.10
  Lebanese Hezbollah..
  Iraqi Militias: Kata’ib Hezbollah (KAH) and Asa’ib Ahl Al Haq (AAH, ~~Kata’ib Hezbollah (KAH). Iran-backed Iraqi Shi’a militia.~~
~~ Asa’ib Ahl Al Haq (AAH). Iran-backed Iraqi Shi’a militia (designated Jan. 3,~~
~~2020)~~
designated Jan. 3, 2020).   Hamas. Sunni, Islamist Palestinian organization that essentially controls the . Sunni, Islamist Palestinian organization that essentially controls the
Gaza Strip. Gaza Strip.
  Palestine Islamic Jihad. Small Sunni Islamist Palestinian militant group. . Small Sunni Islamist Palestinian militant group.
  Al Aqsa Martyr’s Brigade. Secular Palestinian militant group.
 ~~Popular~~ Non-Islamist Palestinian Groups: Al Aqsa Martyr’s Brigade, and Popular Front for the Liberation of Palestine-General Command (PFLP- (PFLP-
~~GC). Leftwing secular Palestinian group based mainly in Syria.~~
GC).   Al Ashtar Brigades. Bahrain militant opposition group. . Bahrain militant opposition group.
Another group, Ansarallah (Houthis) is an Iran- backed insurgent movement in Yemen. It was designated as an FTO on January 10, 2021, but the designation as FTO was revoked by Biden Administration on February 16, 2021. Other Sanctions on Iran’s Support for Regional Armed Factions
Some sanctions have been imposed to try to curtail Iran’s destabilizing influence in the region. Some sanctions have been imposed to try to curtail Iran’s destabilizing influence in the region.
Executive Order 13438 on Threats to Iraq’s Stability
 The July 7, 2007  The July 7, 2007 ~~Order~~, order blocks U.S.-based property of persons determined to blocks U.S.-based property of persons determined to
“have committed, or pose a significant risk of committing” acts of violence that “have committed, or pose a significant risk of committing” acts of violence that
threaten the peace and stability of Iraq or that undermine efforts to promote threaten the peace and stability of Iraq or that undermine efforts to promote
economic reconstruction or political reform in Iraq. Persons sanctioned, to date, economic reconstruction or political reform in Iraq. Persons sanctioned, to date,
include IRGC-Qods Force officers, Iraqi Shiite militia-linked figures, and other include IRGC-Qods Force officers, Iraqi Shiite militia-linked figures, and other
entities, some of which are prominent roles in Iraq’s parliament and politics. entities, some of which are prominent roles in Iraq’s parliament and politics.
Executive Order 13572 on Repression of the Syrian People.
 The April 29, 2011  The April 29, 2011 ~~Order~~, order blocks the U.S.-based property of persons determined blocks the U.S.-based property of persons determined
to be responsible for repression of the Syrian people. The IRGC-Qods Force to be responsible for repression of the Syrian people. The IRGC-Qods Force
(IRGC-QF), IRGC-QF commanders, and others are sanctioned under this order. (IRGC-QF), IRGC-QF commanders, and others are sanctioned under this order.

10 “Exclusive: U.S. Carves out Exceptions for Foreigners Dealing with Revolutionary Guards.” 10 “Exclusive: U.S. Carves out Exceptions for Foreigners Dealing with Revolutionary Guards.” Reuters, April 21, 2019. , April 21, 2019.
See CRS Insight IN11093, See CRS Insight IN11093, Iran’s Revolutionary Guard Named a Terrorist Organization, by Kenneth Katzman. , by Kenneth Katzman.
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Hezbollah-Specific Financial Sanctions
 The Hizballah International Financing Prevention Act (P.L. 114-102) and  The Hizballah International Financing Prevention Act (P.L. 114-102) and
Hizballah International Financing Prevention Amendments Act of 2018 (P.L. Hizballah International Financing Prevention Amendments Act of 2018 (P.L.
115-272). The latter Act was signed on October 23, 2018, the 25th anniversary of 115-272). The latter Act was signed on October 23, 2018, the 25th anniversary of
the Marine barracks bombing in Beirut. The original law, modeled on the 2010 the Marine barracks bombing in Beirut. The original law, modeled on the 2010
Comprehensive Iran Sanctions, Accountability, and Divestment Act (“CISADA,” Comprehensive Iran Sanctions, Accountability, and Divestment Act (“CISADA,”
see below), excludes from the U.S. financial system any bank that conducts see below), excludes from the U.S. financial system any bank that conducts
transactions with Hezbollah or its affiliates. The 2018 amendment also authorizes transactions with Hezbollah or its affiliates. The 2018 amendment also authorizes
the blocking of U.S.-based property of and U.S. transactions with any “agency or the blocking of U.S.-based property of and U.S. transactions with any “agency or
instrumentality of a foreign state” that conducts joint operations with or provides instrumentality of a foreign state” that conducts joint operations with or provides
financing or arms to Lebanese Hezbollah – an apparent reference to Iran. financing or arms to Lebanese Hezbollah – an apparent reference to Iran.
Ban on U.S. Trade and Investment with Iran
In 1995, the Clinton Administration issued Executive Order 12959 (May 6, 1995) banning U.S. In 1995, the Clinton Administration issued Executive Order 12959 (May 6, 1995) banning U.S.
trade with and investment in Iran. 11 It superseded and broadened Executive Order 12957, which trade with and investment in Iran. 11 It superseded and broadened Executive Order 12957, which
was issued two months earlier (March 15, 1995), barring U.S. investment in Iran’s energy sector. was issued two months earlier (March 15, 1995), barring U.S. investment in Iran’s energy sector.
The March 1995 order accompanied President Clinton’s declaration of a “state of emergency” The March 1995 order accompanied President Clinton’s declaration of a “state of emergency”
with respect to Iran. E.O 13059 (August 19, 1997) added a prohibition on U.S. companies’ with respect to Iran. E.O 13059 (August 19, 1997) added a prohibition on U.S. companies’
knowingly exporting goods to a third country for incorporation into products destined for Iran. knowingly exporting goods to a third country for incorporation into products destined for Iran.
Each March since 1995, the Administration has renewed the “state of emergency.” Each March since 1995, the Administration has renewed the “state of emergency.”
Section 103 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 Section 103 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
(CISADA, P.L. 111-195) codified the trade ban and reinstated the full ban on imports that had (CISADA, P.L. 111-195) codified the trade ban and reinstated the full ban on imports that had
earlier been relaxed by April 2000 regulations. That relaxation allowed importation into the earlier been relaxed by April 2000 regulations. That relaxation allowed importation into the
United States of Iranian nuts, fruit products (such as pomegranate juice), carpets, and caviar.12 United States of Iranian nuts, fruit products (such as pomegranate juice), carpets, and caviar.12
Section 101 of the Iran Freedom Support Act (P.L. 109-293) codified the ban on U.S. investment Section 101 of the Iran Freedom Support Act (P.L. 109-293) codified the ban on U.S. investment
in Iran, but gave the President authority to terminate this sanction with notification to Congress. in Iran, but gave the President authority to terminate this sanction with notification to Congress.
JCPOA-Related Easing and Subsequent Reversal. In accordance with the JCPOA, the ban on In accordance with the JCPOA, the ban on
U.S. importation of the Iranian luxury goods discussed above (carpets, caviar, nuts, etc.) was U.S. importation of the Iranian luxury goods discussed above (carpets, caviar, nuts, etc.) was
again relaxed, but general U.S.-Iran trade remained prohibited. Non-sanctioned Iranian airlines again relaxed, but general U.S.-Iran trade remained prohibited. Non-sanctioned Iranian airlines
Iran was also permitted to buy U.S. commercial aircraft.13 The Trump Administration restored the Iran was also permitted to buy U.S. commercial aircraft.13 The Trump Administration restored the
ban on importation of Iranian carpets and other luxury goods, effective August 6, 2018ban on importation of Iranian carpets and other luxury goods, effective August 6, 2018~~, in~~
~~implementing the pullout from the JCPOA.~~
.
11 The executive order was issued not only under the authority of International Emergency Economic Powers Act 11 The executive order was issued not only under the authority of International Emergency Economic Powers Act
(IEEPA, 50 U.S.C. 1701 et seq.(IEEPA, 50 U.S.C. 1701 et seq. (IEEPA) but also the National Emergencies Act (50 U.S.C. 1601 et seq.; §505 of the (IEEPA) but also the National Emergencies Act (50 U.S.C. 1601 et seq.; §505 of the
International Security and Development Cooperation Act of 1985 (22 U.S.C. 2349aa-9) and §301 of Title 3, International Security and Development Cooperation Act of 1985 (22 U.S.C. 2349aa-9) and §301 of Title 3, United
States Code. IEEPA gives the President wide powers to regulate commerce with a foreign country when a ”state of . IEEPA gives the President wide powers to regulate commerce with a foreign country when a ”state of
emergency” is declared in relations with that country, and to alter regulations to license transactions with Iran—emergency” is declared in relations with that country, and to alter regulations to license transactions with Iran—
regulations enumerated in Section 560 of the Code of Federal Regulations (Iranian Transactions Regulations, ITRs). regulations enumerated in Section 560 of the Code of Federal Regulations (Iranian Transactions Regulations, ITRs).
12 Imports were mainly of artwork for exhibitions around the United States, which are counted as imports even though 12 Imports were mainly of artwork for exhibitions around the United States, which are counted as imports even though
the works return to Iran after the exhibitions conclude. the works return to Iran after the exhibitions conclude.
13 The text of the guidance is at https://www.treasury.gov/resource-center/sanctions/Programs/Documents/ 13 The text of the guidance is at https://www.treasury.gov/resource-center/sanctions/Programs/Documents/
implement_guide_jcpoa.pdf. implement_guide_jcpoa.pdf.
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What U.S.-Iran Trade Is Allowed or Prohibited?
The following provisions apply to the U.S. trade ban on Iran as specified in regulations (Iran The following provisions apply to the U.S. trade ban on Iran as specified in regulations (Iran
Transaction Regulations, ITRs) pursuant to the orders and laws discussed above. The regulations Transaction Regulations, ITRs) pursuant to the orders and laws discussed above. The regulations
are administered by the Treasury Department’s Office of Foreign Assets Control (OFAC). are administered by the Treasury Department’s Office of Foreign Assets Control (OFAC).
  Energy Transactions. U.S. . U.S. energy-related transactions with Iran transactions with Iran ~~in energy products~~ are banned. are banned.
The ~~The~~ 1995 trade ban (E.O. 12959) expanded a 1987 ban on imports from Iran that 1995 trade ban (E.O. 12959) expanded a 1987 ban on imports from Iran that
was imposed by Executive Order 12613 of October 29, 1987, which was was imposed by Executive Order 12613 of October 29, 1987, which was
authorized by Section 505 of the International Security and Development authorized by Section 505 of the International Security and Development
Cooperation Act of 1985 (22 U.S.C. 2349aa-9). The 1987 Cooperation Act of 1985 (22 U.S.C. 2349aa-9). The 1987 ~~Order~~order barred the barred the
importation of Iranian oil into the United States but did not ban the trading of importation of Iranian oil into the United States but did not ban the trading of
Iranian oil overseas. The 1995 ban Iranian oil overseas. The 1995 ban ~~prohibits that~~ prohibited that overseas trading activity explicitly, but activity explicitly, but ~~provides~~
provided for U.S. companies to apply for licenses to conduct “swaps” of Caspian Sea oil for U.S. companies to apply for licenses to conduct “swaps” of Caspian Sea oil
with Iran. These swaps have been prohibited in practice, including the denial of a with Iran. These swaps have been prohibited in practice, including the denial of a
Mobil Corporation application to do so in April 1999. Mobil Corporation application to do so in April 1999. The regulations do not ban
the importation, from foreign refiners, of gasoline or other energy products in
which Iranian oil is mixed with oil from other producers, because such refined oil
is considered to be a product of the country where it is refined.
  Transshipment and Brokering. The regulations prohibit U.S. transshipment of . The regulations prohibit U.S. transshipment of
prohibited goods across Iran, and ban any activities by U.S. persons to broker prohibited goods across Iran, and ban any activities by U.S. persons to broker
commercial transactions involving Iran. commercial transactions involving Iran.
  Shipping Insurance. Iran requires shipping insurance in order to transport its . Iran requires shipping insurance in order to transport its
exports. A pool of 13 major insurance organizations, called the International exports. A pool of 13 major insurance organizations, called the International
Group of P & I (Property and Indemnity) Clubs, dominates the shipping Group of P & I (Property and Indemnity) Clubs, dominates the shipping
insurance industry and is based in New York. The U.S. location of this pool insurance industry and is based in New York. The U.S. location of this pool
renders it subject to the U.S. trade ban, but waivers of Sections 212 and 213 of renders it subject to the U.S. trade ban, but waivers of Sections 212 and 213 of
the Iran Threat Reduction and Syria Human Rights Act (ITRSHRA) were issued the Iran Threat Reduction and Syria Human Rights Act (ITRSHRA) were issued
to enable numerous insurers to give Iranian ships insurance during to enable numerous insurers to give Iranian ships insurance during ~~the period of~~
U.S. implementation of the JCPOA.14 This waiver ended on August 6, 2018. U.S. implementation of the JCPOA.14 This waiver ended on August 6, 2018.
  Civilian Airline Sales. . ~~The regulations~~Regulations have always permitted the licensing of have always permitted the licensing of
goods goods related to the safe operation of civilian aircraft for sale to Iranrelated to the safe operation of civilian aircraft for sale to Iran, and spare and spare
parts sales have been licensed periodically.15 However, from June 2011 until parts sales have been licensed periodically.15 However, from June 2011 until
JCPOA implementation in 2016, Iran’s largest state-owned airline, Iran Air, as JCPOA implementation in 2016, Iran’s largest state-owned airline, Iran Air, as
well as other Iranian airlines were sanctioned under Executive Order 13382 and well as other Iranian airlines were sanctioned under Executive Order 13382 and
13224, rendering sales of spare parts impermissible. In accordance with the 13224, rendering sales of spare parts impermissible. In accordance with the
JCPOA, the United States relaxed restrictions to allow for the sale to Iran of JCPOA, the United States relaxed restrictions to allow for the sale to Iran of
finished commercial aircraft, including to Iran Air, which was “delisted” from finished commercial aircraft, including to Iran Air, which was “delisted” from
sanctions.16 A March 2016 general license was issued to permit those sales. Pre-sanctions.16 A March 2016 general license was issued to permit those sales. Pre-
existing licensing restrictions went back into effect on August 6, 2018. Sales of existing licensing restrictions went back into effect on August 6, 2018. Sales of
some
14 Shipping insurers granted the waiver included Assuranceforeningen Skuld, Skuld Mutual Protection and Indemnity 14 Shipping insurers granted the waiver included Assuranceforeningen Skuld, Skuld Mutual Protection and Indemnity
Association, Ltd. (Bermuda), Gard P and I Ltd. (Bermuda), Assuranceforeningen Gard, the Britannia Steam Ship Association, Ltd. (Bermuda), Gard P and I Ltd. (Bermuda), Assuranceforeningen Gard, the Britannia Steam Ship
Insurance Association Limited, The North of England Protecting and Indemnity Association Ltd., the Shipowners’ Insurance Association Limited, The North of England Protecting and Indemnity Association Ltd., the Shipowners’
Mutual Protection and Indemnity Association (Luxembourg), the Standard Club Ltd., the Standard Club Europe Ltd., Mutual Protection and Indemnity Association (Luxembourg), the Standard Club Ltd., the Standard Club Europe Ltd.,
The Standard Club Asia, the Steamship Mutual Underwriting Association Ltd. (Bermuda), the Swedish Club, United The Standard Club Asia, the Steamship Mutual Underwriting Association Ltd. (Bermuda), the Swedish Club, United
Kingdom Mutual Steam Ship Assurance Association Ltd. (Bermuda), United Kingdom Mutual Steam Ship Association Kingdom Mutual Steam Ship Assurance Association Ltd. (Bermuda), United Kingdom Mutual Steam Ship Association
Ltd. (Europe), and the West of England Ship Owners Mutual Insurance Association (Luxembourg). Ltd. (Europe), and the West of England Ship Owners Mutual Insurance Association (Luxembourg).
15 (§560.528 of Title 31, C.F.R.), 15 (§560.528 of Title 31, C.F.R.),
16 “Exclusive: Boeing Says Gets U.S. License to Sell Spare Parts to Iran,” 16 “Exclusive: Boeing Says Gets U.S. License to Sell Spare Parts to Iran,” Reuters, April 4, 2014. , April 4, 2014.
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~~some~~ aircraft spare parts (“dual use items”) to Iran also require a waiver of the aircraft spare parts (“dual use items”) to Iran also require a waiver of the
relevant provision of the Iran-Iraq Arms Non-Proliferation Act, discussed below. relevant provision of the Iran-Iraq Arms Non-Proliferation Act, discussed below.
  Personal Communications, Remittances, and Publishing. The ITRs permit . The ITRs permit
personal communications (phone calls, emails) between the United States and personal communications (phone calls, emails) between the United States and
Iran, personal remittances to Iran, and Americans to engage in publishing Iran, personal remittances to Iran, and Americans to engage in publishing
activities with entities in Iranactivities with entities in Iran ~~(and Cuba and Sudan)~~. .
  Information Technology Equipment. CISADA exempts from the U.S. ban on CISADA exempts from the U.S. ban on
exports to Iran information technology to support personal communications exports to Iran information technology to support personal communications
among the Iranian people and goods for supporting democracy in Iran. In May among the Iranian people and goods for supporting democracy in Iran. In May
2013, OFAC issued a general license for the exportation to Iran of goods (such as 2013, OFAC issued a general license for the exportation to Iran of goods (such as
cell phones) and services, on a fee basis, that enhance the ability of the Iranian cell phones) and services, on a fee basis, that enhance the ability of the Iranian
people to access communication technology. people to access communication technology.
  Food and Medical Exports. Since April 1999, Since April 1999, ~~sales to Iran by U.S. firms~~regulations have permitted U.S. sales to Iran of food ~~of food~~
and medical products (humanitarian items)and medical products (humanitarian items) ~~have been generally permitted,~~
~~although in many cases a specific license issued by OFAC is required~~. In October . In October
2012, OFAC permitted the sale to Iran of specified medical products, such as 2012, OFAC permitted the sale to Iran of specified medical products, such as
scalpels, prosthetics, canes, burn dressings, and other products, that could be sold scalpels, prosthetics, canes, burn dressings, and other products, that could be sold
to Iran under “general license” (no specific license required). This list of general to Iran under “general license” (no specific license required). This list of general
license items license items ~~list~~ was expanded in 2013 and 2016 to include more sophisticated was expanded in 2013 and 2016 to include more sophisticated
medical diagnostic machines and other medical equipment. medical diagnostic machines and other medical equipment. ~~Licenses~~Special licenses for exports for exports
of medical products not on the general license list are routinely expedited for sale of medical products not on the general license list are routinely expedited for sale
to Iran, according to OFAC. The regulations have a specific definition of “food” to Iran, according to OFAC. The regulations have a specific definition of “food”
that can be sold to Iran (excludes alcohol, cigarettes, gum, or fertilizer). that can be sold to Iran (excludes alcohol, cigarettes, gum, or fertilizer).
  Humanitarian and Related Services. Donations by U.S. residents directly to . Donations by U.S. residents directly to
Iranians (such as packages of food, toys, clothes, etc.) are permitted, but U.S. Iranians (such as packages of food, toys, clothes, etc.) are permitted, but U.S.
relief organizations operating in Iran are required to obtain a specific OFAC relief organizations operating in Iran are required to obtain a specific OFAC
license to work there. On September 10, 2013, General License E was issued that license to work there. On September 10, 2013, General License E was issued that
allows relief organizations to conduct activities (up to a value of $500,000 in one allows relief organizations to conduct activities (up to a value of $500,000 in one
year) without a specific licensing requirement, including (1) providing Iran year) without a specific licensing requirement, including (1) providing Iran
services for health projects, disaster relief, wildlife conservation; (2) conducting services for health projects, disaster relief, wildlife conservation; (2) conducting
human rights projects there; or (3) undertaking activities related to sports human rights projects there; or (3) undertaking activities related to sports
matches and events. The policy allows importation from Iran of services related matches and events. The policy allows importation from Iran of services related
to sporting activities, including sponsorship of players, coaching, referees, and to sporting activities, including sponsorship of players, coaching, referees, and
training. In the cases of earthquakes in Iran in 2003 and the 2012, OFAC has training. In the cases of earthquakes in Iran in 2003 and the 2012, OFAC has
issued blanket temporary general licensing for relief work in Iran. issued blanket temporary general licensing for relief work in Iran.
  Payment Methods, Trade Financing, and Financing Guarantees. U.S. importers . U.S. importers
are allowed to pay Iranian exporters for approved imports, but the payment are allowed to pay Iranian exporters for approved imports, but the payment
cannot go directly to Iranian banks, and must instead pass through third-country cannot go directly to Iranian banks, and must instead pass through third-country
banks. Regulations provide that transactions that are banks. Regulations provide that transactions that are incidental to an approved to an approved
transaction are allowed, meaning that financing (“letter of credit”) for approved transaction are allowed, meaning that financing (“letter of credit”) for approved
transactions are normally approved (as long as there is no involvement of an transactions are normally approved (as long as there is no involvement of an
Iranian bank).17 Title IX of the Trade Sanctions Reform and Export Enhancement Iranian bank).17 Title IX of the Trade Sanctions Reform and Export Enhancement
Act of 2000 (P.L. 106-387) bans the use of official credit guarantees (such as the Act of 2000 (P.L. 106-387) bans the use of official credit guarantees (such as the
Ex-Im Bank) for food and medical sales to Iran and other countries on the U.S. Ex-Im Bank) for food and medical sales to Iran and other countries on the U.S.
terrorism list, except Cuba, although allowing for a presidential waiver to permit terrorism list, except Cuba, although allowing for a presidential waiver to permit

17 Text of 31 CFR 598.405: Transactions incidental to a licensed transaction. Any transaction ordinarily incident to a 17 Text of 31 CFR 598.405: Transactions incidental to a licensed transaction. Any transaction ordinarily incident to a
licensed transaction and necessary to give effect to the licensed transaction is also authorized by the license. licensed transaction and necessary to give effect to the licensed transaction is also authorized by the license.
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such credit guarantees. The Ex-Im Bank is prohibited from guaranteeing any such credit guarantees. The Ex-Im Bank is prohibited from guaranteeing any
loans to Iran because of Iran’s presence on the terrorism list. loans to Iran because of Iran’s presence on the terrorism list.
Application to Foreign Subsidiaries of U.S. Firms
The regulations do not ban foreign subsidiaries of U.S. firms from dealing with Iran, as long as The regulations do not ban foreign subsidiaries of U.S. firms from dealing with Iran, as long as
the subsidiary is not “controlled” by the parent company. Most foreign subsidiaries are legally the subsidiary is not “controlled” by the parent company. Most foreign subsidiaries are legally
considered foreign persons subject to the laws of the country in which the subsidiaries are considered foreign persons subject to the laws of the country in which the subsidiaries are
incorporated. Section 218 of the Iran Threat Reduction and Syrian Human Rights Act incorporated. Section 218 of the Iran Threat Reduction and Syrian Human Rights Act
(ITRSHRA, P.L. 112-158) holds “controlled” foreign subsidiaries of U.S. companies to the same (ITRSHRA, P.L. 112-158) holds “controlled” foreign subsidiaries of U.S. companies to the same
standards as U.S. parent firms, defining a controlled subsidiary as (1) one that is more than 50% standards as U.S. parent firms, defining a controlled subsidiary as (1) one that is more than 50%
owned by the U.S. parent; (2) one in which the parent firm holds a majority on the Board of owned by the U.S. parent; (2) one in which the parent firm holds a majority on the Board of
Directors of the subsidiary; or (3) one in which the parent firm directs the operations of the Directors of the subsidiary; or (3) one in which the parent firm directs the operations of the
subsidiary. There is no waiver provision. The President has authority under IEEPA to license subsidiary. There is no waiver provision. The President has authority under IEEPA to license
transactions with Iran, the ITRSHRA notwithstanding. transactions with Iran, the ITRSHRA notwithstanding.
During the U.S. implementation of the JCPOA, the United States licensed “controlled” foreign During the U.S. implementation of the JCPOA, the United States licensed “controlled” foreign
subsidiaries to conduct transactions with Iran through “General License H: Authorizing Certain subsidiaries to conduct transactions with Iran through “General License H: Authorizing Certain
Transactions Relating to Foreign Entities Owned or Controlled by a United States Person.”18 The Transactions Relating to Foreign Entities Owned or Controlled by a United States Person.”18 The
Trump Administration revoked General License H and restored the pre-JCPOA licensing policy Trump Administration revoked General License H and restored the pre-JCPOA licensing policy
(“Statement of Licensing Policy,” SLP) on November 6, 2018. (“Statement of Licensing Policy,” SLP) on November 6, 2018.
Trade Ban Easing and Termination
Termination: Section 401 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 Section 401 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
(CISADA, P.L. 111-195) provides for the President to terminate the trade ban if the Administration certifies to (CISADA, P.L. 111-195) provides for the President to terminate the trade ban if the Administration certifies to
Congress that Iran no longer satisfies the requirements to be designated as a state sponsor of terrorism and that Congress that Iran no longer satisfies the requirements to be designated as a state sponsor of terrorism and that
Iran has ceased pursuing and has dismantled its nuclear, biological, and chemical weapons and ballistic missiles and Iran has ceased pursuing and has dismantled its nuclear, biological, and chemical weapons and ballistic missiles and
related launch technology. The trade ban provision in CISADA could be repealed by congressional action. related launch technology. The trade ban provision in CISADA could be repealed by congressional action.
Waiver Authority: Section 103(b)(vi) of CISADA allows the President to license exports to Iran if he Section 103(b)(vi) of CISADA allows the President to license exports to Iran if he
determines that doing so is in the national interest of the United States. There is no similar provision in CISADA determines that doing so is in the national interest of the United States. There is no similar provision in CISADA
to ease the ban on U.S. imports from Iran. to ease the ban on U.S. imports from Iran.
Sanctions on Iran’s Energy Sector19
In 1996, Congress and the executive branch began to In 1996, Congress and the executive branch began to economically pressure Iran’s energy sectorpressure Iran’s energy sector through secondary sanctions, with the stated , with the stated
aim of denying Iran the financial resources to support terrorist organizations and aim of denying Iran the financial resources to support terrorist organizations and ~~other armed~~
~~factions or~~ to further its nuclear and WMD programs. Iran’s oil sector is as old as the petroleum to further its nuclear and WMD programs. Iran’s oil sector is as old as the petroleum
industry itself (early 20th century), and Iran’s onshore oil fields are in need of substantial industry itself (early 20th century), and Iran’s onshore oil fields are in need of substantial
investment.20 Since 2011, Iran has been reducing its dependence on oil and gas revenues, to the investment.20 Since 2011, Iran has been reducing its dependence on oil and gas revenues, to the
point where Iran’s 2020-2021 budget point where Iran’s 2020-2021 budget ~~assumes~~assumed minimal revenue from oil sales.21 minimal revenue from oil sales.21

18 The text of General License H can be found at Treasury Department: Archive of Revoked and Expired General 18 The text of General License H can be found at Treasury Department: Archive of Revoked and Expired General
Licenses. https://www.treasury.gov/resource-center/sanctions/Pages/general_license_archive.aspx#iran Licenses. https://www.treasury.gov/resource-center/sanctions/Pages/general_license_archive.aspx#iran
19 The 19 The Federal Register (Volume 77, Number 219) “Policy Guidance” defines what products and chemicals constitute (Volume 77, Number 219) “Policy Guidance” defines what products and chemicals constitute
“petroleum,” “petroleum products,” and “petrochemical products” that are used in the laws and executive orders “petroleum,” “petroleum products,” and “petrochemical products” that are used in the laws and executive orders
discussed throughout the report. See http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-27642.pdf. discussed throughout the report. See http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-27642.pdf.
20 Basic data on Iran’s energy sector, including reserves, exports, pipeline projects, and related issues can be found in 20 Basic data on Iran’s energy sector, including reserves, exports, pipeline projects, and related issues can be found in:
Energy Information Agency. Energy Information Agency. Background Reference: Iran. January 7 2019. . January 7 2019.
21 “Iran outlines budget to resist U.S. sanctions as oil exports plunge.” 21 “Iran outlines budget to resist U.S. sanctions as oil exports plunge.” Reuters, December 7, 2019. , December 7, 2019.
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No U.S. sanction requires any country or person to actually seize, intercept, inspect on the high No U.S. sanction requires any country or person to actually seize, intercept, inspect on the high
seas, or impound any Iranian ship suspected of carrying oil or other cargo that is subject to seas, or impound any Iranian ship suspected of carrying oil or other cargo that is subject to
sanctions. However, the Trump Administration used various terrorism-related provisions to sanctions. However, the Trump Administration used various terrorism-related provisions to
sanction some Iranian oil shipments and persons involved in shipping Iranian oil, arguing that the sanction some Iranian oil shipments and persons involved in shipping Iranian oil, arguing that the
shipments were organized by and for the benefit of Iran’s Islamic Revolutionary Guard Corps shipments were organized by and for the benefit of Iran’s Islamic Revolutionary Guard Corps
(IRGC). On September 4, 2019, the OFAC updated its sanctions guidance to state that “bunkering (IRGC). On September 4, 2019, the OFAC updated its sanctions guidance to state that “bunkering
services” (port operational support) for Iranian oil shipments could subject firms and individuals services” (port operational support) for Iranian oil shipments could subject firms and individuals
to U.S. sanctions. to U.S. sanctions.
The Iran Sanctions Act
This section includes sanctions triggers under the ~~Act~~act that were added by subsequent laws.
The Iran Sanctions Act (ISA) has been a pivotal component of U.S. sanctions against Iran’s The Iran Sanctions Act (ISA) has been a pivotal component of U.S. sanctions against Iran’s
energy sector. Since its enactment in 1996, ISA’s provisions have been expanded and extended to energy sector. Since its enactment in 1996, ISA’s provisions have been expanded and extended to
other Iranian industries. ISA sought to thwart Iran’s 1995 opening of the sector to foreign other Iranian industries. ISA sought to thwart Iran’s 1995 opening of the sector to foreign
investment in late 1995 through a “buy-back” program in which foreign firms gradually recoup investment in late 1995 through a “buy-back” program in which foreign firms gradually recoup
their investments as oil and gas is produced. It was first enacted as the Iran and Libya Sanctions their investments as oil and gas is produced. It was first enacted as the Iran and Libya Sanctions
Act (ILSA, P.L. 104-172, signed on August 5, 1996) but was later retitled the Iran Sanctions Act Act (ILSA, P.L. 104-172, signed on August 5, 1996) but was later retitled the Iran Sanctions Act
after it terminated with respect to Libya in 2006. ISA was the first major “extra-territorial after it terminated with respect to Libya in 2006. ISA was the first major “extra-territorial
sanction” on Iran—a sanction that authorizes U.S. penalties against third country firms.sanction” on Iran—a sanction that authorizes U.S. penalties against third country firms.
ISA does not sanction purchasing crude oil from Iran. ISA does not sanction purchasing crude oil from Iran.
Key Sanctions “Triggers” Under ISA
ISA consists of a number of “triggers”— ISA consists of a number of “triggers”— transactions with Iran that would be considered transactions with Iran that would be considered
violations of ISA and could cause a firm or entity to be sanctioned under ISA’s provisions. All violations of ISA and could cause a firm or entity to be sanctioned under ISA’s provisions. All
triggers that were waived during JCPOA implementation were reinstated in 2018. triggers that were waived during JCPOA implementation were reinstated in 2018.
Trigger 1 (Original Trigger): “Investment” To Develop Iran’s Oil and Gas Fields
The core trigger of ISA The core trigger of ISA ~~when it was first enacted~~at enactment was a requirement that the President sanction was a requirement that the President sanction
companies (entities, persons) that make an “investment” of more than $20 million in one year in companies (entities, persons) that make an “investment” of more than $20 million in one year in
Iran’s energy sector.Iran’s energy sector. 22 As amended by CISADA (P.L. 111-195) and P.L. 107-24, the definitions of 22 As amended by CISADA (P.L. 111-195) and P.L. 107-24, the definitions of
sanctionable activity under ISA includessanctionable activity under ISA includes: construction of pipelines to or through Iran, as well as construction of pipelines to or through Iran, as well as
contracts to lead the construction, upgrading, or expansions of energy projects; sales of energy-contracts to lead the construction, upgrading, or expansions of energy projects; sales of energy-
related equipment to Iran (if such sales are structured as investments or ongoing profit-earning related equipment to Iran (if such sales are structured as investments or ongoing profit-earning
ventures); equity and royalty arrangements and any contract that includes “responsibility for the ventures); equity and royalty arrangements and any contract that includes “responsibility for the
development of petroleum resources” of Iran; and additions to existing investment. CISADA also development of petroleum resources” of Iran; and additions to existing investment. CISADA also
clarified that the definition of energy sector includes liquefied natural gas (LNG), oil or LNG clarified that the definition of energy sector includes liquefied natural gas (LNG), oil or LNG
tankers, and products related to pipelines that transport oil or LNG. tankers, and products related to pipelines that transport oil or LNG.
Trigger 2: Sales of WMD and Related Technologies, Advanced Conventional
Weaponry, and Participation in Uranium Mining Ventures
The Iran Freedom Support Act (P.L. 109-293, September 30, 2006) added The Iran Freedom Support Act (P.L. 109-293, September 30, 2006) added Section 5(b)(1) of ISA, of ISA,
subjecting to ISA sanctions firms or persons determined to have sold to Iran (1) “chemical, subjecting to ISA sanctions firms or persons determined to have sold to Iran (1) “chemical,

22 Under §4(d) of the original act, for Iran, the threshold dropped to $20 million, from $40 million, one year after 22 Under §4(d) of the original act, for Iran, the threshold dropped to $20 million, from $40 million, one year after
enactment, when U.S. allies did not join a multilateral sanctions regime against Iran. P.L. 111-195 set the threshold enactment, when U.S. allies did not join a multilateral sanctions regime against Iran. P.L. 111-195 set the threshold
investment level at $20 million. investment level at $20 million.
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biological, or nuclear weapons or related technologies” or (2) “destabilizing numbers and types” biological, or nuclear weapons or related technologies” or (2) “destabilizing numbers and types”
of advanced conventional weapons. Sanctions can be applied if the exporter knew (or had cause of advanced conventional weapons. Sanctions can be applied if the exporter knew (or had cause
to know) that the end-user of the item was Iran. The definitions do not specifically include to know) that the end-user of the item was Iran. The definitions do not specifically include
ballistic or cruise missiles, but those weapons could be considered “related technologies.” ballistic or cruise missiles, but those weapons could be considered “related technologies.”
The Iran Threat Reduction and Syria Human Rights Act (ITRSHRA, P.L. 112-158, signed August The Iran Threat Reduction and Syria Human Rights Act (ITRSHRA, P.L. 112-158, signed August
10, 2012) created 10, 2012) created Section 5(b)(2) of ISA subjecting to sanctions entities determined by the of ISA subjecting to sanctions entities determined by the
Administration to participate in a joint venture with Iran relating to the mining, production, or Administration to participate in a joint venture with Iran relating to the mining, production, or
transportation of uranium. transportation of uranium.
Implementation: This provision of ISA was not waived under the JCPOA. No ISA sanctions have This provision of ISA was not waived under the JCPOA. No ISA sanctions have
been imposed on any entities under this provision. been imposed on any entities under this provision.
Trigger 3: Sales of Gasoline to Iran
Section 102(a) of CISADA (mentioned above) amended Section 5 of ISA to sanction Iran’s Section 102(a) of CISADA (mentioned above) amended Section 5 of ISA to sanction Iran’s
importation of gasoline Its enactment followed legislation, such as P.L. 111-85, that prohibited the importation of gasoline Its enactment followed legislation, such as P.L. 111-85, that prohibited the
use of U.S. funds to fill the Strategic Petroleum Reserve with products from firms that sell use of U.S. funds to fill the Strategic Petroleum Reserve with products from firms that sell
gasoline to Iran; and P.L. 111-117 that denied Ex-Im Bank credits to any firm that sold gasoline or gasoline to Iran; and P.L. 111-117 that denied Ex-Im Bank credits to any firm that sold gasoline or
related equipment to Iran. The section sanctions related equipment to Iran. The section sanctions
 Sales to Iran of over $1 million worth in a single transaction (or $5 million in  Sales to Iran of over $1 million worth in a single transaction (or $5 million in
multiple transactions a one-year period) of gasoline and related aviation and multiple transactions a one-year period) of gasoline and related aviation and
other fuels. (Fuel oil, a petroleum by-product, was not defined as sanctionable.) other fuels. (Fuel oil, a petroleum by-product, was not defined as sanctionable.)
 Sales to Iran of equipment or services (same dollar threshold as above) which  Sales to Iran of equipment or services (same dollar threshold as above) which
would help Iran make or import gasoline. Examples include equipment and would help Iran make or import gasoline. Examples include equipment and
services for Iran’s oil refineries or port operations. services for Iran’s oil refineries or port operations.
Trigger 4: Provision of Equipment for Oil, Gas, and Petrochemicals Production
Section 201 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHA, P.L. Section 201 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHA, P.L.
112-158, August 10, 2012) codified an Executive Order, 13590 (November 21, 2011), by adding 112-158, August 10, 2012) codified an Executive Order, 13590 (November 21, 2011), by adding
Section 5(a)(5 and 6) to ISA sanctioning firms that Section 5(a)(5 and 6) to ISA sanctioning firms that
 Provide to Iran $1 million or more in a single transaction (or a total of $5 million  Provide to Iran $1 million or more in a single transaction (or a total of $5 million
in multiple transactions in a one-year period) worth of goods or services that Iran in multiple transactions in a one-year period) worth of goods or services that Iran
could use to maintain or enhance its oil and gas sector. This subjects to sanctions, could use to maintain or enhance its oil and gas sector. This subjects to sanctions,
for example, transactions with Iran by global oil services firms and the sale to for example, transactions with Iran by global oil services firms and the sale to
Iran of energy industry equipment such as drills, pumps, vacuums, and oil rights. Iran of energy industry equipment such as drills, pumps, vacuums, and oil rights.
 provide to Iran $250,000 in a single transaction (or $1 million in multiple  provide to Iran $250,000 in a single transaction (or $1 million in multiple
transactions in a one-year period) worth of goods or services that Iran could use transactions in a one-year period) worth of goods or services that Iran could use
to maintain or expand its production of petrochemical products.23to maintain or expand its production of petrochemical products.23
Trigger 5: Transporting Iranian Crude Oil
Section 201 of the ITRSHRA amends ISA by sanctioning entities the Administration determines Section 201 of the ITRSHRA amends ISA by sanctioning entities the Administration determines
 owns a vessel that was used to transport Iranian crude oil. The section also  owns a vessel that was used to transport Iranian crude oil. The section also
authorizes but does not require the President to prohibit a ship from putting to the President to prohibit a ship from putting to

23 A definition of chemicals and products considered “petrochemical products” is found in a Policy Guidance 23 A definition of chemicals and products considered “petrochemical products” is found in a Policy Guidance
statement. See statement. See Federal Register, November 13, 2012, http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-, November 13, 2012, http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-
27642.pdf. 27642.pdf.
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port in the United States for two years, if it is owned by a person sanctioned port in the United States for two years, if it is owned by a person sanctioned
under this provision under this provision (adds Section 5[a][7] to ISA). This sanction does not apply This sanction does not apply
to transportation of oil to countries that have received exemptions under Section to transportation of oil to countries that have received exemptions under Section
1245 of P.L. 112-81 (discussed below). 1245 of P.L. 112-81 (discussed below).
 participated in a joint oil and gas development venture with Iran, outside Iran, if  participated in a joint oil and gas development venture with Iran, outside Iran, if
that venture was established after January 1, 2002. The effective date exempts that venture was established after January 1, 2002. The effective date exempts
energy ventures in the Caspian Sea, such as the Shah Deniz oil field energy ventures in the Caspian Sea, such as the Shah Deniz oil field (adds
Section 5[a][4] to ISA).
Iran Threat Reduction and Syria Human Rights Act (ITRSHRA): ISA sanctions
on shipping insurance, Iranian bonds, and dealings with the IRGC
Separate provisions of the ITRSHR Act—Separate provisions of the ITRSHR Act—which do not amend ISA—require the application of require the application of
ISA menu sanctions (five out of the 12 sanctions on the ISA menu) on any entity that ISA menu sanctions (five out of the 12 sanctions on the ISA menu) on any entity that
 provides insurance or reinsurance for the National Iranian Oil Company (NIOC)  provides insurance or reinsurance for the National Iranian Oil Company (NIOC)
or the National Iranian Tanker Company (NITC) (Section 212). or the National Iranian Tanker Company (NITC) (Section 212).
 purchases or facilitates the issuance of sovereign debt of the government of Iran,  purchases or facilitates the issuance of sovereign debt of the government of Iran,
including Iranian government bonds (Section 213). including Iranian government bonds (Section 213).
 assists or engages in a significant transaction with the IRGC or any of its  assists or engages in a significant transaction with the IRGC or any of its
sanctioned entities or affiliates. (Section 302). sanctioned entities or affiliates. (Section 302). This section was not waived to
implement the JCPOA.
 Section 312 of ITRSHRA required an Administration determination, within 45  Section 312 of ITRSHRA required an Administration determination, within 45
days of enactment (by September 24, 2012) whether NIOC and NITC are IRGC days of enactment (by September 24, 2012) whether NIOC and NITC are IRGC
agents or affiliates. The determination would subject financial transactions with agents or affiliates. The determination would subject financial transactions with
NIOC and NITC to CISADA sanctions (see below). NIOC and NITC to CISADA sanctions (see below).
Implementation. In 2012, the Department of the Treasury determined that NIOC and NITC are . In 2012, the Department of the Treasury determined that NIOC and NITC are
affiliates of the IRGC, and it designated NIOC as a proliferation entity under Executive Order affiliates of the IRGC, and it designated NIOC as a proliferation entity under Executive Order
13382. The designations triggered, in accordance with Section 104 of CISADA, a ban on any 13382. The designations triggered, in accordance with Section 104 of CISADA, a ban on any
foreign bank determined to have dealt directly with NIOC (or NIOC bank account) from opening foreign bank determined to have dealt directly with NIOC (or NIOC bank account) from opening
or maintaining a U.S.-based account. (NIOC and NITC were delisted under the JCPOA, but they or maintaining a U.S.-based account. (NIOC and NITC were delisted under the JCPOA, but they
were “relisted” on November 5, 2018.) were “relisted” on November 5, 2018.)
Executive Order 13622/13846: Sanctions on the Purchase of Iranian Crude Oil
and Petrochemical Products, and Dealings in Iranian Bank Notes
Status: 13622 (July 30, 2012) revoked (by E.O. 13716, January 2016) but was put back into effect
by E.O. 13846 of August 6, 2018
Executive Order 13622 (July 30, 2012) imposed specified sanctions on the ISA sanctions menu, Executive Order 13622 (July 30, 2012) imposed specified sanctions on the ISA sanctions menu,
and bars banks from the U.S. financial system, for the following activities: and bars banks from the U.S. financial system, for the following activities:
 the purchase of oil, other petroleum, or petrochemical products from Iran.24  the purchase of oil, other petroleum, or petrochemical products from Iran.24
 transactions with the National Iranian Oil Company (NIOC) or Naftiran  transactions with the National Iranian Oil Company (NIOC) or Naftiran
Intertrade Company (NICO). Intertrade Company (NICO).

24 A definition of what chemicals and products are considered “petroleum products” for the purposes of the order are in 24 A definition of what chemicals and products are considered “petroleum products” for the purposes of the order are in
the policy guidance issued November 13, 2012, http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-27642.pdf. the policy guidance issued November 13, 2012, http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-27642.pdf.
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E.O. 13622 also blocked U.S.-based property of entities determined to have E.O. 13622 also blocked U.S.-based property of entities determined to have
 assisted or provided goods or services to NIOC, NICO, or the Central Bank  assisted or provided goods or services to NIOC, NICO, or the Central Bank
of Iran. of Iran.
 assisted the government of Iran in the purchase of U.S. bank notes or  assisted the government of Iran in the purchase of U.S. bank notes or
precious metals, precious stones, or jewels. (The provision for precious precious metals, precious stones, or jewels. (The provision for precious
stones or jewels was added to this order by E.O. 16345 below.) stones or jewels was added to this order by E.O. 16345 below.)
E.O. 13622 E.O. 13622 sanctions sanctions dodid not apply if the parent country of the entity not apply if the parent country of the entity ~~has received an~~ had an active importation importation
exception under Section 1245 of P.L. 112-81, discussed below. An exception also is provided for exception under Section 1245 of P.L. 112-81, discussed below. An exception also is provided for
pre-existing projects that bring gas from Azerbaijan to Europe and Turkey. pre-existing projects that bring gas from Azerbaijan to Europe and Turkey.
Mandate and Time Frame to Investigate ISA Violations
In the original version of ISA, there was no firm requirement, and no time limit, for the In the original version of ISA, there was no firm requirement, and no time limit, for the
Administration to investigate potential violations and determine that a firm has violated ISA’s Administration to investigate potential violations and determine that a firm has violated ISA’s
provisions. The Iran Freedom Support Act (P.L. 109-293, September 30, 2006) added a provision provisions. The Iran Freedom Support Act (P.L. 109-293, September 30, 2006) added a provision
recommending, recommending, but not requiring, a 180-day time limit for a violation determination.25 CISADA , a 180-day time limit for a violation determination.25 CISADA
(Section 102[g][5]) mandated that the Administration begin an investigation of potential ISA (Section 102[g][5]) mandated that the Administration begin an investigation of potential ISA
violations when there is “credible information” about a potential violation, and made mandatory violations when there is “credible information” about a potential violation, and made mandatory
the 180-day time limit for a determination of violation. the 180-day time limit for a determination of violation.
ITRSHRA defines “credible information” needed to begin an investigation of a violation to ITRSHRA defines “credible information” needed to begin an investigation of a violation to
include a corporate announcement or corporate filing to its shareholders that it has undertaken include a corporate announcement or corporate filing to its shareholders that it has undertaken
transactions with Iran. It says that the President transactions with Iran. It says that the President may use as credible information reports from the use as credible information reports from the
Government Accountability Office and the Congressional Research Service. Section 219 of Government Accountability Office and the Congressional Research Service. Section 219 of
ITRSHRA requires that an investigation begin if a company reports to the Securities and ITRSHRA requires that an investigation begin if a company reports to the Securities and
Exchange Commission (SEC) that it has engaged in activities that would violate ISA (or Section Exchange Commission (SEC) that it has engaged in activities that would violate ISA (or Section
104 of CISADA or transactions with entities designated under E.O 13224 or 13382, see below). 104 of CISADA or transactions with entities designated under E.O 13224 or 13382, see below).
Oversight
ITRSHRA added several mechanisms for Congress to exercise oversight over Administration ITRSHRA added several mechanisms for Congress to exercise oversight over Administration
investigations of ISA violations. Section 223 of that law required a Government Accountability investigations of ISA violations. Section 223 of that law required a Government Accountability
Office report, within 120 days of enactment, and another such report a year later, on companies Office report, within 120 days of enactment, and another such report a year later, on companies
that have undertaken specified activities with Iran that might constitute violations of ISA. Section that have undertaken specified activities with Iran that might constitute violations of ISA. Section
224 amended a reporting requirement in Section 110(b) of CISADA by requiring an 224 amended a reporting requirement in Section 110(b) of CISADA by requiring an
Administration report to Congress every 180 days on investment in Iran’s energy sector, joint Administration report to Congress every 180 days on investment in Iran’s energy sector, joint
ventures with Iran, and estimates of Iran’s imports and exports of petroleum products. ventures with Iran, and estimates of Iran’s imports and exports of petroleum products.

25 Other ISA amendments under that law included recommending against U.S. nuclear agreements with countries that 25 Other ISA amendments under that law included recommending against U.S. nuclear agreements with countries that
supply nuclear technology to Iran and expanding provisions of the USA Patriot Act (P.L. 107-56) to curb money-supply nuclear technology to Iran and expanding provisions of the USA Patriot Act (P.L. 107-56) to curb money-
laundering for use to further WMD programs. laundering for use to further WMD programs.
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ISA Sanctions Menu
For companies that the President determines violated ISA, the original version of ISA required the imposition of For companies that the President determines violated ISA, the original version of ISA required the imposition of
two of a menu of six sanctions on that firm. The Iran Freedom Support Act added three new possible sanctions of a menu of six sanctions on that firm. The Iran Freedom Support Act added three new possible sanctions
and required the imposition of at least three out of the nine against violators. CISADA added three more and required the imposition of at least three out of the nine against violators. CISADA added three more
sanctions to the ISA menu and required imposition of at least sanctions to the ISA menu and required imposition of at least 5 out of the 12 sanctions. Executive Orders 13590 sanctions. Executive Orders 13590
and 13622 provide for exactly the same penalties as those in ISA. The 12 available sanctions against the sanctioned and 13622 provide for exactly the same penalties as those in ISA. The 12 available sanctions against the sanctioned
entity, from which the Secretary of State or the Treasury can select, are as entity, from which the Secretary of State or the Treasury can select, are as ~~fol ows~~follows: :
1. denial of Export-Import Bank loans, credits, or credit guarantees for U.S. exports to the sanctioned entity 1. denial of Export-Import Bank loans, credits, or credit guarantees for U.S. exports to the sanctioned entity
(original ISA) (original ISA)
2. denial of licenses for the U.S. export of military or militarily useful technology to the entity (original ISA) 2. denial of licenses for the U.S. export of military or militarily useful technology to the entity (original ISA)
3. denial of U.S. bank loans exceeding $10 3. denial of U.S. bank loans exceeding $10 ~~mil ion~~million in one year to the entity (original ISA) in one year to the entity (original ISA)
4. if the entity is a financial institution, a prohibition on its service as a primary dealer in U.S. government bonds; 4. if the entity is a financial institution, a prohibition on its service as a primary dealer in U.S. government bonds;
and/or a prohibition on its serving as a repository for U.S. government funds (each counts as one sanction) and/or a prohibition on its serving as a repository for U.S. government funds (each counts as one sanction)
(original ISA) (original ISA)
5. prohibition on U.S. government procurement from the entity (original ISA) 5. prohibition on U.S. government procurement from the entity (original ISA)
6. prohibition on transactions in foreign exchange by the entity (added by CISADA) 6. prohibition on transactions in foreign exchange by the entity (added by CISADA)
7. prohibition on any credit or payments between the entity and any U.S. financial institution (added by CISADA) 7. prohibition on any credit or payments between the entity and any U.S. financial institution (added by CISADA)
8. prohibition of the sanctioned entity from acquiring, holding, using, or trading any U.S.-based property which the 8. prohibition of the sanctioned entity from acquiring, holding, using, or trading any U.S.-based property which the
sanctioned entity has a (financial) interest in (added by CISADA) sanctioned entity has a (financial) interest in (added by CISADA)
9. restriction on imports from the sanctioned entity, in accordance with the International Emergency Economic 9. restriction on imports from the sanctioned entity, in accordance with the International Emergency Economic
Powers Act (IEEPA; 50 U.S.C. 1701) (original ISA) Powers Act (IEEPA; 50 U.S.C. 1701) (original ISA)
10. a ban on a U.S. person from investing in or purchasing significant amounts of equity or debt instruments of a 10. a ban on a U.S. person from investing in or purchasing significant amounts of equity or debt instruments of a
sanctioned person (added by ITRSHRA) sanctioned person (added by ITRSHRA)
11. exclusion from the United States of corporate officers or 11. exclusion from the United States of corporate officers or ~~control ing~~controlling shareholders of a sanctioned firm (added shareholders of a sanctioned firm (added
by ITRSHRA) by ITRSHRA)
12. imposition of any of the ISA sanctions on principal offices of a sanctioned firm (added by ITRSHRA). 12. imposition of any of the ISA sanctions on principal offices of a sanctioned firm (added by ITRSHRA).
Mandatory Sanction: Prohibition on Contracts with the U.S. Government CISADA (§102[b]) added a requirement Mandatory Sanction: Prohibition on Contracts with the U.S. Government CISADA (§102[b]) added a requirement
in ISA that companies, as a condition of obtaining a U.S. government contract, certify to the relevant U.S. in ISA that companies, as a condition of obtaining a U.S. government contract, certify to the relevant U.S.
government agency that the firm—government agency that the firm—and any companies it owns or controls—are not violating ISA. Regulations to —are not violating ISA. Regulations to
implement this requirement were issued on September 29, 2010. implement this requirement were issued on September 29, 2010.
Executive Order 13574 of May 23, 2011 and E.O. 13628 of October 9, 2012, specify which sanctions
are to be imposed. E.O. 13574 stipulated that, when an entity is sanctioned under Section 5 of ISA, the E.O. 13574 stipulated that, when an entity is sanctioned under Section 5 of ISA, the
penalties to be imposed are numbers 3, 6, 7, 8, and 9, above. E.O. 13628 updated that specification to also include penalties to be imposed are numbers 3, 6, 7, 8, and 9, above. E.O. 13628 updated that specification to also include
ISA sanctions numbers 11 and 12. The orders also clarify that it is the responsibility of the Department of the ISA sanctions numbers 11 and 12. The orders also clarify that it is the responsibility of the Department of the
Treasury to implement those ISA sanctions that involve the financial sectors. E.O. 13574 and 13628 were rTreasury to implement those ISA sanctions that involve the financial sectors. E.O. 13574 and 13628 were revoked
by E.O. 13716 on Implementation Day, in accordance with the JCPOA. They were reinstated, and superseded, by E.O. They were reinstated, and superseded, by E.O.
13846 of August 6, 2018, which mandated that, when ISA sanctions are to be imposed, that the sanctions include 13846 of August 6, 2018, which mandated that, when ISA sanctions are to be imposed, that the sanctions include
ISA sanctions numbers 3, 6, 7, 8, 9, 10, and 12. ISA sanctions numbers 3, 6, 7, 8, 9, 10, and 12.
Interpretations of ISA and Related Laws
The sections below provide information on how key ISA provisions have been applied. The sections below provide information on how key ISA provisions have been applied.
Application to Energy Pipelines
ISA’s definition of “investment” has been consistently interpreted to include construction of ISA’s definition of “investment” has been consistently interpreted to include construction of
energy pipelines to or through Iran because pipelines help Iran develop its petroleum (oil and energy pipelines to or through Iran because pipelines help Iran develop its petroleum (oil and
natural gas) sector.26 natural gas) sector.26

26 In March 2012, then-Secretary of State Clinton clarified that the Obama Administration interpreted the provision to 26 In March 2012, then-Secretary of State Clinton clarified that the Obama Administration interpreted the provision to
be applicable from the beginning of pipeline construction “Tough US warning on Iran gas pipeline.” be applicable from the beginning of pipeline construction “Tough US warning on Iran gas pipeline.” Dawn, March 1, , March 1,
2012. 2012.
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Application to Purchases from Iran of Natural Gas
ISA and other laws, such as ISA and other laws, such as ~~IFCA,~~ the Iran Freedom and Counter-proliferation Act (IFCA, see below) exclude from sanctions natural gas transactions with Iran. exclude from sanctions natural gas transactions with Iran.
However, construction of gas However, construction of gas pipelines involving Iran is subject to ISA sanctions. And, involving Iran is subject to ISA sanctions. And, other sanctions sanctions
on financial transactions with Iran might impede gas transactions with Iran. on financial transactions with Iran might impede gas transactions with Iran.
The effective dates of U.S. sanctions laws and orders exclude long-standing joint natural gas The effective dates of U.S. sanctions laws and orders exclude long-standing joint natural gas
projects that involve some Iranian firms—particularly the Shah Deniz natural gas field and projects that involve some Iranian firms—particularly the Shah Deniz natural gas field and
related pipelines in the Caspian Sea. Iran’s NICO holds a passive 10% share in Shah Deniz, related pipelines in the Caspian Sea. Iran’s NICO holds a passive 10% share in Shah Deniz,
which also includes BP, Azerbaijan’s natural gas firm SOCAR, Russia’s Lukoil, and other firms. which also includes BP, Azerbaijan’s natural gas firm SOCAR, Russia’s Lukoil, and other firms.
An OFAC factsheet of November 28, 2012 stated that the Shah Deniz consortium, as a whole, is An OFAC factsheet of November 28, 2012 stated that the Shah Deniz consortium, as a whole, is
not determined to be “a person owned or controlled by” the government of Iran and transactions not determined to be “a person owned or controlled by” the government of Iran and transactions
with the consortium are permissible. with the consortium are permissible.
Application to Iranian Liquefied Natural Gas Development
The original version of ISA did not apply to the development by Iran of a liquefied natural gas The original version of ISA did not apply to the development by Iran of a liquefied natural gas
(LNG) export capability. However, another law, CISADA (see below) specifically included LNG (LNG) export capability. However, another law, CISADA (see below) specifically included LNG
in the ISA definition of petroleum resources and therefore made subject to sanctions LNG in the ISA definition of petroleum resources and therefore made subject to sanctions LNG
investment in Iran and supply of LNG tankers to Iran. Iran has not developed an LNG export investment in Iran and supply of LNG tankers to Iran. Iran has not developed an LNG export
capability to date. capability to date.
Application to Private Financing but Not Official Credit Guarantee Agencies
The ISA definition of investment includes financing for investment in Iran’s energy sector, or for The ISA definition of investment includes financing for investment in Iran’s energy sector, or for
sales of gasoline and refinery-related equipment and services. However, the definitions of sales of gasoline and refinery-related equipment and services. However, the definitions of
financial institutions are interpreted not to apply to official credit guarantee agencies, such as financial institutions are interpreted not to apply to official credit guarantee agencies, such as
France’s COFACE and Germany’s Hermes, because these agencies are arms of their parent France’s COFACE and Germany’s Hermes, because these agencies are arms of their parent
governments. ISA does not provide for sanctioning governments or their agencies. governments. ISA does not provide for sanctioning governments or their agencies.
Implementation of Energy-Related Iran Sanctions
Entities sanctioned under the executive orders or laws cited in this section are listed in the tables Entities sanctioned under the executive orders or laws cited in this section are listed in the tables
at the end of this report. As noted, some of the orders cited provide for blocking U.S.-based assets at the end of this report. As noted, some of the orders cited provide for blocking U.S.-based assets
of the entities designated for sanctions. OFAC has not publicly reported on the accounts, if any, of the entities designated for sanctions. OFAC has not publicly reported on the accounts, if any,
that have been blocked under the orders or laws discussed in this section, and the entities that have been blocked under the orders or laws discussed in this section, and the entities
sanctioned likely do not have a financial presence in the United States. sanctioned likely do not have a financial presence in the United States.
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ISA Waiver, Exemptions, and Sunset Provisions
The President can waive ISA sanctions in several ways—general, country-specific, or company-specific. The President can waive ISA sanctions in several ways—general, country-specific, or company-specific.
General Waiver. Under Section 4(c)(1)(a), the President can waive (for six months at a time) the requirement to . Under Section 4(c)(1)(a), the President can waive (for six months at a time) the requirement to
investigate violations. To implement the JCPOA, this waiver was exercised by the Obama Administration (the investigate violations. To implement the JCPOA, this waiver was exercised by the Obama Administration (the
latest on January 18, 2017), and was last renewed by the Trump Administration on January 12, 2018.latest on January 18, 2017), and was last renewed by the Trump Administration on January 12, 2018.
Country-Specific Waiver. Under Section 4(c)(1)(B), the President can waive ISA sanctions (for 12 months at a time) . Under Section 4(c)(1)(B), the President can waive ISA sanctions (for 12 months at a time)
of all companies whose governments are determined to be “closely cooperating with the United States in of all companies whose governments are determined to be “closely cooperating with the United States in
multilateral efforts to prevent Iran from” acquiring WMD or acquiring advanced conventional weapons. The multilateral efforts to prevent Iran from” acquiring WMD or acquiring advanced conventional weapons. The
President must also certify that the waiver is vital to the national security interests of the United States. President must also certify that the waiver is vital to the national security interests of the United States.
Company-Specific Waiver. Under Section 9(c), the President can waive ISA sanctions (for one year at a time) on any . Under Section 9(c), the President can waive ISA sanctions (for one year at a time) on any
company for which the President determines that the waiver is “essential to the national security interests of the company for which the President determines that the waiver is “essential to the national security interests of the
United States.” This waiver was used in 1998 to avoid penalizing Total, Gazprom, and Petronas for an Iran United States.” This waiver was used in 1998 to avoid penalizing Total, Gazprom, and Petronas for an Iran
investment. investment.
ISA (§5[f]) also contains several exceptions such as that the President is not required to impose sanctions that ISA (§5[f]) also contains several exceptions such as that the President is not required to impose sanctions that
prevent procurement of defense articles and services under existing contracts, in cases where a firm is the sole prevent procurement of defense articles and services under existing contracts, in cases where a firm is the sole
source supplier of a particular defense article or service. The President is not required to prevent procurement of source supplier of a particular defense article or service. The President is not required to prevent procurement of
essential spare parts or component parts. essential spare parts or component parts.
“Special Rule” Exempting Firms That End Their Business with Iran
Under a provision added by CISADA (§102[g][5]), ISA provides a means—a so-called “special rule”—for firms to Under a provision added by CISADA (§102[g][5]), ISA provides a means—a so-called “special rule”—for firms to
avoid ISA sanctions by pledging to verifiably end their business with Iran and such business with Iran in the future. avoid ISA sanctions by pledging to verifiably end their business with Iran and such business with Iran in the future.
Under the special rule, which has been invoked on several occasions, as discussed below, the Administration is not Under the special rule, which has been invoked on several occasions, as discussed below, the Administration is not
required to impose sanctions against a firm that makes such pledges. Firms are allowed several years, in some required to impose sanctions against a firm that makes such pledges. Firms are allowed several years, in some
cases, to wind down existing business in Iran, in part because the buy-back program used by Iran pays energy firms cases, to wind down existing business in Iran, in part because the buy-back program used by Iran pays energy firms
back their investment over time, making it highly costly for them to suddenly end operations in Iran. back their investment over time, making it highly costly for them to suddenly end operations in Iran.
Administration Termination Process and Requirements
The Administration can immediately terminate all ISA provisions if it certifies that Iran: The Administration can immediately terminate all ISA provisions if it certifies that Iran:
(1) has ceased its efforts to acquire WMD; (2) has been removed from the U.S. list of state sponsors of terrorism; (1) has ceased its efforts to acquire WMD; (2) has been removed from the U.S. list of state sponsors of terrorism;
and (3) no longer “poses a significant threat” to U.S. national security and U.S. allies.27 (3) no longer “poses a significant threat” to U.S. national security and U.S. allies.27
This termination provision, like the sunset provision discussed belowThis termination provision, like the sunset provision discussed below, does not apply to those laws that apply ISA
sanctions without specifically amending ISA. The executive orders and laws that apply ISA sanctions to specified The executive orders and laws that apply ISA sanctions to specified
violators violators but without amending ISA itself can be revoked by a superseding executive order or congressional action can be revoked by a superseding executive order or congressional action
that amends or repeals the provisions involved. that amends or repeals the provisions involved.
Sunset and Other Expiration Provisions
ISA was scheduled to sunset on December 31, 2016, as provided for by CISADA. This ISA was scheduled to sunset on December 31, 2016, as provided for by CISADA. This ~~fol owed~~followed prior sunset prior sunset
extensions to December 31, 2011 (by P.L. 109-293); December 31, 2006 (P.L. 107-24, August 3, 2001); and extensions to December 31, 2011 (by P.L. 109-293); December 31, 2006 (P.L. 107-24, August 3, 2001); and
August 5, 2001 (original law). In December 2016, P.L. 114-277 extended the law, as is, until December 31, 2026. August 5, 2001 (original law). In December 2016, P.L. 114-277 extended the law, as is, until December 31, 2026.
P.L. 107-24 also required an Administration report on ISA’s effectiveness within 24 to 30 months of enactment, P.L. 107-24 also required an Administration report on ISA’s effectiveness within 24 to 30 months of enactment,
with the report to include an administration recommendation on whether ISA should be repealed. That report with the report to include an administration recommendation on whether ISA should be repealed. That report
was submitted to Congress in January 2004, and did not recommend that ISA be repealed. was submitted to Congress in January 2004, and did not recommend that ISA be repealed.
Oil Export Sanctions: FY2012 NDAA Sanctioning the Central Bank
In 2011, Congress sought to reduce Iran’s exportation of oil by imposing sanctions on financial In 2011, Congress sought to reduce Iran’s exportation of oil by imposing sanctions on financial
transactions with Iran’s Central Bank, which transactions with Iran’s Central Bank, which ~~receives Iran’s oil payments worldwide. President~~
~~Obama, in his signing statement on the bill, indicated he would implement the provision so as not~~
~~to damage U.S. relations with U.S. partner countries, many of whom were purchasers of~~maintains accounts in banks worldwide to receive payments for Iranian Iranian
oil. Section 1245 of the FY2012 National Defense Authorization Act (NDAA, P.L. 112-81, oil. Section 1245 of the FY2012 National Defense Authorization Act (NDAA, P.L. 112-81,
~~December 31, 2011):~~
December 31, 2011):  Requires the President to prevent a foreign bank from opening an account in the United States—or impose strict limitations on existing U.S. accounts—if that
27 This termination requirement added by P.L. 109-293 formally removed Libya from the act. Application of the act to 27 This termination requirement added by P.L. 109-293 formally removed Libya from the act. Application of the act to
Libya terminated on April 23, 2004, with a determination that Libya had fulfilled U.N. requirements. Libya terminated on April 23, 2004, with a determination that Libya had fulfilled U.N. requirements.
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~~ Requires the President to prevent a foreign bank from opening an account in the~~
~~United States—or impose strict limitations on existing U.S. accounts—if that~~
bank is determined to have conducted a “significant financial transaction” with bank is determined to have conducted a “significant financial transaction” with
Iran’s Central Bank Iran’s Central Bank or with any sanctioned Iranian bank. .
 The provision applies to a foreign  The provision applies to a foreign central bank only if the transaction with Iran’s only if the transaction with Iran’s
Central Bank is to pay for oil purchases. Central Bank is to pay for oil purchases. (Foreign central banks generally do not maintain payable-through accounts or correspondent accounts with U.S. banks, and therefore some U.S. sanctions might not necessarily affect foreign central banks to the extent that sanctions might affect foreign commercial banks. See analysis of the CISADA law, below.)
  Significant Reduction Exception (SRE): The law provides incentive for Iran’s oil The law provides incentive for Iran’s oil
buyers to reduce purchases of Iranian oil by providing for an exception buyers to reduce purchases of Iranian oil by providing for an exception
(exemption) for the banks of any country determined to have “(exemption) for the banks of any country determined to have “significantly
reduced” its purchases of oil from Iran. To maintain the SRE, countries are its purchases of oil from Iran. To maintain the SRE, countries are
required to reduce their oil buys from Iran relative to the previous 180-day required to reduce their oil buys from Iran relative to the previous 180-day
period.28 The law lacks a definition of “significant reduction” of oil purchases, period.28 The law lacks a definition of “significant reduction” of oil purchases,
but a January 2012 letter by several Senators to the then-Treasury Secretary set but a January 2012 letter by several Senators to the then-Treasury Secretary set
that definition at an 18% purchase reduction based on total paid for the Iranian that definition at an 18% purchase reduction based on total paid for the Iranian
oil (not just volume reduction).29The banks of countries given an SRE may oil (not just volume reduction).29The banks of countries given an SRE may
continue to conduct any transactions (not just for oil) with the Central Bank or continue to conduct any transactions (not just for oil) with the Central Bank or
with any sanctioned Iranian bank. with any sanctioned Iranian bank.
 Sanctions on transactions for oil apply if: the President certifies to Congress  Sanctions on transactions for oil apply if: the President certifies to Congress
every 90 days, based on a report by the Energy Information Administration, that every 90 days, based on a report by the Energy Information Administration, that
the oil market the oil market is adequately supplied, and, an Administration determination every adequately supplied, and, an Administration determination every
180 days that there is a sufficient supply of oil worldwide to permit countries to 180 days that there is a sufficient supply of oil worldwide to permit countries to
reduce purchases from Iran. The required EIA reports and Administration reduce purchases from Iran. The required EIA reports and Administration
determinations have been issued at the prescribed intervals. determinations have been issued at the prescribed intervals.
  Humanitarian Exception. Paragraph (2) of Section 1245 exempts transactions . Paragraph (2) of Section 1245 exempts transactions
with Iran’s Central Bank that are for “the sale of agricultural commodities, food, with Iran’s Central Bank that are for “the sale of agricultural commodities, food,
medicine, or medical devices to Iran” from sanctions. However: the Central medicine, or medical devices to Iran” from sanctions. However: the Central
Bank’s designation as a terrorist entity under E.O. 13224 on September 20, 2019, Bank’s designation as a terrorist entity under E.O. 13224 on September 20, 2019,
voided that exception. In February 2020, as the COVID-19 pandemic affected voided that exception. In February 2020, as the COVID-19 pandemic affected
Iran greatly, the Treasury Department issued a General License to permit Iran greatly, the Treasury Department issued a General License to permit
transactions with Iran’s Central Bank for the purchase of humanitarian items.30 transactions with Iran’s Central Bank for the purchase of humanitarian items.30
Implementation/SREs Issued and Ended
The Obama Administration used the FY2012 NDAA to encourage countries to reduce their The Obama Administration used the FY2012 NDAA to encourage countries to reduce their
purchases of Iranian oil. SREs were issued as follows: purchases of Iranian oil. SREs were issued as follows:
 March 20, 2012: Japan  March 20, 2012: Japan
 September 2012 September 2012, (following a July 2012 EU Iran oil purchase embargofollowing a July 2012 EU Iran oil purchase embargo): 10 EU : 10 EU
countries—Belgium, Czech Republic, France, Germany, Greece, Italy, the countries—Belgium, Czech Republic, France, Germany, Greece, Italy, the
Netherlands, Poland, Spain, and BritainNetherlands, Poland, Spain, and Britain
~~ December 2012: China, India, Malaysia, South Africa, South Korea, Singapore,~~
~~Sri Lanka, Turkey, and Taiwan.~~

28 ITRSHRA amended Section 1245 such that any country that completely ceased purchasing oil from Iran entirely 28 ITRSHRA amended Section 1245 such that any country that completely ceased purchasing oil from Iran entirely
would retain an exception. would retain an exception.
29 Text of letter from Senators Mark Kirk and Robert Menendez to Secretary Geithner, January 19, 2012. 29 Text of letter from Senators Mark Kirk and Robert Menendez to Secretary Geithner, January 19, 2012.
30 Treasury Issues General License No. 8 Regarding Certain Permitted Humanitarian Trade Transactions Involving the 30 Treasury Issues General License No. 8 Regarding Certain Permitted Humanitarian Trade Transactions Involving the
Central Bank of Iran. Central Bank of Iran. JDSupra. March 12, 2020. . March 12, 2020.
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 December 2012: China, India, Malaysia, South Africa, South Korea, Singapore, Sri Lanka, Turkey, and Taiwan. SREs Ended in May 2019
The January 2016 waivers issued to implement the JCPOA suspended the requirement for a The January 2016 waivers issued to implement the JCPOA suspended the requirement for a
country to cut oil purchases from Iran in order to maintain their SREs, and Iran’s oil customers country to cut oil purchases from Iran in order to maintain their SREs, and Iran’s oil customers
quickly resumed buying Iranian oil. The provision went back into effect on November 5, 2018 in quickly resumed buying Iranian oil. The provision went back into effect on November 5, 2018 in
concert with the U.S. withdrawal from the JCPOA,31 and eight countries were given SREs and concert with the U.S. withdrawal from the JCPOA,31 and eight countries were given SREs and
continued to buy Iranian oil: China, India, Italy, Greece, Japan, South Korea, Taiwan, and Turkey. continued to buy Iranian oil: China, India, Italy, Greece, Japan, South Korea, Taiwan, and Turkey.
On April 22, 2019, the State Department announced that no more SREs would be granted after On April 22, 2019, the State Department announced that no more SREs would be granted after
May 2, 201932 in order to “apply maximum pressure” on Iran by driving its oil exports as close to May 2, 201932 in order to “apply maximum pressure” on Iran by driving its oil exports as close to
zero as possible. Entities sanctioned are in the tables at the end of this report. In March 2020, zero as possible. Entities sanctioned are in the tables at the end of this report. In March 2020,
Treasury Department officials warned oil traders of U.S. penalties if they continued to conduct Treasury Department officials warned oil traders of U.S. penalties if they continued to conduct
“ship-to-ship” transfers and other mechanisms to conceal trading in Iranian oil.33 “ship-to-ship” transfers and other mechanisms to conceal trading in Iranian oil.33
Waiver and Termination
The law provides for the President to waive the sanctions for 120 days, renewable for successive The law provides for the President to waive the sanctions for 120 days, renewable for successive
120-day periods, if the President determines that doing so is in the national security interest. This 120-day periods, if the President determines that doing so is in the national security interest. This
provision was waived to implement both the interim nuclear accord (January 2014-January 2016), provision was waived to implement both the interim nuclear accord (January 2014-January 2016),
which allowed Iran’s oil customers to maintain purchases level at 1.1 million barrels per day) and which allowed Iran’s oil customers to maintain purchases level at 1.1 million barrels per day) and
to implement the JCPOA. The Trump Administration renewed the waiver for the last time, on to implement the JCPOA. The Trump Administration renewed the waiver for the last time, on
January 12, 2018. The law went back into effect on November 5, 2018. January 12, 2018. The law went back into effect on November 5, 2018.
~~Iran Foreign Account “Restriction” Provision~~
Iranian Foreign Exchange Accounts “Restricted” Section 504 of the ITRSHRA, which went into effect in February 2013, Section 504 of the ITRSHRA, which went into effect in February 2013, ~~impedes the ability of~~
~~Iran to repatriate hard currency to its Central Bank, including U.S. dollars that are the primary~~
~~form of payment for~~amends the FY2012 NDAA so as to impede the ability of Iran’s Central Bank to repatriate or easily utilize the hard currency it receives for its exports abroad, particularly oil. The provision amended Section 1245 of the FY2012 NDAA (adding oil. The provision amended Section 1245 of the FY2012 NDAA (adding
“clause ii” to Paragraph D[1]) to require that any funds paid to Iran as a result of exempted “clause ii” to Paragraph D[1]) to require that any funds paid to Iran as a result of exempted
transactions (oil purchases, for example) be credited to an account located in the country with transactions (oil purchases, for example) be credited to an account located in the country with
primary jurisdiction over the foreign bank making the transaction. Iran can therefore only use the primary jurisdiction over the foreign bank making the transaction. Iran can therefore only use the
funds to buy the products of the countries where the funds are held. funds to buy the products of the countries where the funds are held.
The September 25, 2019, designation of the Central Bank as a terrorist entity under E.O. 13224, The September 25, 2019, designation of the Central Bank as a terrorist entity under E.O. 13224,
restricted Iran’s ability to use its Central Bank accounts abroad to pay for imports of humanitarian restricted Iran’s ability to use its Central Bank accounts abroad to pay for imports of humanitarian
items because the terrorism designation does not carry a humanitarian exception. However, the items because the terrorism designation does not carry a humanitarian exception. However, the
Administration eased that restriction with the February 27, 2020Administration eased that restriction with the February 27, 2020, General License that Iran’s General License that Iran’s
Central Bank accounts could be used for humanitarian transactions (see above). Central Bank accounts could be used for humanitarian transactions (see above).
Waiver
The waiver under the FY2012 NDAA (P.L. 112-81) applies to the foreign bank account restriction The waiver under the FY2012 NDAA (P.L. 112-81) applies to the foreign bank account restriction
provision, in six month periods. During U.S. implementation of the JCPOA, Sections 212(d)(10 provision, in six month periods. During U.S. implementation of the JCPOA, Sections 212(d)(10
and 2134(b)(1) of ITRSHRA were waived and Iran was able to access the hard currency it and 2134(b)(1) of ITRSHRA were waived and Iran was able to access the hard currency it
~~received from oil sales. The waiver was last renewed on January 12, 2018, and the restriction~~
~~went back into effect on November 5, 2018.~~

31 Department of State. Background Briefing on President Trump’s Decision to Withdraw from the JCPOA. May 8, 31 Department of State. Background Briefing on President Trump’s Decision to Withdraw from the JCPOA. May 8,
2018. 2018.
32 See CRS Insight IN11108, 32 See CRS Insight IN11108, Iran Oil Sanctions Exceptions Ended, by Kenneth Katzman. , by Kenneth Katzman.
33 “U.S. to warn shippers against storing Iranian oil.” State Department official. 33 “U.S. to warn shippers against storing Iranian oil.” State Department official. Reuters, March 9, 2020. , March 9, 2020.
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received from oil sales. The waiver was last renewed on January 12, 2018, and the restriction went back into effect on November 5, 2018. Table 1. Iran Crude Oil Sales
(average daily volumes, in barrels per day) (average daily volumes, in barrels per day)
JPA period
At U.S.
At SRE
~~Sept 2020~~March 2021
average
JCPOA Exit
~~Determination~~Determinations
(post-SRE
Country/Bloc
2011
(2014-2016)
(May ‘18)
(Oct. ‘18)
termination)
European Union European Union
(particularly (particularly
UNKNOWN UNKNOWN
~~Italy, Spain,~~
600,000 600,000
negligible negligible
520,000 + 520,000 +
100,000 100,000
Italy, Spain, (U) (U)
Greece) Greece)
China China
550,000 550,000
410,000 410,000
700,000 700,000
838,000 838,000
U900,000
Japan Japan
325,000 325,000
190,000 190,000
133,000 133,000
0 0
U U
India India
320,000 320,000
190,000 190,000
620,000 620,000
354,000 354,000
U U
South Korea South Korea
230,000 230,000
130,000 130,000
100,000 100,000
0 0
U U
Turkey Turkey
200,000 200,000
120,000 120,000
200,000 200,000
161,000 161,000
U U
South Africa South Africa
80,000 80,000
negligible negligible
negligible negligible
0 0
U U
Other Asia Other Asia
(Malaysia, Sri (Malaysia, Sri
90,000 90,000
negligible negligible
negligible negligible

U U
Lanka, Lanka,
Indonesia) Indonesia)
Taiwan Taiwan
35,000 35,000
10,000 10,000
67,000 67,000
0 0
U U
Singapore Singapore
20,000 20,000
negligible negligible
negligible negligible
33,000 33,000
U U
Syria Syria
0 0
negligible negligible
33,000 33,000
96.000 96.000
U U
Other/Unknown Other/Unknown
(Iraq and UAE (Iraq and UAE
55,000 55,000
negligible negligible
100,000 100,000
21,000 21,000
U U
swaps, other) swaps, other)
Total (mbd)
2.5
1.06
2.45
1.60
~~.05-1.5 (est)~~1.30
Explanation and Sources: As of November 2020, this report As of November 2020, this report ~~wil~~ will contain ranges for daily Iranian oil exports. contain ranges for daily Iranian oil exports.
Reported figures vary Reported figures vary ~~wildly~~ as Iranian tankers have sought to evade U.S. sanctions through various methods, as Iranian tankers have sought to evade U.S. sanctions through various methods,
including including ship-to-ship transfers and deactivating tanker tracking locator devices. ship-to-ship transfers and deactivating tanker tracking locator devices. ~~Petroleum Intelligence Weekly~~
~~reported on October 2, 2020 that various energy industry sources reported Iran’s daily oil exports for~~
~~September 2020 to be as low as 50,000 bpd or as high as 1.5 mbd.~~ Some figures include and others exclude Some figures include and others exclude
Iranian exports of condensates, which are light petroleum liquids that are associated with oil and natural gas Iranian exports of condensates, which are light petroleum liquids that are associated with oil and natural gas
production. South Korea was a large customer for Iranian condensates and, as of August 2018, it ended its production. South Korea was a large customer for Iranian condensates and, as of August 2018, it ended its
purchases of that product from Iran to zeropurchases of that product from Iran to zero. March 2021 estimate from: Bloomberg News, April 5, 2021. .
Note: mbd = mbd = ~~mil ion~~million barrels per day. barrels per day.
Sanctions on Arms and Weapons-Related
Technology Transfers
Several laws and executive orders seek to prevent Iran from obtaining arms and weapons-related Several laws and executive orders seek to prevent Iran from obtaining arms and weapons-related
technology. Sanctions on Iran’s exportation of arms are discussed in the sections above on technology. Sanctions on Iran’s exportation of arms are discussed in the sections above on
sanctions for Iran’s support for terrorist groups. No sanctions in this section were eased to sanctions for Iran’s support for terrorist groups. No sanctions in this section were eased to
implement the JCPOAimplement the JCPOA.
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Iran-Iraq Arms Nonproliferation Act and Iraq Sanctions Act
The Iran-Iraq Arms Nonproliferation Act (Title XIV of the FY1993 National Defense The Iran-Iraq Arms Nonproliferation Act (Title XIV of the FY1993 National Defense
Authorization Act, P.L. 102-484, signed in October 1992) imposes a number of sanctions on Authorization Act, P.L. 102-484, signed in October 1992) imposes a number of sanctions on
foreign entities that supply Iran with WMD technology or “destabilizing numbers and types of foreign entities that supply Iran with WMD technology or “destabilizing numbers and types of
advanced conventional weapons.”34 advanced conventional weapons.”34
Advanced conventional weapons are defined as: are defined as:
(1) such long-range precision-guided munitions, fuel air explosives, cruise missiles, low (1) such long-range precision-guided munitions, fuel air explosives, cruise missiles, low
observability aircraft, other radar evading aircraft, advanced military aircraft, military satellites, observability aircraft, other radar evading aircraft, advanced military aircraft, military satellites,
electromagnetic weapons, and laser weapons as the President determines destabilize the military electromagnetic weapons, and laser weapons as the President determines destabilize the military
balance or enhance the offensive capabilities in destabilizing ways. The definition is generally balance or enhance the offensive capabilities in destabilizing ways. The definition is generally
understood to include technology used to develop ballistic missiles. understood to include technology used to develop ballistic missiles.
(2) such advanced command, control, and communications systems, electronic warfare systems, (2) such advanced command, control, and communications systems, electronic warfare systems,
or intelligence collections systems as the President determines destabilize the military balance or or intelligence collections systems as the President determines destabilize the military balance or
enhance offensive capabilities in destabilizing waysenhance offensive capabilities in destabilizing ways~~; and~~.
(3) such other items or systems as the President may, by regulation, determine necessary for the (3) such other items or systems as the President may, by regulation, determine necessary for the
purposes of this title. purposes of this title.
Sanctions to be imposed: Sanctions imposed on violating entities include: Sanctions imposed on violating entities include: (1) a ban, for two years, (1) a ban, for two years,
on U.S. government procurement from the entity; (2) a ban, for two years, on licensing U.S. on U.S. government procurement from the entity; (2) a ban, for two years, on licensing U.S.
exports to that entity; and (3) authority, but not a requirement, to ban U.S. imports from the entity. exports to that entity; and (3) authority, but not a requirement, to ban U.S. imports from the entity.
If the violator is determined to be a foreign If the violator is determined to be a foreign country, sanctions to be imposed are: (1) a one-year , sanctions to be imposed are: (1) a one-year
ban on U.S. assistance to that country; (2) a one-year requirement of a U.S. vote against ban on U.S. assistance to that country; (2) a one-year requirement of a U.S. vote against
international loans to it; (3) a one-year suspension of U.S. coproduction agreements with the international loans to it; (3) a one-year suspension of U.S. coproduction agreements with the
country; (4) a one-year suspension of technical exchanges with the country in military or dual use country; (4) a one-year suspension of technical exchanges with the country in military or dual use
technology; (5) a one-year ban on sales of U.S. arms to the country; and (6) an authorization to technology; (5) a one-year ban on sales of U.S. arms to the country; and (6) an authorization to
deny the country most-favored-nation trade status; and to ban U.S. trade with the country. deny the country most-favored-nation trade status; and to ban U.S. trade with the country.
Section 1603 of the act amended an earlier law, the Iraq Sanctions Act of 1990 (Section 586G(a) Section 1603 of the act amended an earlier law, the Iraq Sanctions Act of 1990 (Section 586G(a)
of P.L. 101-513), to provide for a “presumption of denial” for all dual use exports to Iran. of P.L. 101-513), to provide for a “presumption of denial” for all dual use exports to Iran.
Waiver. Section 1606 of the act provides a presidential waiver for its provisions, and for sanctions Section 1606 of the act provides a presidential waiver for its provisions, and for sanctions
imposed pursuant to the Iraq Sanctions Act of 1990, if the President determines that it is imposed pursuant to the Iraq Sanctions Act of 1990, if the President determines that it is
“essential to the national interest.” “essential to the national interest.”
Implementation. A number of entities were sanctioned under the act in the 1990s, as shown in the A number of entities were sanctioned under the act in the 1990s, as shown in the
tables at the end of this paper, but the designations have all expired. tables at the end of this paper, but the designations have all expired.
Banning Aid to Countries that Aid or Arm Terrorism List States:
Anti-Terrorism and Effective Death Penalty Act of 1996
Another law reinforces the authority of the President to sanction governments that provide aid or Another law reinforces the authority of the President to sanction governments that provide aid or
sell arms to Iran (and other terrorism list countries). Under Sections 620G and 620H of the sell arms to Iran (and other terrorism list countries). Under Sections 620G and 620H of the
Foreign Assistance Act, as added by the Anti-Terrorism and Effective Death Penalty Act of 1996 Foreign Assistance Act, as added by the Anti-Terrorism and Effective Death Penalty Act of 1996
(Sections 325 and 326 of P.L. 104-132), the President is required to withhold foreign aid from any (Sections 325 and 326 of P.L. 104-132), the President is required to withhold foreign aid from any

34 The act originally only applied to advanced conventional weapons. The extension to WMD, defined as chemical, 34 The act originally only applied to advanced conventional weapons. The extension to WMD, defined as chemical,
biological, or nuclear weapons-related technology was added by the FY1996 National Defense Authorization Act (P.L. biological, or nuclear weapons-related technology was added by the FY1996 National Defense Authorization Act (P.L.
104-106). 104-106).
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country that provides to a terrorism list country financial assistance or arms. Waiver authority is country that provides to a terrorism list country financial assistance or arms. Waiver authority is
provided. provided.
Section 321 of the Anti-Terrorism and Effective Death Penalty Act also makes it a criminal Section 321 of the Anti-Terrorism and Effective Death Penalty Act also makes it a criminal
offense for U.S. persons to conduct financial transactions with terrorism list governments. offense for U.S. persons to conduct financial transactions with terrorism list governments.
No foreign assistance cuts or other penalties under this law have been announced. No foreign assistance cuts or other penalties under this law have been announced.
Proliferation-Related Provision of the Iran Sanctions Act
As noted above, As noted above, Section 5(b)(1) of ISA subjects to menu sanctions firms or persons determined to of ISA subjects to menu sanctions firms or persons determined to
have sold to Iran (1) technology useful for weapons of mass destruction (WMD) or (2) have sold to Iran (1) technology useful for weapons of mass destruction (WMD) or (2)
“destabilizing numbers and types” of advanced conventional weapons. This section, and Section “destabilizing numbers and types” of advanced conventional weapons. This section, and Section
5(b)(2) pertaining to joint ventures to mine uranium, are the only provisions of ISA that were not 5(b)(2) pertaining to joint ventures to mine uranium, are the only provisions of ISA that were not
waived to implement the JCPOA.waived to implement the JCPOA. As noted earlier, no sanctions under these sections have been As noted earlier, no sanctions under these sections have been
imposed.imposed.
Iran-North Korea-Syria Nonproliferation Act
The Iran Nonproliferation Act (P.L. 106-178, March 2000) became the Iran-North Korea-Syria The Iran Nonproliferation Act (P.L. 106-178, March 2000) became the Iran-North Korea-Syria
Nonproliferation Act (INKSNA) after the enactment of laws expanding its provisions to North Nonproliferation Act (INKSNA) after the enactment of laws expanding its provisions to North
Korea and to Syria. INKSNA authorizes sanctions—for two years unless renewed—on foreign Korea and to Syria. INKSNA authorizes sanctions—for two years unless renewed—on foreign
persons (individuals or companies, not governments) that are determined in a report by the (individuals or companies, not governments) that are determined in a report by the
Administration to have assisted Iran’s WMD programs. Sanctions imposed include (1) a Administration to have assisted Iran’s WMD programs. Sanctions imposed include (1) a
prohibition on U.S. exportation of arms and dual use items to the sanctioned entity; and (2) a ban prohibition on U.S. exportation of arms and dual use items to the sanctioned entity; and (2) a ban
on U.S. government procurement and of imports to the United States from the sanctioned entity on U.S. government procurement and of imports to the United States from the sanctioned entity
under Executive Order 12938 (of November 14, 1994). INKSNA also banned U.S. extraordinary under Executive Order 12938 (of November 14, 1994). INKSNA also banned U.S. extraordinary
payments to the Russian Aviation and Space Agency in connection with the international space payments to the Russian Aviation and Space Agency in connection with the international space
station unless the President certified that the agency had not transferred any WMD or missile station unless the President certified that the agency had not transferred any WMD or missile
technology to Iran within the year prior.35 technology to Iran within the year prior.35
Entities that have been sanctioned under this law are listed in the tables at the end of the report. Entities that have been sanctioned under this law are listed in the tables at the end of the report.
Designations more than two years old are no longer active. The JCPOA required the United States Designations more than two years old are no longer active. The JCPOA required the United States
to suspend INKSNA sanctions against “the acquisition of nuclear-related commodities and to suspend INKSNA sanctions against “the acquisition of nuclear-related commodities and
services for nuclear activities contemplated in the JCPOA.” No INKSNA sanctions were waived. services for nuclear activities contemplated in the JCPOA.” No INKSNA sanctions were waived.
Waiver and Termination. Section 4 gives the President the authority to not impose sanctions if the . Section 4 gives the President the authority to not impose sanctions if the
President justifies that decision to Congress. Section 5 provides for exemptions from sanctions if President justifies that decision to Congress. Section 5 provides for exemptions from sanctions if
certain conditions are met, including that the government with jurisdiction over the entity certain conditions are met, including that the government with jurisdiction over the entity
cooperates to stop future such transfers to Iran. There is no automatic sunset or expiration, or cooperates to stop future such transfers to Iran. There is no automatic sunset or expiration, or
stipulated conditions under which an Administration could terminate its application. stipulated conditions under which an Administration could terminate its application.
Executive Order 13382 on Proliferation-Supporting Entities
Executive Order 13382 (June 28, 2005) allows the President to block the assets of proliferators of Executive Order 13382 (June 28, 2005) allows the President to block the assets of proliferators of
weapons of mass destruction (WMD) and their supporters under the authority granted by the weapons of mass destruction (WMD) and their supporters under the authority granted by the
International Emergency Economic Powers Act (IEEPA; 50 U.S.C. 1701 et seq.), the National International Emergency Economic Powers Act (IEEPA; 50 U.S.C. 1701 et seq.), the National
Emergencies Act (50 U.S.C. 1601 et seq.), and Section 301 of Title 3, Emergencies Act (50 U.S.C. 1601 et seq.), and Section 301 of Title 3, United States Code. The . The

35 The provision contains certain exceptions to ensure the safety of astronauts, but it nonetheless threatened to limit 35 The provision contains certain exceptions to ensure the safety of astronauts, but it nonetheless threatened to limit
U.S. access to the international space station after April 2006, when Russia started charging the United States for U.S. access to the international space station after April 2006, when Russia started charging the United States for
transportation on its Soyuz spacecraft. Legislation in the 109th Congress (S. 1713, P.L. 109-112) amended the provision transportation on its Soyuz spacecraft. Legislation in the 109th Congress (S. 1713, P.L. 109-112) amended the provision
to facilitate continued U.S. access and extended INA sanctions provisions to Syria. to facilitate continued U.S. access and extended INA sanctions provisions to Syria.
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numerous Iranian or Iran-related entities sanctioned under the numerous Iranian or Iran-related entities sanctioned under the ~~Order~~order are listed in the tables at the are listed in the tables at the
end of this report. Entities delisted during U.S. implementation of the JCPOA are in italics. end of this report. Entities delisted during U.S. implementation of the JCPOA are in italics.
Arms Transfer and Missile Sanctions: The Countering America’s
Adversaries through Sanctions Act (CAATSA, P.L. 115-44)
CAATSA (August 2, 2017) mandates sanctions on arms sales to Iran and on entities that CAATSA (August 2, 2017) mandates sanctions on arms sales to Iran and on entities that
“materially contribute” to Iran’s ballistic missile program. “materially contribute” to Iran’s ballistic missile program.
 Section 104 references E.O. 13382 and mandates that the same sanctions as  Section 104 references E.O. 13382 and mandates that the same sanctions as
provided for in that provided for in that ~~Order~~order be imposed on entities determined by the be imposed on entities determined by the
Administration to be assisting Iran’s ballistic missile program or any system Administration to be assisting Iran’s ballistic missile program or any system
capable of delivering weapons of mass destruction (WMD). The section requires capable of delivering weapons of mass destruction (WMD). The section requires
an Administration report every 180 days on persons contributing to Iran’s an Administration report every 180 days on persons contributing to Iran’s
ballistic missile program. ballistic missile program.
 Section 107 mandates the E.O. 13382 sanctions on any person that the President  Section 107 mandates the E.O. 13382 sanctions on any person that the President
determines has sold or transferred to or from Iran, or for the use in or benefit of determines has sold or transferred to or from Iran, or for the use in or benefit of
Iran: the weapons systems specified as banned for transfer to or from Iran in U.N. Iran: the weapons systems specified as banned for transfer to or from Iran in U.N.
Security Council Resolution 2231. These include most major combat systems Security Council Resolution 2231. These include most major combat systems
such as tanks, armored vehicles, warships, missiles, combat aircraft, and attack such as tanks, armored vehicles, warships, missiles, combat aircraft, and attack
helicopters. The imposition of sanctions is not required if the President certifies helicopters. The imposition of sanctions is not required if the President certifies
that Iran no longer poses a significant threat to the United States or U.S. allies; that Iran no longer poses a significant threat to the United States or U.S. allies;
and that the Iranian government no longer satisfies the requirements for and that the Iranian government no longer satisfies the requirements for
designation as a state sponsor of terrorism. designation as a state sponsor of terrorism.
Implementation. The CAATSA provisions on The CAATSA provisions on Iranian arms and missiles have been implemented through arms and missiles have been implemented through
additional designations for sanctions (SDNs) under the additional designations for sanctions (SDNs) under the relevant executive orders referenced in CAATSA.executive orders referenced in CAATSA.
Executive Order 13949 on Sales of Arms (September 21, 2020)
The Trump Administration issued Executive Order 13949Executive Order 13949 ~~was issued~~ after it became clear that the U.N. Security Council would not after it became clear that the U.N. Security Council would not
support U.S. efforts to extend the Resolution 2231 ban on arms transfers to and from Iransupport U.S. efforts to extend the Resolution 2231 ban on arms transfers to and from Iran~~, which~~
that was set to expire on October 18, 2020. The Order blocks U.S property of any entity determined to was set to expire on October 18, 2020. The Order blocks U.S property of any entity determined to
have “materially contribute[d] to the supply, sale, transfer, directly or indirectly, to or from Iran, have “materially contribute[d] to the supply, sale, transfer, directly or indirectly, to or from Iran,
or for the use in or benefit of Iran, of arms or related material, including spare parts.” The or for the use in or benefit of Iran, of arms or related material, including spare parts.” The
provision applies to any entity or person determined to have facilitated or financed such as provision applies to any entity or person determined to have facilitated or financed such as
transaction with Iran, as well as to persons determined to have helped or financed a person or transaction with Iran, as well as to persons determined to have helped or financed a person or
entity sanctioned under the entity sanctioned under the ~~Order~~order. The . The ~~Order~~order appeared to largely restate the provisions of appeared to largely restate the provisions of
CAATSA, discussed aboveCAATSA, discussed above~~, although lacking the specific listing of arms that are stipulated by~~
~~CAATSA.~~
. The United States considers the U.N. arms transfer ban to be in effect pursuant to the U.S. The United States considers the U.N. arms transfer ban to be in effect pursuant to the U.S.
assertion that it triggered a “snapback” of all U.N. sanctions that existed prior to the JCPOA. assertion that it triggered a “snapback” of all U.N. sanctions that existed prior to the JCPOA.
However, the Security Council as a whole However, the Security Council as a whole ~~opposes~~opposed the U.S. position and the U.S. position and ~~does~~did not consider the not consider the
U.N. sanctions to be back in effect. U.N. sanctions to be back in effect. The Biden Administration submitted a letter to the Security Council on February 18, 2021, stating that the administration does not consider U.N. sanctions, including the arms transfer ban, to have snapped back.36 See~~See:~~ CRS In Focus IF11429, CRS In Focus IF11429, U.N. Ban on Iran Arms
Transfers and Sanctions Snapback, by Kenneth Katzman. , by Kenneth Katzman.
36 “Biden withdraws Trump’s restoration of UN sanctions on Iran.” Associated Press, February 18, 2021. Congressional Research Service 23 Iran Sanctions Foreign Aid Restrictions for Named Suppliers of Iran
Some past foreign aid appropriations have withheld U.S. assistance to the Russian Federation Some past foreign aid appropriations have withheld U.S. assistance to the Russian Federation
unless it terminates technical assistance to Iran’s nuclear and ballistic missiles programs. The unless it terminates technical assistance to Iran’s nuclear and ballistic missiles programs. The
~~Congressional Research Service~~
23

~~Iran Sanctions~~

provision applied to the fiscal year for which foreign aid is appropriated. Because U.S. aid to provision applied to the fiscal year for which foreign aid is appropriated. Because U.S. aid to
Russia generally has not gone to the Russian government, little or no funding was withheld. Russia generally has not gone to the Russian government, little or no funding was withheld.
Sanctions on “Countries of Diversion Concern”
Section 303 of CISADA authorizes the President to designate as a “Destination of Diversion Section 303 of CISADA authorizes the President to designate as a “Destination of Diversion
Concern” a country allows substantial diversion of goods, services, or technologies characterized Concern” a country allows substantial diversion of goods, services, or technologies characterized
in Section 302 of that law to Iranian end-users or intermediaries. The technologies include any in Section 302 of that law to Iranian end-users or intermediaries. The technologies include any
goods that could contribute to Iran’s nuclear or WMD programs, as well as goods listed on the goods that could contribute to Iran’s nuclear or WMD programs, as well as goods listed on the
Commerce Control List or Munitions List. For any country designated as a country of diversion Commerce Control List or Munitions List. For any country designated as a country of diversion
concern, there would be prohibition of denial for licenses for U.S. exports to that country of the concern, there would be prohibition of denial for licenses for U.S. exports to that country of the
goods that were being re-exported or diverted to Iran. To date, no country has been designated a goods that were being re-exported or diverted to Iran. To date, no country has been designated a
“Country of Diversion Concern.” Some countries, such as the UAE, have adopted or enforced “Country of Diversion Concern.” Some countries, such as the UAE, have adopted or enforced
anti-proliferation laws apparently to avoid designation. anti-proliferation laws apparently to avoid designation.
Waiver and Termination. The President may waive sanctions on countries designated as of . The President may waive sanctions on countries designated as of
Diversion Concern for 12 months, and additional 12-month periods, pursuant to certification that Diversion Concern for 12 months, and additional 12-month periods, pursuant to certification that
the country is taking steps to prevent diversions and re-exports. The designation terminates on the the country is taking steps to prevent diversions and re-exports. The designation terminates on the
date the President certifies to Congress that the country has adequately strengthened its export date the President certifies to Congress that the country has adequately strengthened its export
controls to prevent such diversion and re-exports to Iran in the future. controls to prevent such diversion and re-exports to Iran in the future.

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Summary of Sanctions on the Islamic Revolutionary Guard Corps (IRGC)
Numerous sanctions target Iran’s Islamic Revolutionary Guard Corps (IRGC), and none was waived or terminated Numerous sanctions target Iran’s Islamic Revolutionary Guard Corps (IRGC), and none was waived or terminated
to implement the JCPOA. The IRGC plays a role in both internal and external defense, supports pro-Iranian to implement the JCPOA. The IRGC plays a role in both internal and external defense, supports pro-Iranian
movements in the region, and owns or controls economic entities in Iran that account for as much as 20% of movements in the region, and owns or controls economic entities in Iran that account for as much as 20% of
Iran’s economic output. Many of the IRGC’s subordinate units, such as the IRGC Qods Force and the Basij militia, Iran’s economic output. Many of the IRGC’s subordinate units, such as the IRGC Qods Force and the Basij militia,
have been designated for sanctions under various Executive Orders, as have corporate entities owned or have been designated for sanctions under various Executive Orders, as have corporate entities owned or
~~control ed~~controlled by the IRGC, such as the large engineering firm Khatam ol-Anbia. by the IRGC, such as the large engineering firm Khatam ol-Anbia.
 
The IRGC has been named as a proliferation-supporting entity under Executive Order 13382, a human rights The IRGC has been named as a proliferation-supporting entity under Executive Order 13382, a human rights
abuser under E.O. 13553 and, in accordance with the Countering America’s Adversaries through Sanctions abuser under E.O. 13553 and, in accordance with the Countering America’s Adversaries through Sanctions
Act (P.L. 115-44), it was named a terrorism-supporter under E.O. 13224 (October 13, 2017). The IRGC-Act (P.L. 115-44), it was named a terrorism-supporter under E.O. 13224 (October 13, 2017). The IRGC-
Qods Force (IRGC-QF), the unit of the IRGC that assists pro-Iranian movements abroad, is named as a Qods Force (IRGC-QF), the unit of the IRGC that assists pro-Iranian movements abroad, is named as a
terrorism-supporting entity under Executive Order 13324 and a repressor of the Syrian people under E.O. terrorism-supporting entity under Executive Order 13324 and a repressor of the Syrian people under E.O.
13572. Hundreds of IRGC-linked entities—companies, facilitators and financial partners, and commanders—13572. Hundreds of IRGC-linked entities—companies, facilitators and financial partners, and commanders—
are designated for sanctions under those and other orders, as noted in the tables at the end of this report. are designated for sanctions under those and other orders, as noted in the tables at the end of this report.
 
IFCA (Section 1244) mandates that any entity that knowingly conducts transactions with a designated Iranian IFCA (Section 1244) mandates that any entity that knowingly conducts transactions with a designated Iranian
entity is subject to having its U.S.-based assets blocked. entity is subject to having its U.S.-based assets blocked.
 
ITRSHRA (Section 302) imposes at least 5 out of 12 ISA sanctions on persons that materially assist, with ITRSHRA (Section 302) imposes at least 5 out of 12 ISA sanctions on persons that materially assist, with
financing or technology, the IRGC, or assist or engage in “significant” transactions with any of its affiliates that financing or technology, the IRGC, or assist or engage in “significant” transactions with any of its affiliates that
are sanctioned under Executive Order 13382, 13224, or similar executive orders—or which are determined are sanctioned under Executive Order 13382, 13224, or similar executive orders—or which are determined
to be affiliates of the IRGC. Sto be affiliates of the IRGC. Section 302 did not amend ISA.
 
ITRSHRA (Section 311) requires a certification by a contractor to the U.S. government that it is not ITRSHRA (Section 311) requires a certification by a contractor to the U.S. government that it is not
knowingly engaging in a significant transaction with the IRGC, or any of its agents or affiliates that have been knowingly engaging in a significant transaction with the IRGC, or any of its agents or affiliates that have been
sanctioned under several executive orders discussed below. A contract may be terminated if it is determined sanctioned under several executive orders discussed below. A contract may be terminated if it is determined
that the company’s certification of compliance was false. that the company’s certification of compliance was false.
 
ITRSHRA (Section 301) requires the President to identify “officials, agents, or affiliates” of the IRGC and to ITRSHRA (Section 301) requires the President to identify “officials, agents, or affiliates” of the IRGC and to
impose sanctions in accordance with Executive Order 13382 or 13224. Some of these designations, including impose sanctions in accordance with Executive Order 13382 or 13224. Some of these designations, including
of National Iranian Oil Company (NIOC), were made by the Treasury Department on November 8, 2012. of National Iranian Oil Company (NIOC), were made by the Treasury Department on November 8, 2012.
 
ITRSHRA (Section 303) requires the imposition of sanctions on agencies of foreign governments that ITRSHRA (Section 303) requires the imposition of sanctions on agencies of foreign governments that
provide technical or financial support, or goods and services to sanctioned (under U.S. executive orders or provide technical or financial support, or goods and services to sanctioned (under U.S. executive orders or
U.N. resolutions) members or affiliates of the IRGC. Sanctions include a ban on U.S. assistance or credits for U.N. resolutions) members or affiliates of the IRGC. Sanctions include a ban on U.S. assistance or credits for
that foreign government agency, a ban on defense sales to it, a ban on U.S. arms sales to it, and a ban on that foreign government agency, a ban on defense sales to it, a ban on U.S. arms sales to it, and a ban on
exports to it of exports to it of ~~control ed~~controlled U.S. technology. U.S. technology.
 
Section 104 of CISADA sanctions foreign banks that conduct significant transactions with the IRGC or any of Section 104 of CISADA sanctions foreign banks that conduct significant transactions with the IRGC or any of
its agents or affiliates that are sanctioned under any executive order. It also sanctions any entity that assists its agents or affiliates that are sanctioned under any executive order. It also sanctions any entity that assists
Iran’s Central Bank efforts to help the IRGC acquire WMD or support international terrorism. Iran’s Central Bank efforts to help the IRGC acquire WMD or support international terrorism.
 
In October 2018, 20 economic entities, including a steel company and acid and zinc mining firms, were In October 2018, 20 economic entities, including a steel company and acid and zinc mining firms, were
sanctioned under E.O 13224 for providing revenue to the Basij militia, an arm of the IRGC. sanctioned under E.O 13224 for providing revenue to the Basij militia, an arm of the IRGC.
 
On April 8, 2019, the Trump Administration named the IRGC as a Foreign Terrorist Organization (FTO) On April 8, 2019, the Trump Administration named the IRGC as a Foreign Terrorist Organization (FTO)
under Section 219 of the Immigration and Nationality Act (8 U.S.C. 819). In addition to the sanctions above, under Section 219 of the Immigration and Nationality Act (8 U.S.C. 819). In addition to the sanctions above,
the FTO designation provides for criminal penalties for U.S. persons or any bank that knowingly provides the FTO designation provides for criminal penalties for U.S. persons or any bank that knowingly provides
“material support” to an FTO (ex. donations, facilitation of its activities). “material support” to an FTO (ex. donations, facilitation of its activities).
 
On September 4, 2019, U.S. officials announced that they are using the State Department’s “Rewards for On September 4, 2019, U.S. officials announced that they are using the State Department’s “Rewards for
Justice” program that provides reward money for information about potential terrorist plots for Iran. The Justice” program that provides reward money for information about potential terrorist plots for Iran. The
reward monies are to be used to disrupt Iran’s oil shipments and obtain information on the IRGC’s financial reward monies are to be used to disrupt Iran’s oil shipments and obtain information on the IRGC’s financial
operations. The basis for the Administration use of that program, as well as related sanctions designations in operations. The basis for the Administration use of that program, as well as related sanctions designations in
August and September 2019, was an asserted linkage between the IRGC and Iran’s oil exportation. August and September 2019, was an asserted linkage between the IRGC and Iran’s oil exportation.
Financial/Banking Sanctions
U.S. efforts to shut Iran out of the international banking system were a key component of the U.S. efforts to shut Iran out of the international banking system were a key component of the
2010-2016 international sanctions regime. 2010-2016 international sanctions regime.
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Targeted Financial Measures
During 2006-2016, the Department of the Treasury conducted a campaign—which it termed During 2006-2016, the Department of the Treasury conducted a campaign—which it termed
“targeted financial measures”—to persuade foreign banks to cease transactions with Iran. During “targeted financial measures”—to persuade foreign banks to cease transactions with Iran. During
the effort, Treasury officials briefed bank officials on Iran’s use of the international financial the effort, Treasury officials briefed bank officials on Iran’s use of the international financial
system to fund terrorist groups and acquire weapons-related technology. According to a GAO system to fund terrorist groups and acquire weapons-related technology. According to a GAO
report of February 2013, the Department of the Treasury report of February 2013, the Department of the Treasury ~~made overtures to 145 banks in 60~~
~~countries, and~~ convinced at least 80 of them cease handling financial transactions with Iranian convinced at least 80 of them cease handling financial transactions with Iranian
banks. During the period of U.S. implementation of the JCPOA, the Treasury Department banks. During the period of U.S. implementation of the JCPOA, the Treasury Department ~~instead~~
sought to encourage foreign banks to conduct normal transactions with Iran. sought to encourage foreign banks to conduct normal transactions with Iran.
Ban on Iranian Access to the U.S. Financial System/Use of Dollars
U.S. regulations (ITRs, C.F.R. Section 560.516) ban Iran from direct access to the U.S. financial U.S. regulations (ITRs, C.F.R. Section 560.516) ban Iran from direct access to the U.S. financial
system. The regulations allow U.S. banks to send funds (including U.S. dollars) to Iran for system. The regulations allow U.S. banks to send funds (including U.S. dollars) to Iran for
allowed (licensed) transactions, but U.S. dollars must be paid through a third country bank. allowed (licensed) transactions, but U.S. dollars must be paid through a third country bank.
Section 560.510 of the Iran regulations allows for U.S. payments to Iran to settle or pay Section 560.510 of the Iran regulations allows for U.S. payments to Iran to settle or pay
judgments to Iran, but the prohibition on dealing directly with Iranian banks applies. As of judgments to Iran, but the prohibition on dealing directly with Iranian banks applies. As of
November 6, 2008, the regulations have also barred foreign banks or persons from accessing the November 6, 2008, the regulations have also barred foreign banks or persons from accessing the
U.S. financial system (through a U.S. correspondent account) to acquire dollars for any U.S. financial system (through a U.S. correspondent account) to acquire dollars for any
transaction involving Iran (“U-turn transactions”).transaction involving Iran (“U-turn transactions”).3637 There is no blanket ban on foreign banks or There is no blanket ban on foreign banks or
persons paying Iran for goods using U.S. dollars, provided they do not access the U.S. financial persons paying Iran for goods using U.S. dollars, provided they do not access the U.S. financial
system to replenish their supply of dollars to accomplish their transactions with Iran. system to replenish their supply of dollars to accomplish their transactions with Iran.
These regulations remained in effect during JCPOA implementation, and Iran argued that the These regulations remained in effect during JCPOA implementation, and Iran argued that the
restrictions deterred European and other banks from reentering the Iran market because of the restrictions deterred European and other banks from reentering the Iran market because of the
difficulty in paying Iran with U.S. dollars. In 2016, the Obama Administration reportedly difficulty in paying Iran with U.S. dollars. In 2016, the Obama Administration reportedly
consideredconsidered, but did not adopt, a policy of licensing transactions by foreign clearinghouses to acquire dollars that might facilitate licensing transactions by foreign clearinghouses to acquire dollars that might facilitate
transactions with Irantransactions with Iran~~, but the Administration did not take that step. 37~~. 38
Punishments/Fines Implemented against Some Banks.
The Department of the Treasury and other U.S. authorities have announced financial settlements The Department of the Treasury and other U.S. authorities have announced financial settlements
with various banks that violated U.S. regulations in transactions related to Iran (and other with various banks that violated U.S. regulations in transactions related to Iran (and other
countries such as Sudan, Syria, and Cuba). The amounts were reportedly determined, at least in countries such as Sudan, Syria, and Cuba). The amounts were reportedly determined, at least in
part, by the value, number, and duration of illicit transactions conducted, and the strength of the part, by the value, number, and duration of illicit transactions conducted, and the strength of the
evidence collected by U.S. regulators.evidence collected by U.S. regulators.3839 (The FY2016 Consolidated Appropriation, P.L. 114-113, (The FY2016 Consolidated Appropriation, P.L. 114-113,
provided for use of the proceeds of the settlements compensate victims of Iranian terrorism.) provided for use of the proceeds of the settlements compensate victims of Iranian terrorism.)

3637 For text of the OFAC ruling barring U-Turn transactions, see https://www.treasury.gov/resource-center/sanctions/ For text of the OFAC ruling barring U-Turn transactions, see https://www.treasury.gov/resource-center/sanctions/
Documents/fr73_66541.pdf. Documents/fr73_66541.pdf.
3738 Washington Institute for Near East Policy. “Potential U.S. Clarification of Financial Sanctions Regulations,” by Washington Institute for Near East Policy. “Potential U.S. Clarification of Financial Sanctions Regulations,” by
Katharine Bauer. April 5, 2016. Katharine Bauer. April 5, 2016.
3839 Analyst conversations with U.S. banking and sanctions experts, 2010-2015. Analyst conversations with U.S. banking and sanctions experts, 2010-2015.
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Table 2. Major Settlements/Fines Paid by Banks for Violations
Amount
Bank
Date
Paid
Violation
UBS (Switzerland) UBS (Switzerland)
2004 2004
$100 $100 ~~mil ion~~million
Unauthorized movement of U.S. Unauthorized movement of U.S. ~~dol ars~~dollars to to
Iran and others Iran and others
ABN Amro (Netherlands) ABN Amro (Netherlands)
December 2005 December 2005
$80 $80 ~~mil ion~~million
Failing to Failing to ~~ful y~~fully report financial transactions report financial transactions
involving Bank Melli involving Bank Melli
Credit Suisse (Switzerland) Credit Suisse (Switzerland)
December 2009 December 2009
$536 $536 ~~mil ion~~
~~Il icitly~~million Illicitly processing Iranian transactions with processing Iranian transactions with
U.S. banks U.S. banks
ING (Netherlands) ING (Netherlands)
June 2012 June 2012
$619 $619 ~~mil ion~~million
Concealing movement of Concealing movement of ~~bil ions of dol ars~~billions of dollars
through the U.S. financial system for Iranian through the U.S. financial system for Iranian
and Cuban clients. and Cuban clients.
Standard Chartered (UK) Standard Chartered (UK)
August 2012 August 2012
$340 $340 ~~mil ion~~million
Settlement paid to New York State for Settlement paid to New York State for
processing transactions on behalf of Iran processing transactions on behalf of Iran
Clearstream (Luxembourg) Clearstream (Luxembourg)
January 2014 January 2014
$152 $152 ~~mil ion~~million
Helping Iran evade U.S. banking restrictions Helping Iran evade U.S. banking restrictions
Bank of Moscow (Russia) Bank of Moscow (Russia)
January 2014 January 2014
$9.5 $9.5 ~~mil ion~~
~~Il icitly~~million Illicitly allowing Bank Melli to access the U.S. allowing Bank Melli to access the U.S.
financial system financial system
BNP Paribas BNP Paribas
June 2014 June 2014
$9 $9 ~~bil ion~~billion
Amount forfeited for helping Iran (and Amount forfeited for helping Iran (and
Sudan and Cuba) violate U.S. sanction. Sudan and Cuba) violate U.S. sanction.
Standard Chartered (UK) Standard Chartered (UK)
April 2019 April 2019
$639 $639 ~~mil ion~~million
Dubai branch of Standard Chartered Dubai branch of Standard Chartered
processed Iran-related transactions to or processed Iran-related transactions to or
through Standard Chartered–New York. through Standard Chartered–New York.
Unicredit AG (Germany, Unicredit AG (Germany,
April 2019 April 2019
$1.3 $1.3 ~~bil ion~~
~~For il icitly~~billion For illicitly processing transactions through processing transactions through
Austria, Italy) Austria, Italy)
the U.S. financial system on behalf of Islamic the U.S. financial system on behalf of Islamic
Republic of Iran Shipping Lines (IRISL) Republic of Iran Shipping Lines (IRISL)
Halkbank Halkbank
October 2019 October 2019
N/A N/A
Justice Department filed charges against Justice Department filed charges against
Halkbank for allegedly helping Iran evade Halkbank for allegedly helping Iran evade
U.S. sanctions U.S. sanctions
Source: Various press reports. Various press reports.
CISADA: Sanctioning Foreign Banks That Conduct Transactions
with Sanctioned Iranian Entities
The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) was enacted The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) was enacted
to try to limit Iran’s access to the international financial system and to reduce the ability of Iran’s to try to limit Iran’s access to the international financial system and to reduce the ability of Iran’s
import-export community (referred to in Iran as the “bazaar merchants” or “import-export community (referred to in Iran as the “bazaar merchants” or “bazaaris”) from ”) from
obtaining “letters of credit” (trade financing) to buy or sell goods. Section 104 of CISADA obtaining “letters of credit” (trade financing) to buy or sell goods. Section 104 of CISADA
requires the Secretary of the Treasury to forbid U.S. banks from opening new “correspondent requires the Secretary of the Treasury to forbid U.S. banks from opening new “correspondent
accounts” or “payable-through accounts” (cancel existing such accounts) accounts” or “payable-through accounts” (cancel existing such accounts) ~~for:39~~for40
 Any foreign bank that conducts a significant financial transaction with an entity  Any foreign bank that conducts a significant financial transaction with an entity
that is sanctioned by Executive Order 13224 or 13382 (see above). No that is sanctioned by Executive Order 13224 or 13382 (see above). No
~~humanitarian exception is provided for. A full list of sanctioned entities is at the~~
~~end of this report, and entities “delisted” are in italics.~~

3940 Foreign banks that do not have operations in the United States typically establish correspondent accounts or payable- Foreign banks that do not have operations in the United States typically establish correspondent accounts or payable-
through accounts with U.S. banks as a means of accessing the U.S. financial system. The Department of the Treasury through accounts with U.S. banks as a means of accessing the U.S. financial system. The Department of the Treasury
determines the amount money that constitutes a “significant” financial transaction. determines the amount money that constitutes a “significant” financial transaction.
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Foreign central banks generally do not maintain correspondent or payable-through accounts in the U.S. banks. Congressional Research Service 27 Iran Sanctions humanitarian exception is provided for. A full list of sanctioned entities is at the end of this report, and entities “delisted” are in italics.  Any foreign bank determined to have facilitated Iran’s efforts to acquire WMD  Any foreign bank determined to have facilitated Iran’s efforts to acquire WMD
or delivery systems or provide support to groups named as FTOs. or delivery systems or provide support to groups named as FTOs.
 Any foreign bank that facilitates “the activities of” an entity sanctioned under a  Any foreign bank that facilitates “the activities of” an entity sanctioned under a
U.N. Security Council resolution. U.N. Security Council resolution.
 Any foreign bank that transacts business with the IRGC or any of its affiliates  Any foreign bank that transacts business with the IRGC or any of its affiliates
designated under any Executive Order. designated under any Executive Order.
Section 1244(d) of the Iran Freedom and Counter-proliferation Act, IFCA, applies the CISADA Section 1244(d) of the Iran Freedom and Counter-proliferation Act, IFCA, applies the CISADA
sanctions to any foreign bank that does business with Iran’s energy, shipping, and shipbuilding sanctions to any foreign bank that does business with Iran’s energy, shipping, and shipbuilding
sectors, including with NIOC, NITC, and IRISL. The provision was not an amendment to sectors, including with NIOC, NITC, and IRISL. The provision was not an amendment to
CISADA itself. The IFCA provision was waived during U.S. implementation of the JCPOA. CISADA itself. The IFCA provision was waived during U.S. implementation of the JCPOA.
Implementation
Some sanctions have been imposed under Section 104 of CISADA. On July 31, 2012, the United Some sanctions have been imposed under Section 104 of CISADA. On July 31, 2012, the United
States sanctioned the Bank of Kunlun in China and the Elaf Islamic Bank in Iraq under Section States sanctioned the Bank of Kunlun in China and the Elaf Islamic Bank in Iraq under Section
104 of CISADA. On May 17, 2013, the Department of the Treasury lifted sanctions on Elaf 104 of CISADA. On May 17, 2013, the Department of the Treasury lifted sanctions on Elaf
Islamic Bank in Iraq, asserting that the bank had reduced its exposure to the Iranian financial Islamic Bank in Iraq, asserting that the bank had reduced its exposure to the Iranian financial
sector and stopped providing services to the Export Development Bank of Iran. Section 104 was sector and stopped providing services to the Export Development Bank of Iran. Section 104 was
not waived to implement the JCPOA, but during JCPOA implementation, many entities with not waived to implement the JCPOA, but during JCPOA implementation, many entities with
which transactions would have triggered sanctions under Section 104 were “delisted” as Specially which transactions would have triggered sanctions under Section 104 were “delisted” as Specially
Designated Nationals (SDNs), as provided by the JCPOA. Designated Nationals (SDNs), as provided by the JCPOA.
On October 8, 2020, in order to more comprehensively shut Iran’s banks out of the international On October 8, 2020, in order to more comprehensively shut Iran’s banks out of the international
financial system, the financial system, the Trump Administration designated many of Iran’s remaining un-sanctioned banks Administration designated many of Iran’s remaining un-sanctioned banks
for sanctions under E.O. 13902. A general license (L) was issued concurrently in order to make for sanctions under E.O. 13902. A general license (L) was issued concurrently in order to make
purely humanitarian transactions with the newly-designated banks permissible.purely humanitarian transactions with the newly-designated banks permissible.4041
Waiver and Termination
Under Section 401(a) of CISADA, the Section 104 sanctions provisions would terminate 30 days Under Section 401(a) of CISADA, the Section 104 sanctions provisions would terminate 30 days
after the President certifies to Congress that Iran (1) has met the requirements for removal from after the President certifies to Congress that Iran (1) has met the requirements for removal from
the terrorism list, the terrorism list, and (2) has ceased pursuit, acquisition, or development of, and verifiably (2) has ceased pursuit, acquisition, or development of, and verifiably
dismantled its nuclear weapons and other WMD programs. dismantled its nuclear weapons and other WMD programs.
The Secretary of the Treasury may waive sanctions under Section 104, with the waiver taking The Secretary of the Treasury may waive sanctions under Section 104, with the waiver taking
effect 30 days after the Secretary determines that a waiver is necessary to the national interest and effect 30 days after the Secretary determines that a waiver is necessary to the national interest and
submits a report to Congress describing the reason for that determination. submits a report to Congress describing the reason for that determination.
Iran Designated a Money-Laundering Jurisdiction
On November 21, 2011, the Obama Administration identified Iran as a “jurisdiction of primary On November 21, 2011, the Obama Administration identified Iran as a “jurisdiction of primary
money laundering concern”money laundering concern”4142 under Section 311 of the USA Patriot Act (31 U.S.C. 5318A), based under Section 311 of the USA Patriot Act (31 U.S.C. 5318A), based
on a determination that Iran’s financial system constitutes a threat to governments or financial on a determination that Iran’s financial system constitutes a threat to governments or financial
41 Department of the Treasury. October 8, 2020. 42 Federal Register. Finding That the Islamic Republic of Iran Is a Jurisdiction of Primary Money Laundering Concern. November 25, 2011. Congressional Research Service 28 Iran Sanctions institutions that do business with Iran’s banks. The designation imposed additional requirements institutions that do business with Iran’s banks. The designation imposed additional requirements
on U.S. banks to ensure againston U.S. banks to ensure against ~~improper~~ Iranian access to the U.S. financial system. On October Iranian access to the U.S. financial system. On October
25, 2019, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a 25, 2019, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a

~~40 Department of the Treasury. October 8, 2020.~~
~~41 Federal Register. Finding That the Islamic Republic of Iran Is a Jurisdiction of Primary Money Laundering Concern.~~
~~November 25, 2011.~~
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final rule barring the U.S. financial system from any transactions with Iranian banks or foreign final rule barring the U.S. financial system from any transactions with Iranian banks or foreign
banks acting on behalf of Iranian banks.banks acting on behalf of Iranian banks.4243
In October 2018, the Treasury Department Financial Crimes Enforcement Network (FINCEN) In October 2018, the Treasury Department Financial Crimes Enforcement Network (FINCEN)
issued a warning to U.S. banks to guard against likely Iranian efforts to evade U.S. financial issued a warning to U.S. banks to guard against likely Iranian efforts to evade U.S. financial
sanctions. Earlier, in January 1, 2013, OFAC issued an Advisory to highlight Iran’s use of sanctions. Earlier, in January 1, 2013, OFAC issued an Advisory to highlight Iran’s use of
hawalas (traditional informal banking and money exchanges) to circumvent U.S. sanctions. (traditional informal banking and money exchanges) to circumvent U.S. sanctions.
Financial Action Task Force (FATF)
In 2016, the Financial Action Task Force (FATF), a multilateral body that shares best practices to In 2016, the Financial Action Task Force (FATF), a multilateral body that shares best practices to
combat money laundering and the financing of terrorism (AML/CFT), named Iran a “High Risk combat money laundering and the financing of terrorism (AML/CFT), named Iran a “High Risk
Jurisdiction.” In June 2016, the FATF welcomed an “Action Plan” filed by Iran to address its Jurisdiction.” In June 2016, the FATF welcomed an “Action Plan” filed by Iran to address its
strategic AML/CFT deficiencies and suspended “countermeasures”—mostly voluntary strategic AML/CFT deficiencies and suspended “countermeasures”—mostly voluntary
recommendations of increased due diligence with respect to Iran transactions—pending an recommendations of increased due diligence with respect to Iran transactions—pending an
assessment of Iran’s implementation of its Action Plan.assessment of Iran’s implementation of its Action Plan. ~~The FATF continued the suspension of~~
~~countermeasures until 2020.~~
In June 2019, the FATF stated that Iran still had not adequately criminalized terrorist financing, In June 2019, the FATF stated that Iran still had not adequately criminalized terrorist financing,
including by removing the exemption for designated groups “attempting to end foreign including by removing the exemption for designated groups “attempting to end foreign
occupation, colonialism and racism;” identified and frozen terrorist assets in line with the relevant occupation, colonialism and racism;” identified and frozen terrorist assets in line with the relevant
United Nations Security Council resolutions; or ensured an adequate and enforceable customer United Nations Security Council resolutions; or ensured an adequate and enforceable customer
due diligence regime. The FATF continued the suspension of countermeasures, but called on due diligence regime. The FATF continued the suspension of countermeasures, but called on
members to require increased supervisory examination for branches and subsidiaries of financial members to require increased supervisory examination for branches and subsidiaries of financial
institutions based in Iran.institutions based in Iran.4344 On February 21, 2020, the FATF stated that “given Iran’s failure to On February 21, 2020, the FATF stated that “given Iran’s failure to
enact the Palermo and Terrorist Financing Conventions in line with the FATF Standards, the enact the Palermo and Terrorist Financing Conventions in line with the FATF Standards, the
FATF fully lifts the suspension of counter-measures and calls on its members and urges all FATF fully lifts the suspension of counter-measures and calls on its members and urges all
jurisdictions to apply effective counter-measures, in line with Recommendation 19”—a jurisdictions to apply effective counter-measures, in line with Recommendation 19”—a
determination that subjects Iran’s financial system to increased scrutiny by banks worldwide.determination that subjects Iran’s financial system to increased scrutiny by banks worldwide.4445 In December 20120, Iran’s President Rouhani requested that the Expediency Council – Iran’s arbitration body – be tasked with reviewing legislation to bring the country into compliance with the FATF requirements.
“SWIFT” Electronic Payments System
Section 220 of the ITRSHRA required reports on electronic payments systems, such as the Section 220 of the ITRSHRA required reports on electronic payments systems, such as the
Brussels-based SWIFT (Society of Worldwide Interbank Financial Telecommunications), that Brussels-based SWIFT (Society of Worldwide Interbank Financial Telecommunications), that
process transactions for Iranian banks. That law also authorizes, but does not mandate, sanctions process transactions for Iranian banks. That law also authorizes, but does not mandate, sanctions
against SWIFT or against electronic payments systems. against SWIFT or against electronic payments systems.
Sanctions on Iran’s Non-Oil Industries and Sectors
Successive Administrations and Congresses have expanded sanctions on several significant non-Successive Administrations and Congresses have expanded sanctions on several significant non-
oil industries and sectors of Iran’s economy. The targeted sectors include Iran’s automotive oil industries and sectors of Iran’s economy. The targeted sectors include Iran’s automotive
~~production sector, which is Iran’s second-largest industry (after energy), its mineral exports,~~
~~which account for about 10% of Iran’s export earnings, and various light manufacturing sectors.~~

4243 Treasury and State Announce New Humanitarian Mechanism to Increase Transparency of Permissible Trade Treasury and State Announce New Humanitarian Mechanism to Increase Transparency of Permissible Trade
Supporting the Iranian People. October 25, 2019. Supporting the Iranian People. October 25, 2019.
4344 Statement by the Financial Action Task Force, June 19, 2019. Statement by the Financial Action Task Force, June 19, 2019.
4445 Statement by the Financial Action Task Force, February 21, 2020. Statement by the Financial Action Task Force, February 21, 2020.
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Iran Sanctions

production sector, which is Iran’s second-largest industry (after energy), its mineral exports, which account for about 10% of Iran’s export earnings, and various light manufacturing sectors. The Iran Freedom and Counter-Proliferation Act (IFCA)
The Iran Freedom and The Iran Freedom and ~~Counterproliferation~~Counter-proliferation Act (IFCA, Subtitle D of the National Defense Act (IFCA, Subtitle D of the National Defense
Authorization Act for FY2013 (P.L. 112-239, January 2, 2013) sanctioned several Iranian Authorization Act for FY2013 (P.L. 112-239, January 2, 2013) sanctioned several Iranian
economic sectors simultaneously. IFCA’s provisions on Iran’s human rights practices are economic sectors simultaneously. IFCA’s provisions on Iran’s human rights practices are
discussed below. Most IFCA sections were waived during JCPOA implementation (2016-18). discussed below. Most IFCA sections were waived during JCPOA implementation (2016-18).
 Section 1244 of IFCA mandates the blocking of U.S.-based property of any entity  Section 1244 of IFCA mandates the blocking of U.S.-based property of any entity
(Iranian or non-Iranian) that provides goods, services, or other support to any (Iranian or non-Iranian) that provides goods, services, or other support to any
Iranian entity designated by the Treasury Department as a “specially designated Iranian entity designated by the Treasury Department as a “specially designated
national” (SDN). The tables at the end of this report show that hundreds of national” (SDN). The tables at the end of this report show that hundreds of
Iranian entities are designated as SDNs under various executive orders. The Iranian entities are designated as SDNs under various executive orders. The
Iranian entities designated for civilian economic activity were “delisted” to Iranian entities designated for civilian economic activity were “delisted” to
implement the JCPOA, but were relisted on November 5, 2018. implement the JCPOA, but were relisted on November 5, 2018.
 Section 1247 of IFCA prohibits from operating in the United States any bank that  Section 1247 of IFCA prohibits from operating in the United States any bank that
knowingly facilitates a financial transaction on behalf of an Iranian SDN. The knowingly facilitates a financial transaction on behalf of an Iranian SDN. The
section also specifically sanctions foreign banks that facilitate payment to Iran section also specifically sanctions foreign banks that facilitate payment to Iran
for natural gas unless the funds owed to Iran for the gas are placed in a local for natural gas unless the funds owed to Iran for the gas are placed in a local
account. The section provides for a waiver for a period of 180 days. account. The section provides for a waiver for a period of 180 days.
Several sections of IFCA impose ISA sanctions Several sections of IFCA impose ISA sanctions on entities determined to have engaged in on entities determined to have engaged in
specified transactions below. (specified transactions below. (The provisions apply ISA sanctions but do not amend ISA.)
  Energy, Shipbuilding, and Shipping Sector, and Iranian Port Operations. Section Section
1244 (1) blocks the U.S.-based assets; 1244 (1) blocks the U.S.-based assets; and (2) mandates the imposition of five (2) mandates the imposition of five
out of 12 of the ISA menu of sanctions (see above) on entities that provide out of 12 of the ISA menu of sanctions (see above) on entities that provide
financial, material, technological, or other support, or provide goods or services financial, material, technological, or other support, or provide goods or services
to Iran’s energy, shipbuilding, and shipping sectors, or port operations in Iran. to Iran’s energy, shipbuilding, and shipping sectors, or port operations in Iran.
The sanctions do not apply when such transactions involved purchases of Iranian
oil by countries that have SREs (see above) or to the purchase of natural gas
from Iran.
  Dealings in Precious Metals or Materials for Iran’s Missile, Nuclear, or Military
Programs. Section 1245 imposes five out of the 12 sanctions on the ISA menu on Section 1245 imposes five out of the 12 sanctions on the ISA menu on
entities that provide precious metals to Iran (including gold) or semi-finished entities that provide precious metals to Iran (including gold) or semi-finished
metals or software for integrating industrial processes. Section 1245 also metals or software for integrating industrial processes. Section 1245 also
sanctions the supply to Iran of any material determined to be used in connection sanctions the supply to Iran of any material determined to be used in connection
with Iran’s nuclear, missile, or military programs. The section mandates the with Iran’s nuclear, missile, or military programs. The section mandates the
exclusion from the United States of any foreign bank that facilitates any exclusion from the United States of any foreign bank that facilitates any
stipulated transaction. stipulated transaction. There is no exception for countries that receive the SRE.
  Insurance for Related Activities. Section 1246 imposes five out of 12 sanctions Section 1246 imposes five out of 12 sanctions
on the ISA menu on entities that provide underwriting services, insurance, or on the ISA menu on entities that provide underwriting services, insurance, or
reinsurance for any transactions sanctioned under any executive order on Iran, reinsurance for any transactions sanctioned under any executive order on Iran,
ISA, CISADA, the Iran Threat Reduction Act, INKSNA, other IFCA provisions, ISA, CISADA, the Iran Threat Reduction Act, INKSNA, other IFCA provisions,
or any other Iran sanction, as well as to any Iranian SDN. or any other Iran sanction, as well as to any Iranian SDN. There is no exception
for countries that receive the SRE.
Congressional Research Service 30 Iran Sanctions   Exception for Afghanistan Reconstruction. Section 1244(f) of IFCA provides a . Section 1244(f) of IFCA provides a
sanctions exemption for transactions that provide reconstruction assistance for or sanctions exemption for transactions that provide reconstruction assistance for or
further the economic development of Afghanistan. See JCPOA waivers below. further the economic development of Afghanistan. See JCPOA waivers below.
~~Congressional Research Service~~
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Implementation
The entities designated for sanctions under E.O. 13224, 13382, and other orders—which are The entities designated for sanctions under E.O. 13224, 13382, and other orders—which are
listed in the tables at the end of the report—trigger the IFCA sanctions discussed above. Some listed in the tables at the end of the report—trigger the IFCA sanctions discussed above. Some
sanctions have been imposed for transactions with the Iranian sectors stipulated in IFCA, as sanctions have been imposed for transactions with the Iranian sectors stipulated in IFCA, as
shown in the tables at the end of the report. shown in the tables at the end of the report.
Waiver and Termination
Sections 1244 and 1245 of IFCA provide for a waiver of sanctions for 180 days, if such a waiver Sections 1244 and 1245 of IFCA provide for a waiver of sanctions for 180 days, if such a waiver
is determined to be vital to U.S. national security. Sections 1244(i), 1245(g), 1246(e), and 1247(f) is determined to be vital to U.S. national security. Sections 1244(i), 1245(g), 1246(e), and 1247(f)
of IFCA were waived to implement the JCPOA on January 18, 2017, and that waiver was last of IFCA were waived to implement the JCPOA on January 18, 2017, and that waiver was last
renewed on January 12, 2018. All sections of IFCA went back into effect in 2018 in concert with renewed on January 12, 2018. All sections of IFCA went back into effect in 2018 in concert with
the U.S. exit from the JCPOA. the U.S. exit from the JCPOA.
Executive Order 13645/13846: Iran’s Automotive Sector, Rial
Trading, and Precious Stones
Executive Order 13645 of June 3, 2013, as superseded by 13846 of August 6, 2018Executive Order 13645 of June 3, 2013, as superseded by 13846 of August 6, 2018:,
 Imposes ISA sanctions on firms that supply goods or services to Iran’s  Imposes ISA sanctions on firms that supply goods or services to Iran’s
automotive production sector, and blocks foreign banks from the U.S. market if automotive production sector, and blocks foreign banks from the U.S. market if
they conduct transactions with Iran’s automotive sector. they conduct transactions with Iran’s automotive sector.
 Blocks U.S.-based property and prohibits U.S. bank accounts for foreign banks  Blocks U.S.-based property and prohibits U.S. bank accounts for foreign banks
that conduct transactions in Iran’s currency, the that conduct transactions in Iran’s currency, the rial, or hold , or hold rial accounts. The accounts. The
order would presumably apply to any digital currency that Iran might develop order would presumably apply to any digital currency that Iran might develop
that is backed by or tied to the that is backed by or tied to the rial. .
 Expands the application of Executive Order 13622 (above) to helping Iran  Expands the application of Executive Order 13622 (above) to helping Iran
acquire precious stones or jewels (see above). acquire precious stones or jewels (see above).
 Blocks U.S.-based property of a person that conducts transactions with an Iranian  Blocks U.S.-based property of a person that conducts transactions with an Iranian
entity listed as a Specially Designated National (SDN) or Blocked Person. As entity listed as a Specially Designated National (SDN) or Blocked Person. As
noted earlier, all SDNs were “relisted” on November 5, 2018. noted earlier, all SDNs were “relisted” on November 5, 2018.
Executive Order 13871 on Iran’s Minerals and Metals Sectors
On May 8, 2019, President Trump issued Executive Order 13871 sanctioning transactions On May 8, 2019, President Trump issued Executive Order 13871 sanctioning transactions
involving Iran’s minerals and industrial commodities. The announcement stated that Iran earns involving Iran’s minerals and industrial commodities. The announcement stated that Iran earns
10% of its total export revenues from sales of the minerals and metals sanctioned.10% of its total export revenues from sales of the minerals and metals sanctioned.4546 The order The order:
 blocks U.S.-based property of any entity that conducts a significant transaction  blocks U.S.-based property of any entity that conducts a significant transaction
for the “sale, supply, or transfer to Iran” of goods or services, or the transport or for the “sale, supply, or transfer to Iran” of goods or services, or the transport or
marketing, of the iron, steel, aluminum, and copper sectors of Iran; marketing, of the iron, steel, aluminum, and copper sectors of Iran;
46 Statement by President Trump Imposing Sanctions on Iron, Steel, Aluminum and Copper Sectors of Iran, May 8, 2019. Congressional Research Service 31 Iran Sanctions  authorizes the Secretary of the Treasury to bar from the U.S. financial system any  authorizes the Secretary of the Treasury to bar from the U.S. financial system any
foreign bank that conducts a financial transaction for steel, steel products, copper, foreign bank that conducts a financial transaction for steel, steel products, copper,
or copper products from Iran; or copper products from Iran;
 bars the entry into the United States of any person sanctioned under the order.  bars the entry into the United States of any person sanctioned under the order.

~~45 Statement by President Trump Imposing Sanctions on Iron, Steel, Aluminum and Copper Sectors of Iran, May 8,~~
~~2019.~~
~~Congressional Research Service~~
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Executive Order 13902 on the Construction, Mining,
Manufacturing, and Textiles Sector (January 10, 2020)
On January 10, 2020, as a stated response to the Iranian missile strikes on an Iraqi air base used On January 10, 2020, as a stated response to the Iranian missile strikes on an Iraqi air base used
by U.S. forces several days earlier (Iran’s response to the U.S. killing of IRGC-QF commander by U.S. forces several days earlier (Iran’s response to the U.S. killing of IRGC-QF commander
Qasem Soleimani), President Trump issued Executive Order 13902 expanding the Iranian Qasem Soleimani), President Trump issued Executive Order 13902 expanding the Iranian
industrial sectors subject to U.S. sanctions. The orderindustrial sectors subject to U.S. sanctions. The order:
 Blocks U.S. based property of persons determined by the Administration to  Blocks U.S. based property of persons determined by the Administration to
“operate in” or to have knowingly engaged in a significant transaction with the “operate in” or to have knowingly engaged in a significant transaction with the
construction, mining, manufacturing, or textiles sectors of Iran’s economy (such construction, mining, manufacturing, or textiles sectors of Iran’s economy (such
as the vibrant carpet industry), “or any other sector of the Iranian economy as as the vibrant carpet industry), “or any other sector of the Iranian economy as
may be determined by the Secretary of the Treasury, in consultation with the may be determined by the Secretary of the Treasury, in consultation with the
Secretary of State.” Secretary of State.”
 Blocks U.S. property of persons determined to have assisted (financed, supplied  Blocks U.S. property of persons determined to have assisted (financed, supplied
technology) persons sanctioned under the order. technology) persons sanctioned under the order.
 Bars from the U.S. financial system any foreign bank that conducts transactions  Bars from the U.S. financial system any foreign bank that conducts transactions
with these Iranian economic sectors or with persons that supplied goods or with these Iranian economic sectors or with persons that supplied goods or
services to those sectors. services to those sectors.
 Persons sanctioned under the order are banned from travel to the United States.  Persons sanctioned under the order are banned from travel to the United States.
Related State and Treasury Determination (State Department-administered Iran metals-related sanctions): E.O. 13902 followed an October 31, 2019, E.O. 13902 followed an October 31, 2019,
determination by the State and Treasury Departments that the construction sector of Iran is determination by the State and Treasury Departments that the construction sector of Iran is
controlled by the IRGCcontrolled by the IRGC ~~and that, therefore~~. According to the determination, the supply of raw or semi-finished metals, graphite, , the supply of raw or semi-finished metals, graphite,
coal, and industrial software to Iran are sanctionable under Section 1245 of IFCAcoal, and industrial software to Iran are sanctionable under Section 1245 of IFCA ~~(see above).~~
~~The two agencies also determined~~. The determination added that the sale to Iran of the following that the sale to Iran of the following metals and other materials are sanctionable as useful are sanctionable as useful
to Iran’s nuclear, missile, and military programs: stainless steel 304L tubes; MN40 manganese to Iran’s nuclear, missile, and military programs: stainless steel 304L tubes; MN40 manganese
brazing foil; and stainless steel (chromium, nickel, 60% tungsten, titanium, electro-slag brazing foil; and stainless steel (chromium, nickel, 60% tungsten, titanium, electro-slag ~~remelting,~~
re-melting, and vacuum re-melting).and vacuum re-melting).4647 Another determination of January 15, 2021, added to the list of metals for which transactions with Iran would be sanctionable, naming: various aluminiums (6061, 6063, and 7075), zirconium carbide 4340 steel, and AISI 309 and 304.
Executive Order 13608 on Sanctions Evasion
Executive Order 13608 of May 1, 2012, gives the Department of the Treasury the ability to Executive Order 13608 of May 1, 2012, gives the Department of the Treasury the ability to
identify and sanction (cutting them off from the U.S. market) foreign persons who help Iran (or identify and sanction (cutting them off from the U.S. market) foreign persons who help Iran (or
Syria) evade U.S. and multilateral sanctions. Syria) evade U.S. and multilateral sanctions.
Several persons and entities have been designated for sanctions, as shown in the tables at the end. Several persons and entities have been designated for sanctions, as shown in the tables at the end.
47 Dept. of State. Findings Pursuant to the Iran Freedom and Counter-Proliferation Act (IFCA) of 2012. October 31, 2019. Congressional Research Service 32 Iran Sanctions Sanctions on Cyber and Criminal Activities
The Trump Administration has used executive orders issued during the Obama Administration to The Trump Administration has used executive orders issued during the Obama Administration to
sanction Iranian entities determined to be engaged in malicious cyberactivities or in transnational sanction Iranian entities determined to be engaged in malicious cyberactivities or in transnational
crime. Separately, the Justice Department has prosecuted some Iranian entities for such activity. crime. Separately, the Justice Department has prosecuted some Iranian entities for such activity.
Entities sanctioned under the two orders below are listed in the tables at the end of the report. Entities sanctioned under the two orders below are listed in the tables at the end of the report.

~~46 Dept. of State. Findings Pursuant to the Iran Freedom and Counter-Proliferation Act (IFCA) of 2012. October 31,~~
~~2019.~~
~~Congressional Research Service~~
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~~Iran Sanctions~~

Executive Order 13581
Executive Order 13581 (July 25, 2011) blocks the U.S.-based property of entities determined (1) Executive Order 13581 (July 25, 2011) blocks the U.S.-based property of entities determined (1)
to be a foreign person that constitutes a significant transnational criminal organization; (2) to have to be a foreign person that constitutes a significant transnational criminal organization; (2) to have
materially assisted any person sanctioned under this order; or (3) to be owned or controlled by or materially assisted any person sanctioned under this order; or (3) to be owned or controlled by or
to have acted on behalf of a person sanctioned under the order. to have acted on behalf of a person sanctioned under the order.
Executive Order 13694
Executive Order 13694 (April 1, 2015) blocks U.S.-based property of foreign entities determined Executive Order 13694 (April 1, 2015) blocks U.S.-based property of foreign entities determined
to have engaged in cyber-enabled activities that (1) harm or compromise the provision of services to have engaged in cyber-enabled activities that (1) harm or compromise the provision of services
by computers or computer networks supporting in the critical infrastructure sector; (2) by computers or computer networks supporting in the critical infrastructure sector; (2)
compromise critical infrastructure; (3) disrupt computers or computer networks; or (4) cause compromise critical infrastructure; (3) disrupt computers or computer networks; or (4) cause
misappropriation of funds, trade secrets, personal identifiers, or financial information for financial misappropriation of funds, trade secrets, personal identifiers, or financial information for financial
advantage or gain. advantage or gain.
U.S. State-Level Sanctions
Some U.S. laws require or call for divestment of shares of firms that conduct certain transactions Some U.S. laws require or call for divestment of shares of firms that conduct certain transactions
with Iran. A divestment-promotion provision was contained in CISADA, providing a “safe with Iran. A divestment-promotion provision was contained in CISADA, providing a “safe
harbor” for investment managers who sell shares of firms that invest in Iran’s energy sector at harbor” for investment managers who sell shares of firms that invest in Iran’s energy sector at
levels that would trigger U.S. sanctions under the Iran Sanctions Act. Section 219 of the levels that would trigger U.S. sanctions under the Iran Sanctions Act. Section 219 of the
ITRSHRA of 2012 requires companies to reports to the Securities and Exchange Commission ITRSHRA of 2012 requires companies to reports to the Securities and Exchange Commission
whether they or any corporate affiliate has engaged in any transactions with Iran that could trigger whether they or any corporate affiliate has engaged in any transactions with Iran that could trigger
sanctions under ISA, CISADA, and E.O 13382 and 13224. Numerous states have adopted laws, sanctions under ISA, CISADA, and E.O 13382 and 13224. Numerous states have adopted laws,
regulations, and policies to divest from—or avoid state government business with—foreign regulations, and policies to divest from—or avoid state government business with—foreign
companies that conduct certain transactions with Iran. companies that conduct certain transactions with Iran.
Sanctions Supporting Democracy/Human Rights
U.S. policy and legislation since the June 12, 2009, election-related uprising in Iran has sought to U.S. policy and legislation since the June 12, 2009, election-related uprising in Iran has sought to
support the ability of the domestic opposition in Iran to communicate and to sanction Iranian support the ability of the domestic opposition in Iran to communicate and to sanction Iranian
officials and institutions, such as the IRGC, that commit human rights abuses or engage in officials and institutions, such as the IRGC, that commit human rights abuses or engage in
corruption. Individuals and entities designated under the executive orders and provisions corruption. Individuals and entities designated under the executive orders and provisions
discussed below are listed in the tables at the end of this report. For those provisions that ban discussed below are listed in the tables at the end of this report. For those provisions that ban
visas to enter the United States, the State Department interprets the provisions to apply to all visas to enter the United States, the State Department interprets the provisions to apply to all
members of the designated entity.members of the designated entity.47
48 48 U.S. Department of the Treasury, Office of Public Affairs, Treasury Sanctions Iranian Security Forces for Human Rights Abuses, June 9, 2011. Congressional Research Service 33 Iran Sanctions Expanding Internet and Communications Freedoms
Some laws focus on expanding Internet freedom in Iran or preventing the Iranian government Some laws focus on expanding Internet freedom in Iran or preventing the Iranian government
from using the Internet to identify opponents. from using the Internet to identify opponents.
 Subtitle D of the FY2010 Defense Authorization Act (P.L. 111-84), called the  Subtitle D of the FY2010 Defense Authorization Act (P.L. 111-84), called the
“VOICE” (Victims of Iranian Censorship) Act, contained provisions to increase “VOICE” (Victims of Iranian Censorship) Act, contained provisions to increase
U.S. broadcasting to Iran and to identify to Congress companies that are selling U.S. broadcasting to Iran and to identify to Congress companies that are selling
Iran technology equipment that it can use to control Internet usage by Iranians. Iran technology equipment that it can use to control Internet usage by Iranians.

~~47 U.S. Department of the Treasury, Office of Public Affairs,~~ ~~Treasury Sanctions Iranian Security Forces for Human~~
~~Rights Abuses, June 9, 2011.~~
~~Congressional Research Service~~
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~~Iran Sanctions~~

  CISADA Provisions. Section 106 of CISADA prohibits U.S. government . Section 106 of CISADA prohibits U.S. government
contracts with foreign companies that sell technology that Iran could use to contracts with foreign companies that sell technology that Iran could use to
monitor or control Iranian usage of the internet. The provisions were directedmonitor or control Iranian usage of the internet. The provisions were directed~~, in~~
~~part,~~ against Nokia (Finland) and Siemens (Germany) for against Nokia (Finland) and Siemens (Germany) for ~~reportedly~~ selling selling
Internet monitoring and censorship technology to Iran in 2008.Internet monitoring and censorship technology to Iran in 2008.4849 The provision The provision
was derived from the Reduce Iranian Cyber-Suppression Act (111th Congress, S. was derived from the Reduce Iranian Cyber-Suppression Act (111th Congress, S.
1475 and H.R. 3284). Section 103(b)(2) of CISADA exempts from the U.S. 1475 and H.R. 3284). Section 103(b)(2) of CISADA exempts from the U.S.
export ban on Iran the sale of equipment to help Iranians communicate via the export ban on Iran the sale of equipment to help Iranians communicate via the
Internet. Internet.
 Executive Order 13606 (April 23, 2012) sanctions persons who commit “Grave  Executive Order 13606 (April 23, 2012) sanctions persons who commit “Grave
Human Rights Abuses by the Governments of Iran and Syria via Information Human Rights Abuses by the Governments of Iran and Syria via Information
Technology (GHRAVITY).” The order blocks the U.S.-based property and Technology (GHRAVITY).” The order blocks the U.S.-based property and
essentially bars U.S. entry and bans any U.S. trade with persons and entities essentially bars U.S. entry and bans any U.S. trade with persons and entities
listed in an Annex and persons or entities subsequently determined to be (1) listed in an Annex and persons or entities subsequently determined to be (1)
operating any technology that allows the Iranian (or Syrian) government to operating any technology that allows the Iranian (or Syrian) government to
disrupt, monitor, or track computer usage by citizens of those countries or disrupt, monitor, or track computer usage by citizens of those countries or
assisting the two governments in such disruptions or monitoring; or (2) selling to assisting the two governments in such disruptions or monitoring; or (2) selling to
Iran (or Syria) technology that enables them to carry out such actions. Iran (or Syria) technology that enables them to carry out such actions.
 Section 403 of ITRSHRA sanctions (visa ban, U.S.-based property blocked)  Section 403 of ITRSHRA sanctions (visa ban, U.S.-based property blocked)
persons/firms determined to have engaged in censorship in Iran, limited access to persons/firms determined to have engaged in censorship in Iran, limited access to
media, or—for example, a foreign satellite service provider—supported Iranian media, or—for example, a foreign satellite service provider—supported Iranian
government jamming or frequency manipulation. government jamming or frequency manipulation.
 Executive Order 13628 (October 9, 2012) implemented ITRSHRA Section 403  Executive Order 13628 (October 9, 2012) implemented ITRSHRA Section 403
by blocking the property of entities determined to have committed censorship, by blocking the property of entities determined to have committed censorship,
limited free expression, or assisted in jamming communications. The order limited free expression, or assisted in jamming communications. The order
specifies the sanctions authorities of the Department of State and of Treasury. specifies the sanctions authorities of the Department of State and of Treasury.
  Regulations Changes by Treasury/OFAC. On March . On March 8, 2010, a General License 2010, a General License
was was provided for the provision to Iranians of free mass market software.provided for the provision to Iranians of free mass market software.~~49 In~~
~~March 2012, the general license~~50 The General License was expanded was expanded (2012) to include additional types of to include additional types of
software and information technology products, provided the products were software and information technology products, provided the products were
available at no cost to the useravailable at no cost to the user.5051 The items included personal communications, The items included personal communications,
personal data storage, browsers, plug-ins, document readers, and free mobile personal data storage, browsers, plug-ins, document readers, and free mobile
applications related to personal communications. applications related to personal communications. ~~On May 30, 2013, a further~~
~~expansion of the General License applied~~The General License was further amended (2013) to apply to the cash sale (no financing), to Iran to the cash sale (no financing), to Iran
~~of equipment that Iranians can use to communicate (e.g., cellphones, laptops,~~
~~satellite internet, website hosting, and related products and services).~~
~~Measures to Sanction Human Rights Abuses/Promote Civil Society~~
~~Some Iran-specific legislation and administrative action has sought to sanction regime officials~~
~~involved in suppressing the domestic opposition in Iran or in human rights abuses more generally.~~
of equipment that Iranians can use to
4849 Christopher Rhoads, “Iran’s Web Spying Aided by Western Technology,” Christopher Rhoads, “Iran’s Web Spying Aided by Western Technology,” Wall Street Journal, June 22, 2009. , June 22, 2009.
4950 The regulations change required a waiver of the provision of the Iran-Iraq Arms Nonproliferation Act (Section 1606 The regulations change required a waiver of the provision of the Iran-Iraq Arms Nonproliferation Act (Section 1606
waiver provision) discussed above. waiver provision) discussed above.
5051 Fact Sheet: Treasury Issues Interpretive Guidance and Statement of Licensing Policy on Internet Freedom in Iran, ,
March 20, 2012. March 20, 2012.
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communicate (e.g., cellphones, laptops, satellite internet, website hosting, and related products and services). Measures to Sanction Human Rights Abuses/Promote Civil Society Some Iran-specific legislation and administrative action has sought to sanction regime officials involved in suppressing the domestic opposition in Iran or in human rights abuses more generally.  Section 105 of CISADA bans travel and freezes the U.S.-based assets of those  Section 105 of CISADA bans travel and freezes the U.S.-based assets of those
Iranians determined to be human rights abusers. Section 105 terminates if the Iranians determined to be human rights abusers. Section 105 terminates if the
President certifies to Congress that Iran has (1) unconditionally released all President certifies to Congress that Iran has (1) unconditionally released all
political prisoners detained after the June 2009 uprising; (2) ceased violence, political prisoners detained after the June 2009 uprising; (2) ceased violence,
unlawful detention, torture, and abuse of citizens who engaged in peaceful unlawful detention, torture, and abuse of citizens who engaged in peaceful
protest; (3) fully investigated abuses of political activists after the 2009 uprising; protest; (3) fully investigated abuses of political activists after the 2009 uprising;
and (4) committed to and is making progress toward establishing an independent and (4) committed to and is making progress toward establishing an independent
judiciary and respecting human rights. judiciary and respecting human rights.
 Executive Order 13553 (September 29, 2010) implements Section 105 of  Executive Order 13553 (September 29, 2010) implements Section 105 of
CISADA by sanctioning Iranians determined to be responsible for or complicit in CISADA by sanctioning Iranians determined to be responsible for or complicit in
post-2009 Iran election human rights abuses. post-2009 Iran election human rights abuses.
  The CAATSA law (see above)(see above) expanded Section 105 of CISADA by authorizing expanded Section 105 of CISADA by authorizing
(but not mandating) sanctions on Iranian human rights abuses generally—not (but not mandating) sanctions on Iranian human rights abuses generally—not
limited to those connected to the June 2009 uprising. The CAATSA law defines limited to those connected to the June 2009 uprising. The CAATSA law defines
as sanctionable extrajudicial killings, torture, or other gross violations of as sanctionable extrajudicial killings, torture, or other gross violations of
internationally recognized human rights against Iranians who seek to expose internationally recognized human rights against Iranians who seek to expose
illegal activity by officials or to defend or promote human rights and freedoms in illegal activity by officials or to defend or promote human rights and freedoms in
Iran. The persons to be sanctioned are those named in a report provided 90 days Iran. The persons to be sanctioned are those named in a report provided 90 days
after CAATSA enactment (by October 31, 2017) and annually thereafter. after CAATSA enactment (by October 31, 2017) and annually thereafter.
Additional Iranian human rights abusers were designated under E.O. 13533 by an Additional Iranian human rights abusers were designated under E.O. 13533 by an
October 31, 2017, CAATSA deadline. October 31, 2017, CAATSA deadline.
  Sanctions against Iranian Profiteers. Section 1249 of IFCA amended Section 105 . Section 1249 of IFCA amended Section 105
of CISADA by imposing sanctions on any person determined to have engaged in of CISADA by imposing sanctions on any person determined to have engaged in
corruption or to have diverted or misappropriated humanitarian goods or funds corruption or to have diverted or misappropriated humanitarian goods or funds
for such goods for the Iranian people. The measure targets Iranian profiteers who for such goods for the Iranian people. The measure targets Iranian profiteers who
use official connections to corner the market for vital medicines. This provision use official connections to corner the market for vital medicines. This provision
codified a similar provision of Executive Order 13645. codified a similar provision of Executive Order 13645.
  Sanctions against Iranian Government Broadcasters/IRIB. Section 1248 of IFCA Section 1248 of IFCA
(Subtitle D of P.L. 112-239) mandates inclusion of the Islamic Republic of Iran (Subtitle D of P.L. 112-239) mandates inclusion of the Islamic Republic of Iran
Broadcasting (IRIB), the state broadcasting umbrella group, as a human rights Broadcasting (IRIB), the state broadcasting umbrella group, as a human rights
abuser. IRIB was designated as an SDN on February 6, 2013, under E.O. 13628 abuser. IRIB was designated as an SDN on February 6, 2013, under E.O. 13628
for limiting free expression in Iran. On February 14, 2014, the State Department for limiting free expression in Iran. On February 14, 2014, the State Department
waived IFCA sanctions under Sections 1244, 1246, or 1247, on any entity that waived IFCA sanctions under Sections 1244, 1246, or 1247, on any entity that
provides satellite services to IRIB. The waiver has been renewed each year since. provides satellite services to IRIB. The waiver has been renewed each year since.
  Executive Order 13846 (August 6, 2018). The Executive Order that reimposed The Executive Order that reimposed
pre-JCPOA sanctions Iranian human rights abusers and corrupt officials. No pre-JCPOA sanctions Iranian human rights abusers and corrupt officials. No
sanctions imposed for such behaviors were suspended to implement the JCPOA. sanctions imposed for such behaviors were suspended to implement the JCPOA.
Section 7 of the Section 7 of the ~~Order~~order blocks the U.S.-based property of persons that (1) engaged blocks the U.S.-based property of persons that (1) engaged
after January 2, 2013 in corrupt diversion of goods intended for the Iranian after January 2, 2013 in corrupt diversion of goods intended for the Iranian
people; (2) sold (after August 10, 2012) Iran goods or technologies or provided people; (2) sold (after August 10, 2012) Iran goods or technologies or provided
services used by the Iranian government to commit serious human rights abuses; services used by the Iranian government to commit serious human rights abuses;
Congressional Research Service 35 Iran Sanctions (3) engaged in censorship or limited free expression in Iran (after June 12, 2009); (3) engaged in censorship or limited free expression in Iran (after June 12, 2009);
or (4) provided goods or services to any person sanctioned under the or (4) provided goods or services to any person sanctioned under the ~~Order~~order. .
  Sanctions on Sales of Anti-Riot Equipment. Section 402 of the ITRSHRA Section 402 of the ITRSHRA
amended Section 105 of CISADA by imposing visa bans on and blocking the amended Section 105 of CISADA by imposing visa bans on and blocking the
U.S. property of any person or company that sells the Iranian government goods U.S. property of any person or company that sells the Iranian government goods
or technologies that it can use to commit human rights abuses. Such goods or technologies that it can use to commit human rights abuses. Such goods
include firearms, rubber bullets, police batons, chemical or pepper sprays, stun include firearms, rubber bullets, police batons, chemical or pepper sprays, stun
~~Congressional Research Service~~
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~~Iran Sanctions~~

grenades, tear gas, water cannons, and like goods. In addition, ISA sanctions are grenades, tear gas, water cannons, and like goods. In addition, ISA sanctions are
to be imposed on any person determined have sold such equipment to the IRGC. to be imposed on any person determined have sold such equipment to the IRGC.
  Separate Visa Bans. Since 2011, the State Department imposed visa restrictions Since 2011, the State Department imposed visa restrictions
on over 100 Iranian officials for participating in political repression in Iran, but it on over 100 Iranian officials for participating in political repression in Iran, but it
has not named them, on the grounds that visa records are confidential. The action has not named them, on the grounds that visa records are confidential. The action
was taken under the authorities of Section 212(a)(3)(C) of the Immigration and was taken under the authorities of Section 212(a)(3)(C) of the Immigration and
Nationality Act, which renders inadmissible to the United States a foreign person Nationality Act, which renders inadmissible to the United States a foreign person
whose activities could have serious consequences for the United States. On whose activities could have serious consequences for the United States. On
September 25, 2019, President Trump issued a proclamation denying entry into September 25, 2019, President Trump issued a proclamation denying entry into
the United States of senior Iranian officials and immediate family members.the United States of senior Iranian officials and immediate family members.5152
  High Level Iranian Visits to the United Nations. There are certain exemptions in . There are certain exemptions in
the case of high level Iranian visits to attend U.N. meetings in New York. Under the case of high level Iranian visits to attend U.N. meetings in New York. Under
the U.N. Participation Act (P.L. 79-264), because the United States hosts the the U.N. Participation Act (P.L. 79-264), because the United States hosts the
United Nations headquarters in New York, visas are issued to heads of state and United Nations headquarters in New York, visas are issued to heads of state and
their aides attending these meetings. The State Department has refused visas for their aides attending these meetings. The State Department has refused visas for
~~some~~ Iranian officials Iranian officials ~~on the grounds that they~~who were involved in were involved in ~~past~~ acts of acts of
terrorism or human rights abuses. terrorism or human rights abuses.
Non-Iran Specific Human Rights Laws
The Trump Administration has utilized global human rights laws to sanction Iranian violators. The Trump Administration has utilized global human rights laws to sanction Iranian violators.
  Global Magnitsky Act. The Global Magnitsky Human Rights Accountability Act, The Global Magnitsky Human Rights Accountability Act,
enacted as part of the National Defense Authorization Act for Fiscal Year 2017 enacted as part of the National Defense Authorization Act for Fiscal Year 2017
(NDAA 2017; P.L. 114-328; December 23, 2016), authorizes the President to (NDAA 2017; P.L. 114-328; December 23, 2016), authorizes the President to
impose economic sanctions and deny entry into the United States to any foreign impose economic sanctions and deny entry into the United States to any foreign
person he identifies as engaging in human rights abuse or corruption. Executive person he identifies as engaging in human rights abuse or corruption. Executive
Order 13818, providing for sanctions on persons determined to have engaged in Order 13818, providing for sanctions on persons determined to have engaged in
the activity outlined in the act, was issued on December 20, 2017. the activity outlined in the act, was issued on December 20, 2017.
  Section 7031(c) of the State Department and Foreign Operations Appropriation.
For the last few years, successive foreign aid appropriations laws have contained For the last few years, successive foreign aid appropriations laws have contained
a section (7031c) that makes persons determined to have committed gross a section (7031c) that makes persons determined to have committed gross
violations of human rights ineligible for entry to the United States. For FY2020, violations of human rights ineligible for entry to the United States. For FY2020,
this provision is inthis provision is in: P.L. 116-94, division G (H.R.1865) P.L. 116-94, division G (H.R.1865)
Sanctions on Iran’s Leadership
The Trump Administration The Trump Administration ~~has~~ imposed sanctions on some members of Iran’s civilian leadership. imposed sanctions on some members of Iran’s civilian leadership.
Any Iranian official that is named an SDN is subject to a freezing of their U.S.-based property Any Iranian official that is named an SDN is subject to a freezing of their U.S.-based property
and there are secondary sanctions (noted throughout) on third parties that deal with those entities. and there are secondary sanctions (noted throughout) on third parties that deal with those entities.
~~Section 103(b)(3) of CISADA also provides for the freezing of assets of any “family member or~~
~~associate acting for on behalf of the person” that is named as an SDN.~~

5152 Proclamation on the Suspension of Entry as Immigrants and Nonimmigrants of Senior Officials of the Government Proclamation on the Suspension of Entry as Immigrants and Nonimmigrants of Senior Officials of the Government
of Iran. September 25, 2019. of Iran. September 25, 2019.
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~~Executive Order 13876~~
~~On June 24, 2019, in the context of heightened U.S.-Iran tensions~~Section 103(b)(3) of CISADA also provides for the freezing of assets of any “family member or associate acting for on behalf of the person” that is named as an SDN. Executive Order 13876 On June 24, 2019, President Trump issued , President Trump issued
Executive Order 13876, imposing sanctions on the assets of Supreme Leader Ali Khamene’i and Executive Order 13876, imposing sanctions on the assets of Supreme Leader Ali Khamene’i and
his top associates. The his top associates. The ~~Order~~
order  Blocks the U.S.-based property or assets of the Supreme Leader and his office,  Blocks the U.S.-based property or assets of the Supreme Leader and his office,
any Iranian appointed by him to an official position, or any person that materially any Iranian appointed by him to an official position, or any person that materially
assists the Supreme Leader or his office. assists the Supreme Leader or his office.
 Bars from the U.S. financial system any bank determined to have conducted or  Bars from the U.S. financial system any bank determined to have conducted or
facilitated a financial transaction with a Supreme Leader-related or Supreme facilitated a financial transaction with a Supreme Leader-related or Supreme
Leader-appointed official. Leader-appointed official.
Implementation: Supreme Leader Khamene’i and his office are sanctioned by the order itself. Supreme Leader Khamene’i and his office are sanctioned by the order itself.
Subsequently, Iran’s Foreign Minister Mohammad Javad Zarif and other senior Iranian officials Subsequently, Iran’s Foreign Minister Mohammad Javad Zarif and other senior Iranian officials
and commanders were designated under the order, as shown in the tables at the end of the report. and commanders were designated under the order, as shown in the tables at the end of the report.
U.N. Sanctions
~~U.N. sanctions on Iran, enacted by the Security Council under Article 41 of Chapter VII of the~~
~~U.N. Charter,52 applied to all U.N. member states.~~ During 2006-2008, three U.N. Security During 2006-2008, three U.N. Security
Council resolutions—1737, 1747, and 1803—imposed sanctions on Iran’s nuclear program and Council resolutions—1737, 1747, and 1803—imposed sanctions on Iran’s nuclear program and
weapons of mass destruction (WMD) infrastructure. Resolution 1929 (June 9, 2010) asserted that weapons of mass destruction (WMD) infrastructure. Resolution 1929 (June 9, 2010) asserted that
major sectors of the Iranian economy support Iran’s nuclear program and authorized U.N. major sectors of the Iranian economy support Iran’s nuclear program and authorized U.N.
member states to sanction civilian sectors of Iran’s economy. It also imposed binding limitations member states to sanction civilian sectors of Iran’s economy. It also imposed binding limitations
on Iran’s development of nuclear-capable ballistic missiles and imports and exports of arms.on Iran’s development of nuclear-capable ballistic missiles and imports and exports of arms.
The U.N. sanctions on Iran were enacted by the Security Council under Article 41 of Chapter VII of the U.N. Charter53 and applied to all U.N. member states. Resolution 2231 and U.N. Sanctions Eased
U.N. Security Council Resolution 2231 (July 20, 2015) contained the provisions below. The U.N. Security Council Resolution 2231 (July 20, 2015) contained the provisions below. The
resolution resolution
 Endorsed the JCPOA, superseded all prior Iran-related resolutions as of  Endorsed the JCPOA, superseded all prior Iran-related resolutions as of
Implementation Day (January 16, 2016), and lifted U.N. sanctions on Iran. Under Implementation Day (January 16, 2016), and lifted U.N. sanctions on Iran. Under
Paragraph 6(c) of Annex B of Resolution 2231, Iranian civilian nuclear entities Paragraph 6(c) of Annex B of Resolution 2231, Iranian civilian nuclear entities
sanctioned under Resolutions 1737 and subsequent resolutions (and named in an sanctioned under Resolutions 1737 and subsequent resolutions (and named in an
attachment to the Annex) were “delisted” on Implementation Day. Those not attachment to the Annex) were “delisted” on Implementation Day. Those not
listed on the attachment continue to be sanctioned until Transition Day (October listed on the attachment continue to be sanctioned until Transition Day (October
18, 2023). Bank Sepah and Bank Sepah International PLC, were delisted on 18, 2023). Bank Sepah and Bank Sepah International PLC, were delisted on
Implementation Day by separate Security Council action. Paragraph 6(c) Implementation Day by separate Security Council action. Paragraph 6(c)
provides for the Security Council to be able to delist or list any entity at any time. provides for the Security Council to be able to delist or list any entity at any time.
 “Called on” Iran not to develop ballistic missiles “designed to be capable” of  “Called on” Iran not to develop ballistic missiles “designed to be capable” of
delivering a nuclear weapon for a maximum of eight years from Adoption Day delivering a nuclear weapon for a maximum of eight years from Adoption Day
(October 18, 2015). The restriction expires on October 18, 2023. (October 18, 2015). The restriction expires on October 18, 2023.
~~ Requires Security Council approval for Iran to export arms or to purchase any~~
~~arms (major combat systems named in the resolution) for a maximum of five~~
~~years from Adoption Day (October 18, 2020). The Security Council deems the~~

5253 Security Council resolutions that reference Chapter VII of the U.N. Charter represent actions taken with respect to Security Council resolutions that reference Chapter VII of the U.N. Charter represent actions taken with respect to
threats to international peace and acts of aggression. Article 41 of that Chapter, in general, provides for enforcement of threats to international peace and acts of aggression. Article 41 of that Chapter, in general, provides for enforcement of
the resolution in question through economic and diplomatic sanctions, but not through military action. the resolution in question through economic and diplomatic sanctions, but not through military action.
Congressional Research Service Congressional Research Service
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Iran Sanctions

 Requires Security Council approval for Iran to export arms or to purchase any arms (major combat systems named in the resolution) for a maximum of five years from Adoption Day (October 18, 2020). The Security Council deems the ban to have expired on October 18, 2020,~~ban to have expired on October 18, 2020~~ as planned, a position that the Trump as planned, a position that the Trump
Administration Administration ~~disputes~~disputed but which the Biden Administration upheld in a letter to the U.N. Secretary-General of February 18, 2021. See CRS In Focus IF11429, . See CRS In Focus IF11429, U.N. Ban on Iran Arms
Transfers and Sanctions Snapback, by Kenneth Katzman. , by Kenneth Katzman.
Table 3. Summary of Provisions of U.N. Resolutions on Iran Nuclear Program
(1737, 1747, 1803, 1929, and 2231)
Resolution 2231 superseded all the previous Iran resolutions Resolution 2231 superseded all the previous Iran resolutions
Resolution 1737 required Iran to suspend uranium enrichment, to suspend construction of the heavy-water Resolution 1737 required Iran to suspend uranium enrichment, to suspend construction of the heavy-water
reactor at Arak, ratify the “Additional Protocol” to Iran’s IAEA Safeguards Agreement. (1737) reactor at Arak, ratify the “Additional Protocol” to Iran’s IAEA Safeguards Agreement. (1737)
Assets frozen of Iranian persons and entities named in annexes to the resolutions, and countries required to ban Assets frozen of Iranian persons and entities named in annexes to the resolutions, and countries required to ban
the travel of named Iranians. (Initial list in Resolution 1737, and additional designations in subsequent resolutions). the travel of named Iranians. (Initial list in Resolution 1737, and additional designations in subsequent resolutions).
Transfer to Iran of nuclear, missile, and dual use items to Iran prohibited, except for use in light-water reactors Transfer to Iran of nuclear, missile, and dual use items to Iran prohibited, except for use in light-water reactors
(1737 and 1747). Resolution 2231 delegates to a Joint Commission the authority to approve Iran’s applications to (1737 and 1747). Resolution 2231 delegates to a Joint Commission the authority to approve Iran’s applications to
purchase dual-use items. purchase dual-use items.
Resolution 1747 prohibited Iran from exporting arms. Resolution 2231 requires Iran to obtain Security Council Resolution 1747 prohibited Iran from exporting arms. Resolution 2231 requires Iran to obtain Security Council
approval to export arms for a maximum of five years. approval to export arms for a maximum of five years.
Resolution 1929 prohibited Iran from investing abroad in uranium mining, related nuclear technologies or nuclear Resolution 1929 prohibited Iran from investing abroad in uranium mining, related nuclear technologies or nuclear
capable ballistic missile technology, and prohibits Iran from developing/testing, nuclear-capable ballistic missiles. capable ballistic missile technology, and prohibits Iran from developing/testing, nuclear-capable ballistic missiles.
1929 mandated that countries not export major combat systems to Iran, but did not bar sales of missiles that are 1929 mandated that countries not export major combat systems to Iran, but did not bar sales of missiles that are
not on the U.N. Registry of Conventional Arms. Resolution 2231 makes arms sales to Iran and exportation of not on the U.N. Registry of Conventional Arms. Resolution 2231 makes arms sales to Iran and exportation of
arms from Iran subject to approval by the U.N. Security Council, for a maximum of five years from Adoption Day arms from Iran subject to approval by the U.N. Security Council, for a maximum of five years from Adoption Day
(until October 2020). (until October 2020).
1929 called for restraint on transactions with Iranian banks, particularly Bank Melli and Bank Saderat. 1929 called for restraint on transactions with Iranian banks, particularly Bank Melli and Bank Saderat.
Resolution called for “Vigilance” (but not a ban) on making international lending to Iran and providing trade credits Resolution called for “Vigilance” (but not a ban) on making international lending to Iran and providing trade credits
and other financing. and other financing.
Resolution 1929 called on countries to inspect cargoes carried by Iran Air Cargo and Islamic Republic of Iran Resolution 1929 called on countries to inspect cargoes carried by Iran Air Cargo and Islamic Republic of Iran
Shipping Lines—or by any ships in national or international waters—if there are indications they carry cargo Shipping Lines—or by any ships in national or international waters—if there are indications they carry cargo
banned for carriage to Iran. Searches in international waters would require concurrence of the country where the banned for carriage to Iran. Searches in international waters would require concurrence of the country where the
ship is registered. Resolution 2231 requires continued enforcement of remaining restrictions. ship is registered. Resolution 2231 requires continued enforcement of remaining restrictions.
Prior to JCPOA implementation, a Sanctions Committee, composed of the 15 members of the Security Council, Prior to JCPOA implementation, a Sanctions Committee, composed of the 15 members of the Security Council,
monitored implementation of all Iran sanctions and monitored implementation of all Iran sanctions and ~~col ected~~collected and disseminated information on Iranian violations and disseminated information on Iranian violations
and other entities involved in banned activities. A “panel of experts” was empowered by Resolution 1929 to assist and other entities involved in banned activities. A “panel of experts” was empowered by Resolution 1929 to assist
the sanctions committee in implementing all Iran resolutions and to suggest ways to be more effective. the sanctions committee in implementing all Iran resolutions and to suggest ways to be more effective.
Source: Text of U.N. Security Council resolutions 1737, 1747, 1803, 1929, and 2231. http://www.un.org. Text of U.N. Security Council resolutions 1737, 1747, 1803, 1929, and 2231. http://www.un.org.

Iran Compliance Status
Until August 2019, U.N. and International Atomic Energy Agency reports stated that Iran was Until August 2019, U.N. and International Atomic Energy Agency reports stated that Iran was
complying with its nuclear obligations under the JCPOA. Since mid-2019, Iran has decreased its complying with its nuclear obligations under the JCPOA. Since mid-2019, Iran has decreased its
compliance with the nuclear restrictions of the JCPOA on the grounds that the United States has compliance with the nuclear restrictions of the JCPOA on the grounds that the United States has
reimposed secondary sanctions on Iran. Seereimposed secondary sanctions on Iran. See: CRS Report R43333, CRS Report R43333, Iran Nuclear Agreement and
U.S. Exit, by Paul K. Kerr and Kenneth Katzman. , by Paul K. Kerr and Kenneth Katzman.
Congressional Research Service 38 Iran Sanctions U.N. reports on Iranian compliance with Resolution U.N. reports on Iranian compliance with Resolution ~~223153~~223154 have noted assertions by several U.N. have noted assertions by several U.N.
Security Council members, including the United States, that Iranian missile tests have been Security Council members, including the United States, that Iranian missile tests have been
inconsistent with the resolution. U.S. officials have called some of Iran’s space and medium-inconsistent with the resolution. U.S. officials have called some of Iran’s space and medium-

~~53 The report is reprinted in, Iran Watch, at http://www.iranwatch.org/library/multilateral-organizations/united-nations/~~
~~un-secretary-general/third-report-secretary-general-implementation-security-council-resolution-2231.~~
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38

~~Iran Sanctions~~

range missile launches as violations of the resolution. Iran range missile launches as violations of the resolution. Iran ~~has not been able to~~ did not buy major combat buy major combat
systems during the period that the arms transfer ban systems during the period that the arms transfer ban ~~has been~~was in effect, but it repeatedly violated in effect, but it repeatedly violated
the U.N. ban on exportation of arms, as analyzed in CRS In Focus IF11429, the U.N. ban on exportation of arms, as analyzed in CRS In Focus IF11429, U.N. Ban on Iran
Arms Transfers and Sanctions Snapback, by Kenneth Katzman , by Kenneth Katzman
Sanctions Application under Nuclear Agreements
The following sections discuss sanctions relief provided under the November 2013 interim The following sections discuss sanctions relief provided under the November 2013 interim
nuclear agreement (Joint Plan of Action, JPoA) and the JCPOA. nuclear agreement (Joint Plan of Action, JPoA) and the JCPOA.
Sanctions Eased by the JPoA
~~U.S. officials said that the JPoA provided~~The JPoA (in effect January 20, 2014-January 16, 2016) provided Iran with “limited, temporary, targeted, and reversible” easing of “limited, temporary, targeted, and reversible” easing of
international sanctionsinternational sanctions~~. Under the JPoA (in effect January 20, 2014-January 16, 2016):54~~:55
 Iran’s oil customers were not required to further reduce their oil purchases from  Iran’s oil customers were not required to further reduce their oil purchases from
Iran, with waivers of Section 1244c(1) of IFCA, ITRSHRA, and ISA. Iran, with waivers of Section 1244c(1) of IFCA, ITRSHRA, and ISA.
 A waiver of Section 1245(d)(1) of IFCA allowed Iran to receive directly $700  A waiver of Section 1245(d)(1) of IFCA allowed Iran to receive directly $700
million per month in hard currency from oil sales and $65 million per month to million per month in hard currency from oil sales and $65 million per month to
make tuition payments for Iranian students abroad (paid directly to the schools). make tuition payments for Iranian students abroad (paid directly to the schools).
 Executive Orders 13622 and 13645 and several provisions of U.S.-Iran trade  Executive Orders 13622 and 13645 and several provisions of U.S.-Iran trade
regulations were suspended, and several sections of IFCA were waived, to enable regulations were suspended, and several sections of IFCA were waived, to enable
Iran to sell petrochemicals and trade in gold and other precious metals, and to Iran to sell petrochemicals and trade in gold and other precious metals, and to
conduct transactions with foreign firms related to automotive manufacturing. conduct transactions with foreign firms related to automotive manufacturing.
 Executive Order 13382 and certain U.S.-Iran trade regulations were suspended to  Executive Order 13382 and certain U.S.-Iran trade regulations were suspended to
allow for U.S. aircraft and spare parts sales to Iran Air. allow for U.S. aircraft and spare parts sales to Iran Air.
Sanctions Easing under the JCPOA and U.S. ~~Re-imposition~~Reimposition
In accordance with the JCPOA, international sanctions relief occurred at Implementation Day In accordance with the JCPOA, international sanctions relief occurred at Implementation Day
(January 16, 2016). U.S. secondary sanctions were waived or terminated, but most sanctions on (January 16, 2016). U.S. secondary sanctions were waived or terminated, but most sanctions on
direct U.S.-Iran trade remained. The secondary sanctions eased during JCPOA implementation direct U.S.-Iran trade remained. The secondary sanctions eased during JCPOA implementation
included (1) sanctions that limited Iran’s exportation of oil and sanction foreign sales to Iran of included (1) sanctions that limited Iran’s exportation of oil and sanction foreign sales to Iran of
gasoline and energy sector equipment, and which limit foreign investment in Iran’s energy sector; gasoline and energy sector equipment, and which limit foreign investment in Iran’s energy sector;
(2) financial sector sanctions; and (3) sanctions on Iran’s auto sector and trading in the (2) financial sector sanctions; and (3) sanctions on Iran’s auto sector and trading in the rial. The The
EU lifted its ban on purchases of oil and gas from Iran; and Iranian banks were readmitted to the EU lifted its ban on purchases of oil and gas from Iran; and Iranian banks were readmitted to the
SWIFT electronic payments system. All U.N. sanctions were lifted. The U.S. sanctions that were SWIFT electronic payments system. All U.N. sanctions were lifted. The U.S. sanctions that were
eased went back into effect by November 5, 2018, in accordance with the Trump Administration’s eased went back into effect by November 5, 2018, in accordance with the Trump Administration’s
withdrawing the United States from the JCPOA. withdrawing the United States from the JCPOA.
The laws below were waived during the period of U.S. implementation of the JCPOA: The laws below were waived during the period of U.S. implementation of the JCPOA:
 Iran Sanctions Act. The WMD-related provision of ISA was not waived.  Iran Sanctions Act. The WMD-related provision of ISA was not waived.
54 The report is reprinted in, Iran Watch, at http://www.iranwatch.org/library/multilateral-organizations/united-nations/un-secretary-general/third-report-secretary-general-implementation-security-council-resolution-2231. 55 The Administration sanctions suspensions and waivers are detailed at http://www.state.gov/p/nea/rls/220049.htm. Congressional Research Service 39 Iran Sanctions  FY2012 NDAA. Section 1245(d) sanctioning banks of countries that do not  FY2012 NDAA. Section 1245(d) sanctioning banks of countries that do not
reduce Iran oil imports was waived. reduce Iran oil imports was waived.
 ITRSHRA. Iranian economy provisions waived. Human rights-related provisions  ITRSHRA. Iranian economy provisions waived. Human rights-related provisions
were not waived. were not waived.

~~54 The Administration sanctions suspensions and waivers are detailed at http://www.state.gov/p/nea/rls/220049.htm.~~
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 IFCA. Sections 1244, 1245, 1246, and 1247 of the  IFCA. Sections 1244, 1245, 1246, and 1247 of the ~~Act~~act sanctioning transactions sanctioning transactions
with SDNs and with named economic sectors were waived. with SDNs and with named economic sectors were waived.
 Executive Orders  Executive Orders: 13574, 13590, 13622, 13645, and Sections 5-7 and 15 of 13574, 13590, 13622, 13645, and Sections 5-7 and 15 of
Executive Order 13628 were revoked outright by Executive Order 13716. Executive Order 13628 were revoked outright by Executive Order 13716.
 The core provision of CISADA that sanctions foreign banks was not waived, but  The core provision of CISADA that sanctions foreign banks was not waived, but
most listed Iranian banks were “delisted.” most listed Iranian banks were “delisted.”
 Other Iranian economic entities and personalities listed in Attachment III of the  Other Iranian economic entities and personalities listed in Attachment III of the
JCPOA were delisted, enabling foreign companies/banks to resume transactions JCPOA were delisted, enabling foreign companies/banks to resume transactions
with those entities without risking being penalized by the United States. The with those entities without risking being penalized by the United States. The
tables at the end of the report depict in italics those entities delisted. tables at the end of the report depict in italics those entities delisted.
 The JCPOA required the U.S. Administration, by “Transition Day,” (October  The JCPOA required the U.S. Administration, by “Transition Day,” (October
2023, eight years after Adoption Day) to request that Congress lift virtually all of 2023, eight years after Adoption Day) to request that Congress lift virtually all of
the sanctions that were suspended under the JCPOA. No outcome is mandated. the sanctions that were suspended under the JCPOA. No outcome is mandated.
 The JCPOA terminates U.N. sanctions on persons and entities still designated for  The JCPOA terminates U.N. sanctions on persons and entities still designated for
U.N. sanctions on Transition Day. All U.N. sanctions are to terminate by U.N. sanctions on Transition Day. All U.N. sanctions are to terminate by
“Termination Day” (October 2025, ten years after Adoption Day). “Termination Day” (October 2025, ten years after Adoption Day).
In implementing its decision to exit the JCPOA and apply “maximum pressure” on Iran’s In implementing its decision to exit the JCPOA and apply “maximum pressure” on Iran’s
economy, all U.S. sanctions that were eased were reimposed within two “wind down” periods – a economy, all U.S. sanctions that were eased were reimposed within two “wind down” periods – a
90 day wind down ending on August 6, 2018 and a 180 day wind down ending on November 4, 90 day wind down ending on August 6, 2018 and a 180 day wind down ending on November 4,
2018. Even though it reimposed all U.S. sanctions on Iran, the Trump Administration: 2018. Even though it reimposed all U.S. sanctions on Iran, the Trump Administration:
 initially gave eight countries were given the SRE to enable them to continue  initially gave eight countries were given the SRE to enable them to continue
transactions with Iran’s Central Bank and to purchase Iranian oil. However, on transactions with Iran’s Central Bank and to purchase Iranian oil. However, on
May 2, 2019, the SREs were terminated. May 2, 2019, the SREs were terminated.
 kept in place seven waivers under IFCA that enable foreign entities to remove  kept in place seven waivers under IFCA that enable foreign entities to remove
Iran’s LEU that exceeds the 300kg allowed stockpile, to buy Iran’s heavy water, Iran’s LEU that exceeds the 300kg allowed stockpile, to buy Iran’s heavy water,
and expand the Bushehr civilian nuclear power reactor. However, the and expand the Bushehr civilian nuclear power reactor. However, the
Administration ended these waivers during 2019-2020. Administration ended these waivers during 2019-2020.
  ~~has~~ continued to waive Section 1247(e) of IFCA to enable Iraq to continue continued to waive Section 1247(e) of IFCA to enable Iraq to continue
paying for paying for purchases of natural gas from Iran. The waiver term can be as long as purchases of natural gas from Iran. The waiver term can be as long as
180 days, but the Administration has been providing waivers for shorter periods. 180 days, but the Administration has been providing waivers for shorter periods.
  ~~has~~ issued the permitted IFCA exception for Afghan reconstruction to enable issued the permitted IFCA exception for Afghan reconstruction to enable
India to India to continue work at Iran’s Chahbahar Port. continue work at Iran’s Chahbahar Port.
  ~~has~~ renewed the licenses of certain firms to enable them to continue developing renewed the licenses of certain firms to enable them to continue developing
the the Rhum gas field in the North Sea that Iran partly owns. Rhum gas field in the North Sea that Iran partly owns.
U.S. Sanctions that Remained in Place under the JCPOA
The JCPOA did not commit the United States to suspend U.S. sanctions related to terrorism, The JCPOA did not commit the United States to suspend U.S. sanctions related to terrorism,
proliferation, arms transfer, or human rights abuses, or suspend the ban on U.S.-Iran direct trade proliferation, arms transfer, or human rights abuses, or suspend the ban on U.S.-Iran direct trade
(with the selected exceptions discussed above). The sanctions below remained in place(with the selected exceptions discussed above). The sanctions below remained in place ~~during~~
~~JCPOA implementation~~: :
 E.O. 12959, the ban on U.S. trade with and investment in Iran;  E.O. 12959, the ban on U.S. trade with and investment in Iran;
Congressional Research Service 40 Iran Sanctions  E.O. 13224 sanctioning terrorism entities, any sanctions related to Iran’s  E.O. 13224 sanctioning terrorism entities, any sanctions related to Iran’s
designation as a state sponsor or terrorism, and any other terrorism-related designation as a state sponsor or terrorism, and any other terrorism-related
sanctions. The JCPOA did not commit the United States to revoke Iran’s sanctions. The JCPOA did not commit the United States to revoke Iran’s
placement on the terrorism list; placement on the terrorism list;
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 E.O. 13382 on proliferation;  E.O. 13382 on proliferation;
 Proliferation-related sanctions laws: the Iran-Iraq Arms Non-Proliferation Act;  Proliferation-related sanctions laws: the Iran-Iraq Arms Non-Proliferation Act;
the Iran-North Korea-Syria Non-Proliferation Act (INKSNA); the Iran-North Korea-Syria Non-Proliferation Act (INKSNA);5556 and the section and the section
of ISA that sanctions WMD- and arms-related transactions with Iran; of ISA that sanctions WMD- and arms-related transactions with Iran;
 E.O. 13438 on Iran’s interference in Iraq and E.O. 13572 on repression in Syria;  E.O. 13438 on Iran’s interference in Iraq and E.O. 13572 on repression in Syria;
 Executive Orders (E.O. 13606 and E.O. 13628) and the provisions of CISADA,  Executive Orders (E.O. 13606 and E.O. 13628) and the provisions of CISADA,
ITRSHRA, and IFCA that pertain to human rights or democratic change in Iran; ITRSHRA, and IFCA that pertain to human rights or democratic change in Iran;
 all sanctions on the IRGC, military, proliferation-related, and human rights- and  all sanctions on the IRGC, military, proliferation-related, and human rights- and
terrorism-related entities, which were not “delisted” from sanctions; and terrorism-related entities, which were not “delisted” from sanctions; and
 regulations barring Iran from access to the U.S. financial system.  regulations barring Iran from access to the U.S. financial system.
Other Mechanisms to “Snap-Back” Sanctions on Iran
Sanctions might have been reimposed by congressional action in accordance with President Sanctions might have been reimposed by congressional action in accordance with President
Trump’s withholding of certification of Iranian compliance with the JCPOA, under the Iran Trump’s withholding of certification of Iranian compliance with the JCPOA, under the Iran
Nuclear Agreement Review Act (INARA, P.L. 114-17). Certification was withheld in October Nuclear Agreement Review Act (INARA, P.L. 114-17). Certification was withheld in October
2017 and January and April of 2018, but Congress did not reimpose sanctions.2017 and January and April of 2018, but Congress did not reimpose sanctions.5657
The JCPOA (paragraph 36 and 37) and Resolution 2231 (paragraphs 10-13) contain a mechanism The JCPOA (paragraph 36 and 37) and Resolution 2231 (paragraphs 10-13) contain a mechanism
for the “snap back” of U.N. sanctions if Iran does not satisfactorily resolve a compliance dispute. for the “snap back” of U.N. sanctions if Iran does not satisfactorily resolve a compliance dispute.
According to the JCPOA (and Resolution 2231), the United States (or any veto-wielding member According to the JCPOA (and Resolution 2231), the United States (or any veto-wielding member
of the U.N. Security Council) would have been able to block a U.N. Security Council resolution of the U.N. Security Council) would have been able to block a U.N. Security Council resolution
that would continue the lifting of U.N. sanctions despite Iran’s refusal to resolve the dispute. In that would continue the lifting of U.N. sanctions despite Iran’s refusal to resolve the dispute. In
that case “that case “ ...the provisions of the old U.N. Security Council resolutions would be reimposed, ...the provisions of the old U.N. Security Council resolutions would be reimposed,
unless the U.N. Security Council decides otherwise.” unless the U.N. Security Council decides otherwise.”
The Trump Administration asserted that Resolution 2231 allows the United States to trigger the The Trump Administration asserted that Resolution 2231 allows the United States to trigger the
snap-back because it remains legally a “participant” in Resolution. The Administration formally snap-back because it remains legally a “participant” in Resolution. The Administration formally
triggered the snapback provision and asserted that, on September 19, 2020, U.N. sanctions had triggered the snapback provision and asserted that, on September 19, 2020, U.N. sanctions had
been been ~~re-imposed~~reimposed. However, the Security Council members overwhelmingly rejected the U.S. . However, the Security Council members overwhelmingly rejected the U.S.
argument and the U.N. argument and the U.N. ~~considers~~considered U.N. sanctions still ended. The Biden Administration revoked the assertion of U.N. sanctions snapback on February 18, 2021, as noted above. Sanctions Imposed Subsequent to the U.S. Exit from the JCPOA President Joseph Biden and his top foreign policy officials have ~~U.N. sanctions still ended. The Council also considers the U.N.~~
~~ban or arms transfers to and from Iran to have expired as scheduled on October 18, 2020.~~
~~Sanctions Imposed Subsequent to the U.S. Exit from the JCPOA~~
~~In a September 13, 2020 editorial, the presumptive winner of the 2020 election, former Vice~~
~~President Joseph Biden,~~ expressed an intent to rejoin the JCPOA if Iran comes back into expressed an intent to rejoin the JCPOA if Iran comes back into
~~compliance.57 Rejoining the agreement will in all likelihood~~compliance.58 They have acknowledged in press interviews that doing so will require again easing those sanctions require again easing those sanctions
~~that~~that were suspended during the 2016- suspended during the 2016-18 2018 period of U.S. implementation of the JCPOAperiod of U.S. implementation of the JCPOA~~. And, Iran is~~
~~almost certain to demand that the additional economic sanctions imposed by the Trump~~
~~Administration subsequent to 2018 must be eased as well as a condition of Iran’s return to full~~

55, as well as economic sanctions imposed by the Trump Administration that are “inconsistent” with the agreement (ie. any sanctions on Iran’s economic sectors). The following sanctions will likely be the subject of negotiations on a U.S. 56 The JCPOA committed the United States to terminate sanctions on some entities designated under INKSNA. The JCPOA committed the United States to terminate sanctions on some entities designated under INKSNA.
5657 For more information, see CRS Report R44942, For more information, see CRS Report R44942, U.S. Decision to Cease Implementing the Iran Nuclear Agreement, ,
by Kenneth Katzman, Paul K. Kerr, and Valerie Heitshusen. by Kenneth Katzman, Paul K. Kerr, and Valerie Heitshusen.
5758 Joseph R. Biden editorial “Joe Biden: There Joseph R. Biden editorial “Joe Biden: There'’s a smarter way to be tough on Iran.” CNN, September 13, 2020. s a smarter way to be tough on Iran.” CNN, September 13, 2020.
Congressional Research Service Congressional Research Service
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~~compliance with the terms of the accord. Trump Administration officials say they will continue~~
~~adding sanctions on Iran as long as the administration is in office.58~~
~~The following sanctions will likely be the subject of negotiations on a U.S.~~ return to JCPOA return to JCPOA
implementation, noting, as discussed above, that arms and proliferation, terrorism-related, and implementation, noting, as discussed above, that arms and proliferation, terrorism-related, and
human rights-related sanctions human rights-related sanctions ~~were not eased as part of the JCPOA.~~
~~On the other hand, the~~are not inconsistent with the JCPOA. The Trump Administration Trump Administration ~~has~~ designated several Iranian economic entities, designated several Iranian economic entities,
including its Central Bank, as terrorism-supporting entities, and Iran is including its Central Bank, as terrorism-supporting entities, and Iran is ~~likely to demand~~demanding that any that any
economic entity be “de-listed” from U.S. sanctions as part of a U.S. return to the JCPOA.59 A economic entity be “de-listed” from U.S. sanctions as part of a U.S. return to the JCPOA.59 A
U.S. return to the JCPOA would likely require “de-listing” not only all the entities de-listed for U.S. return to the JCPOA would likely require “de-listing” not only all the entities de-listed for
sanctions in 2016, but also the hundreds of sanctions in 2016, but also the hundreds of ~~entities listed~~additional economic entities designated for sanctions since the U.S. exit from the since the U.S. exit from the JCPOA~~JCPOA and~~
~~the entities listed under the economy-centric executive orders issued since 2018~~. And, Iran and . And, Iran and
the United Nations considers the U.N. ban on arms transfers to and from Iran to have expired on the United Nations considers the U.N. ban on arms transfers to and from Iran to have expired on
October 18, 2020, in accordance with Resolution 2231,60 and it is possible Iran might demand October 18, 2020, in accordance with Resolution 2231,60 and it is possible Iran might demand
that sanctions related to arms transfers be eased in a revised JCPOA. that sanctions related to arms transfers be eased in a revised JCPOA.
The post-JCPOA sanctions U.S. sanctions include: The post-JCPOA sanctions U.S. sanctions include:
 The Countering America’s Adversaries through Terrorism Sanctions Act  The Countering America’s Adversaries through Terrorism Sanctions Act
(CAATSA (CAATSA~~). Enacted~~, enacted in August 2017 in August 2017). Most provisions focus on arms, missiles, . Most provisions focus on arms, missiles,
and human rights and might not necessarily require easing in a revived JCPOA. and human rights and might not necessarily require easing in a revived JCPOA.
  The designation of the IRGC as an FTO. April 2019. As noted above, no IRGC The designation of the IRGC as an FTO. April 2019. As noted above, no IRGC
sanctions were lifted to implement the JCPOA. sanctions were lifted to implement the JCPOA.
 Executive Order 13871 sanctioning Iran’s minerals and metals sector. May 2019  Executive Order 13871 sanctioning Iran’s minerals and metals sector. May 2019.
 Executive Order 13876 sanctioning the office of Iran’s Supreme Leader. June  Executive Order 13876 sanctioning the office of Iran’s Supreme Leader. June
2019. Even though human rights related sanctions were not required to be eased 2019. Even though human rights related sanctions were not required to be eased
as part of the JCPOA, it can be argued that Iranian negotiators will insist on the as part of the JCPOA, it can be argued that Iranian negotiators will insist on the
revocation of this revocation of this ~~Order in negotiations on a revised JCPOA~~order because of the because of the
political sensitivity of his position in Iran’s hierarchy. political sensitivity of his position in Iran’s hierarchy.
 Central Bank named as a terrorism entity under E.O. 13224. September 2019.  Central Bank named as a terrorism entity under E.O. 13224. September 2019.
Because of the centrality of the Central Bank to Iran’s financial system, Iran Because of the centrality of the Central Bank to Iran’s financial system, Iran
~~might demand~~is demanding that this designation be revoked. that this designation be revoked.
 Executive Order 13902 sanctioning the construction, manufacturing, mining, and  Executive Order 13902 sanctioning the construction, manufacturing, mining, and
textile sector. January 2020. textile sector. January 2020. ~~As noted, numerous Iranian banks not sanctioned~~
~~under other Orders were designated for sanctions under this Order in October~~
~~2020.~~
 Executive Order 13949 sanctioning entities that facilitate sales of conventional  Executive Order 13949 sanctioning entities that facilitate sales of conventional
weaponry to Iran (September 2020). U.S. sanctions on conventional weapons weaponry to Iran (September 2020). U.S. sanctions on conventional weapons
were not required to be eased in implementation of the JCPOA, were not required to be eased in implementation of the JCPOA,

~~58 Secretary of State Michael Pompeo. Statement: The Importance of Sanctions on Iran. November 18, 2020.~~
~~59 “Trump Administration Hopes to Make Iran Pressure Campaign Harder to Reverse.” Wall Street Journal, October~~
~~23, 2020.~~
~~60 “U.S. says Iran sanctions back on, but the world is ignoring Washington.” CBS News, September 21, 2020.~~
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42

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~~International Implementation and Compliance~~
~~During 2010-2016, converging international views on Iran’s expanding nuclear program~~
~~produced global consensus to pressure Iran through sanctions. All the JCPOA parties publicly~~
~~opposed the U.S. decision to exit the JCPOA in 2018 and have sought to continue to provide its~~
~~economic benefits to Iran. A comparison between U.S., U.N., and EU sanctions is below.61~~ International Implementation and Compliance During 2010-2016, converging international views on Iran’s expanding nuclear program produced global consensus to pressure Iran through sanctions. All the JCPOA parties publicly opposed the U.S. decision to exit the JCPOA in 2018 and have sought to continue to provide its economic benefits to Iran. A comparison between U.S., U.N., and EU sanctions is below.61 59 “Trump Administration Hopes to Make Iran Pressure Campaign Harder to Reverse.” Wall Street Journal, October 23, 2020. 60 “U.S. says Iran sanctions back on, but the world is ignoring Washington.” CBS News, September 21, 2020. 61 See CRS Report R44017, Iran’s Foreign and Defense Policies, by Kenneth Katzman. Congressional Research Service 42 Iran Sanctions
European Union (EU)
After the passage of Resolution 1929, European Union (EU) sanctions on Iran became nearly as After the passage of Resolution 1929, European Union (EU) sanctions on Iran became nearly as
extensive as those of the United States. This contrasted with earlier periods, when the EU extensive as those of the United States. This contrasted with earlier periods, when the EU
countries refused to join the 1995 U.S. trade ban on Iran, EU countries rescheduled $16 billion in countries refused to join the 1995 U.S. trade ban on Iran, EU countries rescheduled $16 billion in
Iranian debt bilaterally, and EU and Iran held talks on a trade agreement during 2002-2005.62 Iranian debt bilaterally, and EU and Iran held talks on a trade agreement during 2002-2005.62
Under the JCPOA, EU sanctions that were imposed in 2012 were lifted, includingUnder the JCPOA, EU sanctions that were imposed in 2012 were lifted, including:
 A ban on oil and gas imports from Iran; including on insurance for shipping oil or  A ban on oil and gas imports from Iran; including on insurance for shipping oil or
petrochemicals from Iran and a freeze on the assets of Iranian shipping firms. petrochemicals from Iran and a freeze on the assets of Iranian shipping firms.
 A ban on trade with Iran in gold, precious metals, diamonds, and petrochemicals.  A ban on trade with Iran in gold, precious metals, diamonds, and petrochemicals.
 A freeze of the assets of Iran’s Central Bank (except for approved civilian trade)  A freeze of the assets of Iran’s Central Bank (except for approved civilian trade)
and a ban on transactions between European and Iranian banks and on short-term and a ban on transactions between European and Iranian banks and on short-term
export credits, guarantees, and insurance. export credits, guarantees, and insurance.
 A ban on exports to Iran of graphite, semi-finished metals, industrial software,  A ban on exports to Iran of graphite, semi-finished metals, industrial software,
shipbuilding technology, oil storage capabilities, and flagging or classification shipbuilding technology, oil storage capabilities, and flagging or classification
services for Iranian tankers and cargo vessels. services for Iranian tankers and cargo vessels.
 large number of entities that had been sanctioned by EU Council decisions and  large number of entities that had been sanctioned by EU Council decisions and
regulations over the years were “delisted” by the EU on Implementation Day. regulations over the years were “delisted” by the EU on Implementation Day.
The following EU sanctions remained in place: The following EU sanctions remained in place:
 An embargo on sales to Iran of arms, missile technology, other proliferation-  An embargo on sales to Iran of arms, missile technology, other proliferation-
sensitive items, and gear for internal repression. sensitive items, and gear for internal repression.
 A ban on Iranian persons and entities designated for human rights abuses or  A ban on Iranian persons and entities designated for human rights abuses or
supporting terrorism from visiting EU countries, and a freeze on their EU-based supporting terrorism from visiting EU countries, and a freeze on their EU-based
assets (see assets (see Appendix A below). below).
Even though the EU countries did not Even though the EU countries did not ~~re-impose~~reimpose sanctions on Iran after the U.S. withdrawal from sanctions on Iran after the U.S. withdrawal from
the JCPOA, many European firms ceased Iran-related transactions or exited the Iran market:63 the JCPOA, many European firms ceased Iran-related transactions or exited the Iran market:63
  ~~Cars and Buses~~Industry. Renault and Citroen of France suspended their post-JCPOA $1 Renault and Citroen of France suspended their post-JCPOA $1
billion billion investments in a joint venture with two Iranian firms to boost car investments in a joint venture with two Iranian firms to boost car
production capacity in Iran. In production capacity in Iran. In ~~August~~ 2018, Daimler (Mercedes Benz) 2018, Daimler (Mercedes Benz)
announced suspension of business in Iranannounced suspension of business in Iran., Scania of Sweden ended an effort to Scania of Sweden ended an effort to
establish a bus factory in establish a bus factory in ~~Iran~~Iran, and Volvo halted truck assembly in Iran ~~and Volvo halted truck assembly in Iran in 2018.~~

~~61 See: CRS Report R44017, Iran’s Foreign and Defense Policies, by Kenneth Katzman.~~
~~62 During the active period of talks, which began in December 2002, there were working groups on the trade agreement~~
~~terms, proliferation, human rights, Iran-sponsored terrorism, counternarcotics, refugees, migration issues, and the~~
~~Iranian opposition PMOI.~~
~~63 “Iran Nuclear Deal: The EU’s Billion-Dollar Deals at Risk,” BBC News, May 11, 2018.~~
~~Congressional Research Service~~
43

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 Other Industry. German industrial giant Siemens said in late 2018 that it would . German industrial giant Siemens said in late 2018 that it would
pursue no new Iranian business. Italy’s Danieli industrial conglomerates and pursue no new Iranian business. Italy’s Danieli industrial conglomerates and
Gruppo Ventura Gruppo Ventura ~~have~~ exited the Iranian market. exited the Iranian market.
  Banking. Among the major banks that publicly announced exiting the Iran market . Among the major banks that publicly announced exiting the Iran market
~~are~~were: DZ Bank and Allianz of Germany; Oberbank of Austria; and Banque : DZ Bank and Allianz of Germany; Oberbank of Austria; and Banque
Wormser Freres of France. In July 2018, at U.S. request, Germany’s central bank Wormser Freres of France. In July 2018, at U.S. request, Germany’s central bank
blocked Iran’s withdrawal of $400 million in cash from the Europaische-blocked Iran’s withdrawal of $400 million in cash from the Europaische-
Iranische Handlesbank (EIH), which is partly owned by Iran.64 Iranische Handlesbank (EIH), which is partly owned by Iran.64
62 During the active period of talks, which began in December 2002, there were working groups on the trade agreement terms, proliferation, human rights, Iran-sponsored terrorism, counternarcotics, refugees, migration issues, and the Iranian opposition PMOI. 63 “Iran Nuclear Deal: The EU’s Billion-Dollar Deals at Risk,” BBC News, May 11, 2018. 64 Germany’s Central Bank Imposes Rule to Stop Cash Delivery to Tehran. Jerusalem Post, August 6, 2018. Congressional Research Service 43 Iran Sanctions   Energy. No EU state is known to have bought Iranian oil since U.S. energy No EU state is known to have bought Iranian oil since U.S. energy
sanctions went back into effect in November 2018. Total SA of France exited a sanctions went back into effect in November 2018. Total SA of France exited a
nearly $5 billion energy investment in South Pars gas field. nearly $5 billion energy investment in South Pars gas field.
  Shipping. Hapag-Lloyd of Germany and Denmark’s AP Moller-Maersk Hapag-Lloyd of Germany and Denmark’s AP Moller-Maersk ~~have~~
~~ceased~~ ceased shipping services to Iran. shipping services to Iran.
  Telecommunications. Germany telecommunications firm Deutsche Telekom Germany telecommunications firm Deutsche Telekom
announced in September 2018 that it would end its business in Iran. announced in September 2018 that it would end its business in Iran.
  Rhum Gas Field. . ~~One project, the~~The Rhum gas field in the North Sea Rhum gas field in the North Sea ~~that~~, which is partly is partly
owned by owned by Iranian Oil Company (a subsidiary of NIOC), has Iranian Oil Company (a subsidiary of NIOC), has ~~been able to~~
~~continue~~continued operating. In part because the field supplies about 5% of Britain’s operating. In part because the field supplies about 5% of Britain’s
demand for natural gas, in October 2018, the Trump Administration renewed the demand for natural gas, in October 2018, the Trump Administration renewed the
license of BP and Serica Energy to continue providing services to the field.65 license of BP and Serica Energy to continue providing services to the field.65
European Special Purpose Vehicle/INSTEX
The EU countries continue to support the JCPOA while assailing Tehran’s violations of its The EU countries continue to support the JCPOA while assailing Tehran’s violations of its
nuclear commitmentsnuclear commitments - —despite the Trump Administration’s maximum pressure policy on Iran and despite the Trump Administration’s maximum pressure policy on Iran and
Iran’s violations of the JCPOA’s terms. On August 6, 2018, a 1996 EU “blocking statute” that Iran’s violations of the JCPOA’s terms. On August 6, 2018, a 1996 EU “blocking statute” that
seeks to protect EU firms from seeks to protect EU firms from ~~re-imposed~~reimposed U.S. sanctions took effect. U.S. sanctions took effect.
In September 2018, Germany, France, and Britain, joined by Russia and China, as well as Iran, In September 2018, Germany, France, and Britain, joined by Russia and China, as well as Iran,
endorsed the creation of a “special purpose vehicle” (SPV) that would facilitate trade with Iran by endorsed the creation of a “special purpose vehicle” (SPV) that would facilitate trade with Iran by
avoiding dollar-denominated transactions or other exposure to the U.S. market. In a January 31, avoiding dollar-denominated transactions or other exposure to the U.S. market. In a January 31,
2019, joint statement, France, Britain, and Germany announced the registration of2019, joint statement, France, Britain, and Germany announced the registration of ~~the SPV,~~
~~named~~ the “Instrument for Supporting Trade Exchanges” (INSTEX) the “Instrument for Supporting Trade Exchanges” (INSTEX)~~. Its~~, with the stated focus stated focus ~~has been~~ on on
transactions in goods not subject to sanctions, including medicines, medical devicestransactions in goods not subject to sanctions, including medicines, medical devices~~, and food,~~
~~but it might eventually expand to oil and other products~~ and food.66 In April 2019, Iran set up the required .66 In April 2019, Iran set up the required
counterparty—the “Special Trade and Finance Instrument” (STFI). Six additional countries in counterparty—the “Special Trade and Finance Instrument” (STFI). Six additional countries in
Europe joined the INSTEX system in December 2019 and the mechanism subsequently sought to Europe joined the INSTEX system in December 2019 and the mechanism subsequently sought to
speed up processing of medical transactions to help Iran deal with the COVID-19 pandemic in speed up processing of medical transactions to help Iran deal with the COVID-19 pandemic in
2020. On March 31, 2020, INSTEX completed its first transaction—for about $540,000 worth of 2020. On March 31, 2020, INSTEX completed its first transaction—for about $540,000 worth of
~~medical equipment.67~~
~~At the August 2019 G-7 summit in Biarritz, France, French President Emmanuel Macron~~
~~proposed to provide a $15 billion credit line for Iran to purchase goods through INSTEX, with the~~

~~64 Germany’s Central Bank Imposes Rule to Stop Cash Delivery to Tehran. Jerusalem Post, August 6, 2018.~~
~~65 “U.S. Grants BP, Serica License to Run Iran-Owned North Sea Field.” Reuters, October 9, 2018.~~
~~66 Joint Statement on the New Mechanism to Facilitate Trade with Iran. January 31, 2019.~~
~~67 “EU Ramps up Trade System with Iran despite U.S. Threats.” Wall Street Journal, March 31, 2020.~~
~~Congressional Research Service~~
44

~~link to page 27~~ ~~Iran Sanctions~~

~~credit line to be secured by future Iranian oil deliveries. U.S. officials later signaled opposition to~~
~~the credit line proposal and it did not advance.68~~medical equipment67 but the vehicle has been dormant since.
While attempting to preserve civilian economic engagement with Iran, the European countries While attempting to preserve civilian economic engagement with Iran, the European countries
have sought to support U.S. efforts to counter Iran’s terrorism and proliferation activities. In have sought to support U.S. efforts to counter Iran’s terrorism and proliferation activities. In
January 2019, the EU added Iran’s intelligence service (MOIS) and two intelligence operatives to January 2019, the EU added Iran’s intelligence service (MOIS) and two intelligence operatives to
its terrorism-related sanctions list in response to allegations of Iranian terrorism plotting in its terrorism-related sanctions list in response to allegations of Iranian terrorism plotting in
Europe. Germany and Italy have denied landing rights to Iran’s Mahan Air, which the United Europe. Germany and Italy have denied landing rights to Iran’s Mahan Air, which the United
States has designated as a terrorism-supporting entity. States has designated as a terrorism-supporting entity.
SWIFT Electronic Payments System
The management of the Brussels-based Swift electronic payments system has sought to balance The management of the Brussels-based Swift electronic payments system has sought to balance
financial risks with the policies of the EU governments. In March 2012, SWIFT acceded to an EU financial risks with the policies of the EU governments. In March 2012, SWIFT acceded to an EU
request to expel 14 EU-sanctioned Iranian banks.request to expel 14 EU-sanctioned Iranian banks.6968 Some Iranian banks were still able to conduct Some Iranian banks were still able to conduct
electronic transactions with the European Central Bank via the “Target II” system. Even though electronic transactions with the European Central Bank via the “Target II” system. Even though
65 “U.S. Grants BP, Serica License to Run Iran-Owned North Sea Field.” Reuters, October 9, 2018. 66 Joint Statement on the New Mechanism to Facilitate Trade with Iran. January 31, 2019. 67 “EU Ramps up Trade System with Iran despite U.S. Threats.” Wall Street Journal, March 31, 2020. 68 Avi Jorish, “Despite Sanctions, Iran’s Money Flow Continues,” Wall Street Journal, June 25, 2013. Congressional Research Service 44 Iran Sanctions the EU has not reimposed~~the EU has not re-imposed~~ sanctions on Iran in concert with the Trump Administration, SWIFT’s sanctions on Iran in concert with the Trump Administration, SWIFT’s
board is independent and, in order to avoid risk of U.S. penalties, in late 2018, the system again board is independent and, in order to avoid risk of U.S. penalties, in late 2018, the system again
disconnected the Iranian banks that are designated for U.S. sanctions. disconnected the Iranian banks that are designated for U.S. sanctions.
China and Russia
Russia and China, two permanent members of the U.N. Security Council and parties to the Russia and China, two permanent members of the U.N. Security Council and parties to the
JCPOA, historically have imposed only those sanctions required by Security Council resolutions. JCPOA, historically have imposed only those sanctions required by Security Council resolutions.
Increasingly aligned on regional issues, Iran and Russia have agreed to expand energy and more Increasingly aligned on regional issues, Iran and Russia have agreed to expand energy and more
general trade, but there is little evident implementation of any agreements. In December 2018, general trade, but there is little evident implementation of any agreements. In December 2018,
Iran signed a free trade deal with the Russia-led “Eurasian Economic Union,” suggesting Russian Iran signed a free trade deal with the Russia-led “Eurasian Economic Union,” suggesting Russian
intent to help Iran circumvent U.S. sanctions. intent to help Iran circumvent U.S. sanctions.
China is a major factor in the effectiveness of any sanctions regime on Iran because China China is a major factor in the effectiveness of any sanctions regime on Iran because China
remains Iran’s largest oil customer. During 2012-2016, China was instrumental in reducing Iran’s remains Iran’s largest oil customer. During 2012-2016, China was instrumental in reducing Iran’s
total oil exports by reducing its buys from Iran to about 435,000 barrels per day from its 2011 total oil exports by reducing its buys from Iran to about 435,000 barrels per day from its 2011
average of 600,000 barrels per day. Since the reimposition of U.S. sanctions, Chinaaverage of 600,000 barrels per day. Since the reimposition of U.S. sanctions, China ~~has reduced~~
~~its oil imports from Iran (see Table 1), but China~~ has continued to import Iranian oil despite the has continued to import Iranian oil despite the
ending of the SRE as of May 2, 2019ending of the SRE as of May 2, 2019, and it has increased its purchases from Iran since the start of the Biden Administration. Iran’s automotive sector obtains a significant proportion of . Iran’s automotive sector obtains a significant proportion of
its parts from China. In November 2018, China’s Kunlun Bank—a CNPC affiliate that was its parts from China. In November 2018, China’s Kunlun Bank—a CNPC affiliate that was
sanctioned under CISADA in 2012—reportedly stopped accepting Euro and then China currency-sanctioned under CISADA in 2012—reportedly stopped accepting Euro and then China currency-
denominated payments from Iran.denominated payments from Iran.7069 A state-owned China firm (CNPC) withdrew from a major A state-owned China firm (CNPC) withdrew from a major
phase of Iran’s South Pars gas field, perhaps to avoid U.S. sanctions. phase of Iran’s South Pars gas field, perhaps to avoid U.S. sanctions.
Since mid-2019, the Administration has sanctioned numerous Chinese economic entities for Since mid-2019, the Administration has sanctioned numerous Chinese economic entities for
transactions with Iran.transactions with Iran.7170 On July 23, 2019, the Administration sanctioned (under IFCA) a small On July 23, 2019, the Administration sanctioned (under IFCA) a small

~~68 “Trump Administration cool to French plan for $15 billion Iranian credit line: officials.” Reuters, September 4, 2019;~~
~~Press briefing by Ambasador Brian Hook, September 4, 2019.~~
~~69 Avi Jorish, “Despite Sanctions, Iran’s Money Flow Continues,” Wall Street Journal, June 25, 2013.~~
70Chinese firm, Zhuhai Zhenrong Company Ltd., for buying oil from Iran.71 Prior to the expiration of the SREs, China had stockpiled 20 million barrels of Iranian oil at its Dalian port,72 and importation of that oil apparently is not counted until it clears customs checkpoints. China is also a large investor in Iran. China’s President Xi Jinping visited Iran and other Middle East countries in the immediate aftermath of the JCPOA, and stated that Iran is a vital link in an effort to extend its economic influence westward through its “One Belt, One Road” initiative. In concert, Chinese firms and entrepreneurs have been modernizing Iran’s rail and other infrastructure.73 Since 2019, Iran and China have negotiated a reported 25-year deal for China to invest a total of $280 billion in Iran’s oil, gas, and petrochemical sectors, and $120 billion to upgrade Iran’s transport and manufacturing infrastructure.74 The deal reportedly might include 69 “As U.S. Sanctions Loom, China’s Bank of Kunlun to Stop Receiving Iran Payments—Sources.” “As U.S. Sanctions Loom, China’s Bank of Kunlun to Stop Receiving Iran Payments—Sources.” Reuters, October , October
23, 2018. 23, 2018.
7170 In April 2018, the Commerce Department (Bureau of Industry and Security, BIS, which administers Export In April 2018, the Commerce Department (Bureau of Industry and Security, BIS, which administers Export
Administration Regulations) issued a denial of export privileges action against China-based ZTE Corporation and its Administration Regulations) issued a denial of export privileges action against China-based ZTE Corporation and its
affiliates. The action was taken on the grounds that ZTE did not uphold the terms of a March 2017 settlement affiliates. The action was taken on the grounds that ZTE did not uphold the terms of a March 2017 settlement
~~Congressional Research Service~~
45

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~~Chinese firm, Zhuhai Zhenrong Company Ltd., for buying oil from Iran.72 Prior to the expiration~~
~~of the SREs, China had stockpiled 20 million barrels of Iranian oil at its Dalian port,73 and~~
~~importation of that oil apparently is not counted until it clears customs checkpoints.~~
~~Yet, China continues to invest in Iran. China’s President Xi Jinping visited Iran and other Middle~~
~~East countries in the immediate aftermath of the JCPOA, and stated that Iran is a vital link in an~~
~~effort to extend its economic influence westward through its “One Belt, One Road” initiative. In~~
~~concert, Chinese firms and entrepreneurs have been modernizing Iran’s rail and other~~
~~infrastructure.74 Since 2019, Iran and China have discussed a 25-year deal for China investments~~
~~in Iran to total $280 billion to be invested in Iran’s oil, gas, and petrochemical sectors, and $120~~
~~billion in upgrading Iran’s transport and manufacturing infrastructure.75 China and Iran reportedly~~
~~have finalized, or nearly finalized, the agreement, which might include~~ agreement with BIS. 71 “The United States to Impose Sanctions on Chinese Firm Zhuhai Zhenrong Company Limited for Purchasing Oil from Iran. Department of State, July 22, 2019. 72 “Boxed In: $1 billion of Iranian Crude Sits at China’s Dalian Port.” Reuters, May 1, 2019. 73 Thomas Erdbrink. “China’s Push to Link East and West Puts Iran at ‘Center of Everything.’” New York Times, July 25, 2017. 74 “China and Iran Flesh out Strategic Partnership.” Petroleum Economist, September 3, 2019. Congressional Research Service 45 Iran Sanctions arms sales to Iran and arms sales to Iran and
other strategic ties, and other strategic ties, and ~~including~~ China’s purchases of Iranian oil at discounted prices.China’s purchases of Iranian oil at discounted prices.7675 China and Iran signed the agreement formally in late March 2021.
Japan/Korean Peninsula/Other East Asian Countries
During 2010-2016, Japan and South Korea enforced sanctions on Iran similar to those imposed During 2010-2016, Japan and South Korea enforced sanctions on Iran similar to those imposed
by the United States and the EU. Both countries cut imports of Iranian oil sharply and banks in by the United States and the EU. Both countries cut imports of Iranian oil sharply and banks in
the two countries restricted Iran’s foreign exchange assets held in their banks. From 2016-2018, the two countries restricted Iran’s foreign exchange assets held in their banks. From 2016-2018,
when U.S. sanctions were suspended, both countries increased importation of Iranian oil, and when U.S. sanctions were suspended, both countries increased importation of Iranian oil, and
eased restrictions on Iran’s accounts. However, both countries—and their companies—have eased restrictions on Iran’s accounts. However, both countries—and their companies—have
historically been unwilling to undertake transactions with Iran that could violate U.S. sanctions, historically been unwilling to undertake transactions with Iran that could violate U.S. sanctions,
and both ended their Iranian oil purchases after their SREs were ended in May 2019. South Korea and both ended their Iranian oil purchases after their SREs were ended in May 2019. South Korea
sought, but was denied, Administration concurrence to continue to import Iranian condensates (a sought, but was denied, Administration concurrence to continue to import Iranian condensates (a
very light oil) on which South Korea’s petrochemical sector depends.very light oil) on which South Korea’s petrochemical sector depends. Among banks, South Among banks, South
Korea’s Woori Bank and Industrial Bank of Korea, and Nomura Holdings of Japan, are reportedly Korea’s Woori Bank and Industrial Bank of Korea, and Nomura Holdings of Japan, are reportedly
restricting Iran’s use of its Central Bank accounts held in both countries.restricting Iran’s use of its Central Bank accounts held in both countries.~~77 Iran reportedly has~~
76 South Korean banks reportedly hold about $7 billion in Iranian foreign exchange assets,77 and the Biden Administration reportedly has considered licensing the transfer to Iran of $1 billion of those funds for humanitarian purchases through the “Swiss Humanitarian Channel” (see above). Iran reportedly has sued South Korean banks for refusing to release Iran’s funds to buy humanitarian items there.sued South Korean banks for refusing to release Iran’s funds to buy humanitarian items there.
Japanese banks reportedly hold about $3 billion in Iranian assets.78 Other East Asian Countries
North Korea, like Iran, has been subject to significant international sanctions, and North Korea North Korea, like Iran, has been subject to significant international sanctions, and North Korea
has not pledged to abide by international sanctions against Iran. The two countries reportedly has not pledged to abide by international sanctions against Iran. The two countries reportedly
share information on a wide range of strategic ventures, particularly the development of ballistic share information on a wide range of strategic ventures, particularly the development of ballistic
missiles. A portion of the oil that China buys from Iran (and from other suppliers) might be missiles. A portion of the oil that China buys from Iran (and from other suppliers) might be
transshipped to North Korea, but it is not known if North Korea buys any Iranian oil directly.transshipped to North Korea, but it is not known if North Korea buys any Iranian oil directly.7879
Taiwan and Singapore have generally been small buyers of Iranian oil. Taiwan resumed imports Taiwan and Singapore have generally been small buyers of Iranian oil. Taiwan resumed imports
of Iranian oil after sanctions were eased in 2016 and received an SRE in November 5, 2018, but of Iranian oil after sanctions were eased in 2016 and received an SRE in November 5, 2018, but

~~agreement with BIS.~~
~~72 “The United States to Impose Sanctions on Chinese Firm Zhuhai Zhenrong Company Limited for Purchasing Oil~~
~~from Iran. Department of State, July 22, 2019.~~
~~73 “Boxed In: $1 billion of Iranian Crude Sits at China’s Dalian Port.” Reuters, May 1, 2019.~~
~~74 Thomas Erdbrink. “China’s Push to Link East and West Puts Iran at ‘Center of Everything.’” New York Times, July~~
~~25, 2017.~~
~~75 “China and Iran Flesh out Strategic Partnership.” Petroleum Economist, September 3, 2019.~~
~~76 “Defying U.S., China and Iran near Trade and Military Partnership.” New York Times, July 11, 2020.~~
~~77 Author conversations with South Korean officials, January-December 2019.~~
~~78 “The Military Relationship between Iran and North Korea.” Inside Sources, January 27, 2020.~~
~~Congressional Research Service~~
46

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has bought no Iranian oil since late 2018. Singapore has been a small buyer of Iranian oil and has has bought no Iranian oil since late 2018. Singapore has been a small buyer of Iranian oil and has
not bought any Iranian oil since U.S. sanctions went back into effect in 2018. not bought any Iranian oil since U.S. sanctions went back into effect in 2018.
India and Pakistan
Iran’s economy is highly integrated into those of its immediate neighbors in South Asia. India Iran’s economy is highly integrated into those of its immediate neighbors in South Asia. India
cites U.N. Security Council resolutions as its guideline for policy toward Iran. During 2011-2016, cites U.N. Security Council resolutions as its guideline for policy toward Iran. During 2011-2016,
when U.N. sanctions were in force on Iran, India’s central bank ceased using a Tehran-based when U.N. sanctions were in force on Iran, India’s central bank ceased using a Tehran-based
regional body, the Asian Clearing Union, to handle transactions with Iran, and the two countries regional body, the Asian Clearing Union, to handle transactions with Iran, and the two countries
agreed to settle half of India’s oil buys from Iran in India’s currency, the rupee. India reduced its agreed to settle half of India’s oil buys from Iran in India’s currency, the rupee. India reduced its
imports of Iranian oil substantially after 2011, but, after sanctions were eased in 2016, India’s oil imports of Iranian oil substantially after 2011, but, after sanctions were eased in 2016, India’s oil
75 “Defying U.S., China and Iran near Trade and Military Partnership.” New York Times, July 11, 2020. 76 Author conversations with South Korean officials, January-December 2019. 77 Iran Says It Hopes South Korea, Japan Will Release $1 Billion in Blocked Funds. Reuters, February 23, 2021. 78 Ibid. 79 “The Military Relationship between Iran and North Korea.” Inside Sources, January 27, 2020. Congressional Research Service 46 Iran Sanctions imports from Iran increased to as much as 800,000 bpd in July 2018—well above 2011 levels. imports from Iran increased to as much as 800,000 bpd in July 2018—well above 2011 levels.
India paid Iran the $6.5 billion it owed for oil purchased during 2012-2016.India paid Iran the $6.5 billion it owed for oil purchased during 2012-2016.7980 India has not India has not
imported Iranian oil since its SRE ended in May 2019. imported Iranian oil since its SRE ended in May 2019.
In 2015, India In 2015, India ~~and Iran agreed that India would~~agreed to help develop Iran’s Chahbahar port and an help develop Iran’s Chahbahar port and an
associated railway that would enable India to trade with Afghanistan unimpeded by Pakistan. In associated railway that would enable India to trade with Afghanistan unimpeded by Pakistan. In
May 2016, Indian Prime Minister Narendra Modi visited Iran and signed an agreement to invest May 2016, Indian Prime Minister Narendra Modi visited Iran and signed an agreement to invest
$500 million to develop the port and related infrastructure. $500 million to develop the port and related infrastructure. ~~The Trump Administration has given~~
Even though the Trump Administration gave India the “Afghanistan reconstruction” exception under Section 1244(f) of IFCAIndia the “Afghanistan reconstruction” exception under Section 1244(f) of IFCA~~. However, in~~
~~July 2020, Iran cited India’s non-performance of contracts to exclude the country from further~~
~~work on the railway at the port.80 In October 2020, Iran excluded India (ONGC Videsh) from the~~
~~development of Farzad-B gas field in the Persian Gulf for its failure to move forward on the~~
~~project.81~~
, India largely stopped work on the project until late 2020. It accelerated work in early 2021 and the port is expected to be declared operational no later than May 2021. Iran’s economic relations with Pakistan are less extensive than are its economic ties to India. One Iran’s economic relations with Pakistan are less extensive than are its economic ties to India. One
test of Pakistan’s compliance with sanctions was a pipeline project that would carry Iranian gas to test of Pakistan’s compliance with sanctions was a pipeline project that would carry Iranian gas to
Pakistan—a $7 billion project that U.S. officials on several occasions stated would be subject to Pakistan—a $7 billion project that U.S. officials on several occasions stated would be subject to
ISA sanctions. Iran reportedly completed the pipeline on its side of the border but, during ISA sanctions. Iran reportedly completed the pipeline on its side of the border but, during
President Hassan Rouhani’s visit to Pakistan in March 2016, Pakistan did not commit to complete President Hassan Rouhani’s visit to Pakistan in March 2016, Pakistan did not commit to complete
the line. In 2009, India dissociated itself from the project. the line. In 2009, India dissociated itself from the project.
Turkey
Turkey is a large neighbor whose relations with Iran have been uneven. Prior to the Trump Turkey is a large neighbor whose relations with Iran have been uneven. Prior to the Trump
Administration’s ending of all SREs in 2019, Turkey bought about 40% of its oil from Iran. Administration’s ending of all SREs in 2019, Turkey bought about 40% of its oil from Iran.
Turkey reduced purchases of Iranian oil during 2012-2016, but its buys returned to 2011 levels Turkey reduced purchases of Iranian oil during 2012-2016, but its buys returned to 2011 levels
after sanctions on Iran were eased in 2016. Turkey’s SRE to buy Iranian oil expired in May 2019 after sanctions on Iran were eased in 2016. Turkey’s SRE to buy Iranian oil expired in May 2019
and Turkey has not been a buyer of Iranian oil since, according to Bloomberg data. Turkey also and Turkey has not been a buyer of Iranian oil since, according to Bloomberg data. Turkey also
buys natural gas from Iran via a pipeline built in 1997, which at first was used for a swap buys natural gas from Iran via a pipeline built in 1997, which at first was used for a swap
arrangement under which gas from Turkmenistan was exported to Turkey. Direct Iranian gas arrangement under which gas from Turkmenistan was exported to Turkey. Direct Iranian gas
exports to Turkey through the line began in 2001.exports to Turkey through the line began in 2001.8281 No ISA sanctions were imposed on the No ISA sanctions were imposed on the
pipeline on the grounds that the gas supplies were crucial to Turkey’s energy security. pipeline on the grounds that the gas supplies were crucial to Turkey’s energy security.

~~79 “India Seeks to Pay $6.5 Billion to Iran for Oil Imports.” Economic Times of India. May 16, 2016.~~
~~80 “Iran drops India from Chabahar rail project, cites funding delay.” The Hindu, July 14, 2020~~
~~81 “India loses giant gas field in Iran – even though 3 Indian companies discovered the field.” Oil and Gas 360, October~~
~~21, 2020.~~
~~82 “Iran Clears 40% of Gas Fine to Turkey.” Financial Tribune, June 13, 2017.~~
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There have been some indications that banks in Turkey, including Halkbank, have continued to There have been some indications that banks in Turkey, including Halkbank, have continued to
allow Iran to obtain hard currency, including in the form of gold, in return for Iranian currency, allow Iran to obtain hard currency, including in the form of gold, in return for Iranian currency,
oil, and other commodities. U.S. prosecutions have occurred against Halkbank and various oil, and other commodities. U.S. prosecutions have occurred against Halkbank and various
individuals, for alleged violations of U.S. sanctions on Iran.individuals, for alleged violations of U.S. sanctions on Iran.8382
The rich energy reserves of the Caspian Sea have created challenges for U.S. efforts to deny Iran The rich energy reserves of the Caspian Sea have created challenges for U.S. efforts to deny Iran
financial resources. The Clinton and George W. Bush Administrations cited potential ISA financial resources. The Clinton and George W. Bush Administrations cited potential ISA
sanctions to deter oil pipeline routes involving Iran—thereby successfully promoting an the sanctions to deter oil pipeline routes involving Iran—thereby successfully promoting an the
alternate route from Azerbaijan (Baku) to Turkey (Ceyhan), which became operational in 2005. alternate route from Azerbaijan (Baku) to Turkey (Ceyhan), which became operational in 2005.
Iraq and Persian Gulf States
The Arab monarchy states of the Persian Gulf—Saudi Arabia, United Arab Emirates, Qatar, The Arab monarchy states of the Persian Gulf—Saudi Arabia, United Arab Emirates, Qatar,
Kuwait, Bahrain, and Oman—are oil exporters and close allies of the United States, but they all Kuwait, Bahrain, and Oman—are oil exporters and close allies of the United States, but they all
maintain relatively normal trade with Iran. The UAE has a large presence of Iranian firms and maintain relatively normal trade with Iran. The UAE has a large presence of Iranian firms and
80 “India Seeks to Pay $6.5 Billion to Iran for Oil Imports.” Economic Times of India. May 16, 2016. 81 “Iran Clears 40% of Gas Fine to Turkey.” Financial Tribune, June 13, 2017. 82 Department of Justice. Turkish Bank Charged In Manhattan Federal Court For Its Participation In A Multibillion-Dollar Iranian Sanctions Evasion Scheme. October 15, 2019. Congressional Research Service 47 Iran Sanctions several UAE-based firms have been sanctioned by the United States, including for facilitating several UAE-based firms have been sanctioned by the United States, including for facilitating
Iranian oil and petrochemicals exports, as noted in the tables at the end of the report. Iranian oil and petrochemicals exports, as noted in the tables at the end of the report.
Iran and several of the Gulf states, including Kuwait and Bahrain, have had discussions on Iran and several of the Gulf states, including Kuwait and Bahrain, have had discussions on
various energy and related projects. However, the projects have not materialized because of broad various energy and related projects. However, the projects have not materialized because of broad
Iran-Gulf disputes. Qatar and Iran share the large gas field in the Gulf waters between them, and Iran-Gulf disputes. Qatar and Iran share the large gas field in the Gulf waters between them, and
their economic relations have become closer in light of the isolation of Qatar by three of its GCC their economic relations have become closer in light of the isolation of Qatar by three of its GCC
neighbors, Saudi Arabia, UAE, and Bahrain. Iran and Oman have active economic relations, neighbors, Saudi Arabia, UAE, and Bahrain. Iran and Oman have active economic relations,
including a joint venture to expand Oman’s Al Duqm port, which is envisioned as a major hub for including a joint venture to expand Oman’s Al Duqm port, which is envisioned as a major hub for
regional trade. Omani banks, some of which operate in Iran, were used to implement some of the regional trade. Omani banks, some of which operate in Iran, were used to implement some of the
financial arrangements of the JPoA and financial arrangements of the JPoA and ~~JCPOA~~JCPOA83 and reportedly still hold substantial sums of Iranian Central Bank foreign exchange assets.84 .84
Iraq has sought to remain engaged economically with Iran while avoiding running afoul of U.S. Iraq has sought to remain engaged economically with Iran while avoiding running afoul of U.S.
sanctions on Iran. In 2013, Iraq signed an agreement with Iran to buy natural gas through a joint sanctions on Iran. In 2013, Iraq signed an agreement with Iran to buy natural gas through a joint
pipeline that would supply several Iraqi power plants. The Trump Administration has pipeline that would supply several Iraqi power plants. The Trump Administration has
accommodated Iraq’s need for Iranian electricity supplies by giving Iraq waiver permission—accommodated Iraq’s need for Iranian electricity supplies by giving Iraq waiver permission—
under Section 1247 of IFCA—to pay Iran for electricity and the Iranian natural gas that runs under Section 1247 of IFCA—to pay Iran for electricity and the Iranian natural gas that runs
Iraq’s power plants. That section provides for waivers of up to 180 days, but the Administration Iraq’s power plants. That section provides for waivers of up to 180 days, but the Administration
has limited the waiver to shorter increments, and requires that the funds due to Iran are held in has limited the waiver to shorter increments, and requires that the funds due to Iran are held in

~~83 Department of Justice.~~ ~~Turkish Bank Charged In Manhattan Federal Court For Its Participation In A Multibillion-~~
~~Dollar Iranian Sanctions Evasion Scheme. October 15, 2019.~~
84escrow at Iraq’s Trade Bank.85 However, in October 2020, Iraq and Iran reached an agreement under which Iran would access the funds in escrow to purchase food and medical goods in Iraq.86Doing so might require the Biden Administration to issue special licenses to convert the funds into U.S. dollars. Syria and Lebanon Iran has sought to use its extensive political influence in both Syria and Lebanon to provide financial assistance to Hezbollah and secure investments in key sectors of the Syrian economy. The Trump Administration sanctioned some Lebanese banks and Lebanese politicians for supporting Hezbollah and Iran, although in the process perhaps weakening the Lebanese banking system and aggravating Lebanon’s economic downturn. In July 2020, the Trump Administration threatened to impose sanctions if Lebanon adopted a Hezbollah plan to buy oil from Iran.87 83 Omani banks had a waiver from U.S. sanctions laws to permit transferring those funds to Iran’s Central Bank, in Omani banks had a waiver from U.S. sanctions laws to permit transferring those funds to Iran’s Central Bank, in
accordance with Section 1245(d)(5) of the National Defense Authorization Act for Fiscal Year 2012 (P.L. 112-81). For accordance with Section 1245(d)(5) of the National Defense Authorization Act for Fiscal Year 2012 (P.L. 112-81). For
text of the waiver, see a June 17, 2015, letter from Assistant Secretary of State for Legislative Affairs Julia Frifield to text of the waiver, see a June 17, 2015, letter from Assistant Secretary of State for Legislative Affairs Julia Frifield to
Senate Foreign Relations Committee Chairman Bob Corker, containing text of the “determination of waiver.” A total of Senate Foreign Relations Committee Chairman Bob Corker, containing text of the “determination of waiver.” A total of
$5.7 billion in Iranian funds had built up in Oman’s Bank Muscat by the time of implementation of the JCPOA in $5.7 billion in Iranian funds had built up in Oman’s Bank Muscat by the time of implementation of the JCPOA in
January 2016. In its efforts to easily access these funds, Iran obtained from the Office of Foreign Assets Control January 2016. In its efforts to easily access these funds, Iran obtained from the Office of Foreign Assets Control
(OFAC) of the Treasury Department a February 2016 special license to convert the funds (held as Omani rials) to (OFAC) of the Treasury Department a February 2016 special license to convert the funds (held as Omani rials) to
dollars as a means of easily converting the funds into Euros. Iran ultimately used a different mechanism to access the dollars as a means of easily converting the funds into Euros. Iran ultimately used a different mechanism to access the
funds as hard currency, but the special license issuance resulted in a May 2018 review by the majority of the Senate funds as hard currency, but the special license issuance resulted in a May 2018 review by the majority of the Senate
Permanent Subcommittee on Investigation to assess whether that license was consistent with U.S. regulations Permanent Subcommittee on Investigation to assess whether that license was consistent with U.S. regulations
Permanent Subcommittee on Investigations of the U.S. Senate. “Review of U.S. Treasury Department’s License to Permanent Subcommittee on Investigations of the U.S. Senate. “Review of U.S. Treasury Department’s License to
Convert Iranian Assets Using the U.S. Financial System.” Majority Report. May 2018. Convert Iranian Assets Using the U.S. Financial System.” Majority Report. May 2018.
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~~escrow at Iraq’s Trade Bank.85 However, in October 2020, Iraq and Iran reached an agreement~~
~~under which Iran would access the funds in escrow to purchase food and medical goods in Iraq.86~~
~~Syria and Lebanon~~
~~Iran has extensive economic relations with and political influence in both Syria and Lebanon. Iran~~
~~has sought to use banks in Lebanon to provide financial assistance to Hezbollah as well as to the~~
~~regime of Syrian President Bashar Al Asad. The Trump Administration has sanctioned some~~
~~Lebanese banks and Lebanese politicians for supporting Hezbollah and Iran, although in the~~
~~process perhaps weakening the Lebanese banking system and aggravating Lebanon’s economic~~
~~downturn. In July 2020, U.S. officials threatened to impose sanctions on Lebanon if the~~
~~government moves forward with a Hezbollah suggestion that the country ease its financial~~
~~difficulties by buying oil from Iran.87~~
84 Iran says US approved release of $3 bln of Iran’s funds in Iraq, Oman, S. Korea. Al Arabiya News, March 7, 2021. 85 Department of State. Waiver Transmittal Letter, April 27, 2020. 86 Iranian official says Iraq agrees to release Iran’s frozen assets. Xinhua, October 13, 2020. 87 “Pompeo: We are trying to prevent Iran from selling crude oil to Hezbollah.” Arab News, July 9, 2020. Congressional Research Service 48 Iran Sanctions In January 2017, Iran and Syria signed a series of economic agreements giving Iranian firms In January 2017, Iran and Syria signed a series of economic agreements giving Iranian firms
increased access to Syria’s mining, agriculture, and telecommunications sectors, as well as increased access to Syria’s mining, agriculture, and telecommunications sectors, as well as
management of a Syrian port.88 In July 2019, Gibraltar diverted an Iranian tanker delivering oil to management of a Syrian port.88 In July 2019, Gibraltar diverted an Iranian tanker delivering oil to
Syria, a transaction that violated EU sanctions on Syria. The ship delivered the oil to Syria after Syria, a transaction that violated EU sanctions on Syria. The ship delivered the oil to Syria after
its release by Gibraltar in August 2019. its release by Gibraltar in August 2019.
Venezuela
During 2020, Iran has expanded its economic relations with the regime of Nicolas Maduro in During 2020, Iran has expanded its economic relations with the regime of Nicolas Maduro in
Venezuela which, like Iran, is heavily targeted by U.S. sanctions. In May 2020, five Iranian Venezuela which, like Iran, is heavily targeted by U.S. sanctions. In May 2020, five Iranian
tankers shipped gasoline to Venezuela, reportedly in exchange for gold (which is a form of hard tankers shipped gasoline to Venezuela, reportedly in exchange for gold (which is a form of hard
currency). U.S. officials threatened sanctions on those as well as four other tankers bound for currency). U.S. officials threatened sanctions on those as well as four other tankers bound for
Venezuela and successfully deterred the latter four from completing their deliveries.89 The United Venezuela and successfully deterred the latter four from completing their deliveries.89 The United
States subsequently took legal action to impound those four shipments. Additional shipments States subsequently took legal action to impound those four shipments. Additional shipments
reportedly arrived in September 2020.90 Iran-Venezuela relations had fluctuated prior to the 2020 reportedly arrived in September 2020.90 Iran-Venezuela relations had fluctuated prior to the 2020
Iranian shipments, and earlier agreements between the two received little, if any, implementation. Iranian shipments, and earlier agreements between the two received little, if any, implementation.
International Financial Institutions/World Bank/IMF and WTO
The United States representatives to international financial institutions are required to vote The United States representatives to international financial institutions are required to vote
against international lending to Iran, but that vote, although weighted, is not sufficient to block against international lending to Iran, but that vote, although weighted, is not sufficient to block
international lending. Asserting that it needs additional funds to cope with the costs of the international lending. Asserting that it needs additional funds to cope with the costs of the
COVID-19 pandemic, Iran applied for a $5 billion International Monetary Fund (IMF) loan in COVID-19 pandemic, Iran applied for a $5 billion International Monetary Fund (IMF) loan in
March 2020. March 2020. ~~Administration officials have~~The Trump Administration opposed the loan on the grounds that Iran has opposed the loan on the grounds that Iran has
sufficient funds to manage its response to the pandemic, and sufficient funds to manage its response to the pandemic, and ~~no loan decision has been announced~~
~~by the IMF.91~~the loan did not proceed.91 However, IMF officials have said since the start of the Biden Administration that they had begun processing the loan application.92
Iran has received no international financial loans since 2005. In 1993, the United States voted its Iran has received no international financial loans since 2005. In 1993, the United States voted its
16.5% share of the World Bank against loans to Iran of $460 million for electricity, health, and 16.5% share of the World Bank against loans to Iran of $460 million for electricity, health, and

~~85 Department of State. Waiver Transmittal Letter, April 27, 2020.~~
~~86 Iranian official says Iraq agrees to release Iran's frozen assets. Xinhua, October 13, 2020.~~
~~87 “Pompeo: We are trying to prevent Iran from selling crude oil to Hezbollah.” Arab News, July 9, 2020.~~
~~88 Iran Signs Phone, Gas Deals with Syria. Agence France Presse, January 17, 2017.~~
~~89 Comments by Ambassador Brian Hook at Hudson Institute Seminar on Iran-Venezuela relations. July 10, 2020.~~
~~90 “Venezuela and Iran continue to defy U.S. oil sanctions with new shipments.” World Oil, September 28, 2020.~~
~~91 “Pompeo Reiterates US Opposition To IMF Loan For Iran.” Radio Farda, April 15, 2020.~~
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irrigation projects, but the loans were approved. During FY1994-FY1996, foreign aid irrigation projects, but the loans were approved. During FY1994-FY1996, foreign aid
appropriations (P.L. 103-87, P.L. 103-306, and P.L. 104-107) cut the amount appropriated for the appropriations (P.L. 103-87, P.L. 103-306, and P.L. 104-107) cut the amount appropriated for the
U.S. contribution to the bank because of its loans to Iran, contributing to a temporary halt in new U.S. contribution to the bank because of its loans to Iran, contributing to a temporary halt in new
bank lending to Iran. In May 2000, the United States’ allies outvoted the United States to approve bank lending to Iran. In May 2000, the United States’ allies outvoted the United States to approve
$232 million in loans for health and sewage projects. During April 2003-May 2005, a total of $232 million in loans for health and sewage projects. During April 2003-May 2005, a total of
$725 million in loans were approved for environmental management, housing reform, water and $725 million in loans were approved for environmental management, housing reform, water and
sanitation projects, and land management projects, plus $400 million for earthquake relief. sanitation projects, and land management projects, plus $400 million for earthquake relief.
WTO Accession
Iran has sought to join the World Trade Organization (WTO). Iran began accession talks in 2006 Iran has sought to join the World Trade Organization (WTO). Iran began accession talks in 2006
after the George W. Bush Administration dropped its objection to Iran’s application as part of an after the George W. Bush Administration dropped its objection to Iran’s application as part of an
effort to persuade Iran to reach a nuclear agreement. The accession process generally takes many effort to persuade Iran to reach a nuclear agreement. The accession process generally takes many
88 Iran Signs Phone, Gas Deals with Syria. Agence France Presse, January 17, 2017. 89 Comments by Ambassador Brian Hook at Hudson Institute Seminar on Iran-Venezuela relations. July 10, 2020. 90 “Venezuela and Iran continue to defy U.S. oil sanctions with new shipments.” World Oil, September 28, 2020. 91 “Pompeo Reiterates US Opposition To IMF Loan For Iran.” Radio Farda, April 15, 2020. 92 “IMF Says Processing Iran’s $5 Billion Loan Request.” Financial Tribune, February 6, 2021. Congressional Research Service 49 Iran Sanctions years, and generally requires consensus of existing WTO members. The Trump Administration years, and generally requires consensus of existing WTO members. The Trump Administration
opposes Iran’s admission, and Iran’s efforts to join the WTO have not advanced. opposes Iran’s admission, and Iran’s efforts to join the WTO have not advanced.
Effectiveness of Sanctions
Trump Administration officials Trump Administration officials ~~assert~~asserted that U.S. sanctions on Iran that U.S. sanctions on Iran ~~have~~ “worked,”“worked,”~~92although~~93although it is it is
arguable that Iran’s policies and behavior arguable that Iran’s policies and behavior ~~have not changed~~did not change dramatically. The Biden Administration has asserted that the policies of the previous administration did not prevent Iran from committing significant violations of the JCPOA or reduce the other challenges Iran poses to U.S. interests. The ~~dramatically. The~~ following sections following sections
assess the effectiveness of Iran sanctions according to assess the effectiveness of Iran sanctions according to ~~a number of~~several criteria. criteria.
Effect on Iran’s Nuclear Program and Strategic Capabilities
The international sanctions regime of 2011-2015 is widely credited with increasing Iran’s The international sanctions regime of 2011-2015 is widely credited with increasing Iran’s
willingness to accept the JCPOA. The Trump Administration willingness to accept the JCPOA. The Trump Administration ~~asserts~~asserted that its campaign of that its campaign of
“maximum pressure” on Iran, implemented mainly through sanctions, “maximum pressure” on Iran, implemented mainly through sanctions, iswas intended to cause Iran to intended to cause Iran to
negotiate a revised JCPOA that would limit not only Iran’s nuclear program but also its missile negotiate a revised JCPOA that would limit not only Iran’s nuclear program but also its missile
program and its regional malign activities. Iran program and its regional malign activities. Iran ~~has~~ refused such negotiations with the Trump refused such negotiations with the Trump
Administration, insisting that the United States provide JCPOA sanctions relief as a precondition Administration, insisting that the United States provide JCPOA sanctions relief as a precondition
to talks.to talks.93 94 Iran has agreed to indirect talks with the Biden Administration to restore the full force of the JCPOA, suggesting that Iran seeks the sanctions relief of the 2015 deal. Still, even though sanctions during 2011-2015 might have made Iranian leaders more Still, even though sanctions during 2011-2015 might have made Iranian leaders more
willing to negotiate nuclear limits, sanctions did not prevent Iran from advancing its nuclear willing to negotiate nuclear limits, sanctions did not prevent Iran from advancing its nuclear
program during that time or since. program during that time or since.
And, even though U.S. and EU sanctions remained on Iran’s missile programs after the JCPOA And, even though U.S. and EU sanctions remained on Iran’s missile programs after the JCPOA
was implemented, Iran was implemented, Iran ~~has been able to expand~~expanded the scale and sophistication of its missile the scale and sophistication of its missile
capabilities, as demonstrated by Iran’s September 14, 2019, strike on critical Saudi energy capabilities, as demonstrated by Iran’s September 14, 2019, strike on critical Saudi energy
infrastructure and Iran’s retaliatory attack for the killing of Qasem Soleimani in January 2020. infrastructure and Iran’s retaliatory attack for the killing of Qasem Soleimani in January 2020.
Sanctions—as well as Resolution 2231—have prevented Iran from buying significant amounts of Sanctions—as well as Resolution 2231—have prevented Iran from buying significant amounts of
major combat systems since the early 1990s. The U.N. ban on Iran’s importation and exportation major combat systems since the early 1990s. The U.N. ban on Iran’s importation and exportation
of weaponry expired on October 18, 2020, according to the U.N. Security Council. U.S. of weaponry expired on October 18, 2020, according to the U.N. Security Council. U.S.
intelligence directors have testified that Iran continues to develop its own increasingly advanced intelligence directors have testified that Iran continues to develop its own increasingly advanced
naval mines, submarines, and attack craft.naval mines, submarines, and attack craft.94

~~92 “U.S. envoy says Iran sanctions working, warns against nuclear breaches.” Reuters, June 27, 2019.~~
~~93 “Iran says pandemic will not force talks with the US.” Al Monitor, April 20, 2020.~~
~~94 Worldwide Threat Assessment of the U.S. Intelligence Community, January 29, 2019.~~
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95
Effects on Iran’s Regional Influence
The imposition, lifting, or reimposition of strict sanctions have arguably had minimal effect on The imposition, lifting, or reimposition of strict sanctions have arguably had minimal effect on
Iran’s regional behavior. Iran intervened extensively in Syria, Iraq, and Yemen during the 2011-Iran’s regional behavior. Iran intervened extensively in Syria, Iraq, and Yemen during the 2011-
2015 period when sanctions had a significant adverse effect on Iran’s economy. Iran has remained 2015 period when sanctions had a significant adverse effect on Iran’s economy. Iran has remained
engaged in these regional conflicts after sanctions were eased in 2016, and since U.S. sanctions engaged in these regional conflicts after sanctions were eased in 2016, and since U.S. sanctions
were reimposed in late 2018. Iran’s regional activities are assessed inwere reimposed in late 2018. Iran’s regional activities are assessed in: CRS Report R44017, CRS Report R44017,
Iran’s Foreign and Defense Policies, by Kenneth Katzman , by Kenneth Katzman
~~Administration officials have~~ 93 “U.S. envoy says Iran sanctions working, warns against nuclear breaches.” Reuters, June 27, 2019. 94 “Iran says pandemic will not force talks with the US.” Al Monitor, April 20, 2020. 95 Worldwide Threat Assessment of the U.S. Intelligence Community, January 29, 2019. Congressional Research Service 50 Iran Sanctions Trump Administration officials cited Hezbollah’s financial difficulties as evidence that its cited Hezbollah’s financial difficulties as evidence that its
“maximum pressure” campaign on Iran “maximum pressure” campaign on Iran ~~is harming~~harmed Iran’s abilities to project power in the region. Iran’s abilities to project power in the region.9596
The claim The claim ~~references~~referenced reports since early 2019 that the party reports since early 2019 that the party ~~has~~ had to appeal for donations, cut had to appeal for donations, cut
expenses, request donations, and delay or reduce payments to its fighters.expenses, request donations, and delay or reduce payments to its fighters.9697 In 2020, the In 2020, the
Trump Administration has also attributed the apparent drawdown of pro-Iranian fighters in Syria to the Administration has also attributed the apparent drawdown of pro-Iranian fighters in Syria to the
effect of U.S. sanctions. An alternative explanation is that Iran effect of U.S. sanctions. An alternative explanation is that Iran ~~is adjusting~~adjusted its expenditures to the its expenditures to the
reduced activity on the Syria battlefield, where Hezbollah and other Iran-backed militias have reduced activity on the Syria battlefield, where Hezbollah and other Iran-backed militias have
been fighting on behalf of the Asad regime. been fighting on behalf of the Asad regime.
The The Trump Administration also Administration also ~~has~~ sought to highlight the effect of its policy on Iran’s defense budget. sought to highlight the effect of its policy on Iran’s defense budget.
President Trump stated that Iran’s defense budget had increased 40% during the 2016-2018 time President Trump stated that Iran’s defense budget had increased 40% during the 2016-2018 time
frame of JCPOA implementation.frame of JCPOA implementation.9798 On October 16, 2019, the State Department On October 16, 2019, the State Department ~~Special~~
’s then- Special Representative on Iran, Ambassador Brian Hook, testified before the Senate Foreign Relations Representative on Iran, Ambassador Brian Hook, testified before the Senate Foreign Relations
Committee that Committee that
However, from 2017 to 2018, when our pressure However, from 2017 to 2018, when our pressure went into effect we saw a reduction in went into effect we saw a reduction in
[Iran’s] military spending of nearly 10 percent. Iran’s 2019 budget, which was released in [Iran’s] military spending of nearly 10 percent. Iran’s 2019 budget, which was released in
March, called for even steeper cuts, including a 28 percent cut to their defense budget and March, called for even steeper cuts, including a 28 percent cut to their defense budget and
a 17 percent cut for IRGC funding.a 17 percent cut for IRGC funding.9899
Oversight. A provision of the Iran Nuclear Agreement Review Act (P.L. 114-17) requires that a . A provision of the Iran Nuclear Agreement Review Act (P.L. 114-17) requires that a
semiannual report on Iran’s compliance with the JCPOA include information on any Iranian use semiannual report on Iran’s compliance with the JCPOA include information on any Iranian use
of funds to support acts of terrorism. However, because the United States has ceased of funds to support acts of terrorism. However, because the United States has ceased
implementing the JCPOA, the semi-annual reports apparently are not prepared any more. implementing the JCPOA, the semi-annual reports apparently are not prepared any more.
Iranian Domestic Political Effects
Although no U.S. Administration has publicly asserted that the goal of U.S. sanctions on Iran is to Although no U.S. Administration has publicly asserted that the goal of U.S. sanctions on Iran is to
bring about the change of Iran’s regime, a key question is whether U.S. sanctions might produce bring about the change of Iran’s regime, a key question is whether U.S. sanctions might produce
political change in Iran. In late 2017- early 2018 and in November 2019, unrest broke out over political change in Iran. In late 2017- early 2018 and in November 2019, unrest broke out over
economic conditions and government repression. Still, U.S. sanctions were suspended at the time economic conditions and government repression. Still, U.S. sanctions were suspended at the time
of the unrest in late 2017 and there were few secondary sanctions during the large Green of the unrest in late 2017 and there were few secondary sanctions during the large Green
Movement uprising of 2009-2010, suggesting that the connection between sanctions and Iran Movement uprising of 2009-2010, suggesting that the connection between sanctions and Iran
unrest unrest ~~might be~~is tenuous. Still, some Iranian protesters tenuous. Still, some Iranian protesters ~~complain~~have complained that the country’s money is being that the country’s money is being
spent on regional interventions rather than on the domestic economy. spent on regional interventions rather than on the domestic economy.
Nor have U.S. sanctions necessarily always achieved favorable gradual political change. The Trump Administration’s maximum pressure campaign arguably undermined President Hassan Rouhani—and bolstered Iranian hardliners—by illustrating that negotiations with the United States do not produce better relations with the United States. Hardliners overwhelmingly won Iran’s February 2020 parliamentary elections100 and many of the potentially strong candidates in the June 2021 presidential election apparently are hardliners, to varying degrees. 96
95 Testimony of Ambassador Brian Hook before the Subcommittee on the Middle East, North Africa, and International Testimony of Ambassador Brian Hook before the Subcommittee on the Middle East, North Africa, and International
Terrorism of the House Foreign Affairs Committee, June 19, 2019. Terrorism of the House Foreign Affairs Committee, June 19, 2019.
9697 “Sanctions on Iran are Hitting Hezbollah,” “Sanctions on Iran are Hitting Hezbollah,” Washington Post, May 19, 2019. , May 19, 2019.
9798 Statement from the President on the Reimposition of United States Sanctions with Respect to Iran, August 6, 2018. Statement from the President on the Reimposition of United States Sanctions with Respect to Iran, August 6, 2018.
9899 Testimony of Special Representative Brian Hook. Senate Foreign Relations Committee, October 16, 2019. Testimony of Special Representative Brian Hook. Senate Foreign Relations Committee, October 16, 2019.
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~~Nor have U.S. sanctions necessarily always achieved favorable gradual political change. The~~
~~Trump Administration’s maximum pressure campaign has arguably undermined President Hassan~~
~~Rouhani—and bolstered Iranian hardliners—by illustrating that negotiations with the United~~
~~States do not produce better relations with the United States. Hardliners overwhelmingly won~~
~~Iran’s February 2020 parliamentary elections99 and many of the potentially strong candidates in~~
~~the June 2021 presidential election apparently are hardliners, to varying degrees.~~
100 “Iran’s Hardliners Win Election by Large Margin, Mehr Says.” Bloomberg News, February 23, 2020. Congressional Research Service 51 Iran Sanctions Economic Effects
There is little dispute that U.S. sanctions imposed during 2011-2015, and since 2018, have taken a There is little dispute that U.S. sanctions imposed during 2011-2015, and since 2018, have taken a
substantial toll on Iran’s economy. substantial toll on Iran’s economy.
  GDP and Employment Trends. During 2011-2015, Iran’s economy contracted During 2011-2015, Iran’s economy contracted
approximately 20% over the period, and the unemployment rate rose to about approximately 20% over the period, and the unemployment rate rose to about
20%, but the JCPOA-related sanctions relief enabled Iran to achieve 7% annual 20%, but the JCPOA-related sanctions relief enabled Iran to achieve 7% annual
growth during 2016-2018.growth during 2016-2018.~~100~~101 The IMF reported that Iran’s economy declined by The IMF reported that Iran’s economy declined by
about 8% during March 2019-March 2020, about 8% during March 2019-March 2020, ~~and a further contraction is expected~~
~~during 2020-2021.101 The estimates account for the effects of the COVID-19~~
~~pandemic and of U.S. sanctions~~but the agency’s January 2021 estimate indicated Iran would achieve slight growth (1.5%) in 2021. .
  Oil Exports. During the 2011-2015 sanctions period, Iran’s crude oil sales fell During the 2011-2015 sanctions period, Iran’s crude oil sales fell
from 2.5 mbd in 2011 to about 1.1 mbd by 2014. The JCPOA sanctions relief from 2.5 mbd in 2011 to about 1.1 mbd by 2014. The JCPOA sanctions relief
enabled Iran to increase its oil exports to 2011 levels, but the reimposition of U.S. enabled Iran to increase its oil exports to 2011 levels, but the reimposition of U.S.
sanctions—including termination of the SREs—sanctions—including termination of the SREs—~~has driven~~drove Iran’s oil exports Iran’s oil exports
down significantly. (See oil export chart earlier in this report.) down significantly. (See oil export chart earlier in this report.)
  Banking. Global banks mostly left the Iranian market during 2011-2015 and Global banks mostly left the Iranian market during 2011-2015 and
hesitated to reenter the Iran market hesitated to reenter the Iran market ~~after the 2016 easing of sanctions~~thereafter because of because of
(1) reported concerns that the United States might still sanction their Iran (1) reported concerns that the United States might still sanction their Iran
transactions; (2) a lack of transparency in Iran’s financial sector; (3) lingering transactions; (2) a lack of transparency in Iran’s financial sector; (3) lingering
concerns over past financial penalties for processing Iran-related transactions in concerns over past financial penalties for processing Iran-related transactions in
the United States; and (4) the inability to use dollars in Iran-related transactions. the United States; and (4) the inability to use dollars in Iran-related transactions.
~~Those~~Many banks that reentered the banks that reentered the Iran market after 2016 exited again after the U.S. reimposed~~Iran market exited again or limited their~~
~~transactions with Iran after the U.S. re-imposed~~ sanctions in 2018. sanctions in 2018.
  Accessibility of Hard Currency Assets Held Abroad. During 2011-2016, . During 2011-2016,
sanctions prevented Iran from accessing the hard currency in its accounts abroad sanctions prevented Iran from accessing the hard currency in its accounts abroad
which stood at about $115 billion.102 Iran was able to access the funds during which stood at about $115 billion.102 Iran was able to access the funds during
2016-2018, but Iran’s foreign reserves again became restricted by reimposed 2016-2018, but Iran’s foreign reserves again became restricted by reimposed
U.S. sanctions in 2018. The current total value of Iran’s hard currency assets U.S. sanctions in 2018. The current total value of Iran’s hard currency assets
abroad has been estimated by U.S. officials as about $85 billion, but only about abroad has been estimated by U.S. officials as about $85 billion, but only about
10% of that is accessible due to the U.S.-imposed restrictions.103 10% of that is accessible due to the U.S.-imposed restrictions.103

~~99 “Iran’s Hardliners Win Election by Large Margin, Mehr Says.” Bloomberg News, February 23, 2020.~~
~~100 “Foreign Investors Flock to Iran as U.S. Firms Watch on the Sidelines.” Wall Street Journal, March 27, 2017.~~
~~101 The World Bank. Islamic Republic of Iran economy overview and outlook. May 1, 2020.~~
~~102 CRS conversation with Department of the Treasury officials, July 2015. Of this amount, about $60 billion was due~~
~~to creditors such as China or to repay nonperforming loans to Iranian energy companies working in the Caspian and~~
~~Persian Gulf.~~
~~103 “Iran, Cut Off From Vital Cash Reserves, Faces Deeper Economic Peril, U.S. Says.” Wall Street Journal, December~~
~~3, 2019.~~
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  Currency Decline. During the period of U.S. JCPOA implementation, the market . During the period of U.S. JCPOA implementation, the market
value of the value of the rial was about 35,000 to the dollar. The reimposition of U.S. was about 35,000 to the dollar. The reimposition of U.S.
sanctions in 2018 caused the sanctions in 2018 caused the rial’s value to plummet to 150,000 to the dollar by ’s value to plummet to 150,000 to the dollar by
the November 5, 2018, and, in September 2020, to about 265,000 to the dollar.104the November 5, 2018, and, in September 2020, to about 265,000 to the dollar.104
Expecting a Biden Administration change in Iran policy, the rial value strengthened slightly in early 2021 to about 230,000 to the dollar.105   Inflation. The drop in value of the currency caused inflation to accelerate during The drop in value of the currency caused inflation to accelerate during
2011-2013 to a rate of about 60%—a higher figure than that acknowledged by 2011-2013 to a rate of about 60%—a higher figure than that acknowledged by
Iran’s Central Bank. As sanctions were eased, inflation slowed to the single digits Iran’s Central Bank. As sanctions were eased, inflation slowed to the single digits
by June 2016, meeting the Central Bank’s stated goal. The U.S. exit from the by June 2016, meeting the Central Bank’s stated goal. The U.S. exit from the
101 “Foreign Investors Flock to Iran as U.S. Firms Watch on the Sidelines.” Wall Street Journal, March 27, 2017. 102 CRS conversation with Department of the Treasury officials, July 2015. Of this amount, about $60 billion was due to creditors such as China or to repay nonperforming loans to Iranian energy companies working in the Caspian and Persian Gulf. 103 “Iran, Cut Off From Vital Cash Reserves, Faces Deeper Economic Peril, U.S. Says.” Wall Street Journal, December 3, 2019. 104 “Iran’s rial hits new low against dollar as economy reels.” Reuters, September 15, 2020. 105 Bloomberg News, January 20, 2021. Congressional Research Service 52 Iran Sanctions JCPOA caused inflation to increase to nearly 40%, and the rate was about 45% as of early 2021, according to the Statistical Center of Iran.~~JCPOA caused inflation to increase to nearly 40%, by the end of 2018, but the~~
~~level stabilized as of 2019, according to Iran’s Central Bank governor.105~~
  Industrial/Auto Production and Sales. Iran’s light-medium manufacturing sector Iran’s light-medium manufacturing sector
was expanding prior to 2011, but its dependence on imported parts left the sector was expanding prior to 2011, but its dependence on imported parts left the sector
vulnerable to sanctions and vehicle production fell by about 60% from 2011 to vulnerable to sanctions and vehicle production fell by about 60% from 2011 to
2013. The auto sector, and manufacturing overall, rebounded after sanctions were 2013. The auto sector, and manufacturing overall, rebounded after sanctions were
lifted in 2016, but declined again following the U.S. exit from the JCPOA. lifted in 2016, but declined again following the U.S. exit from the JCPOA.
  U.S.-Iran Trade.106 U.S.-Iran trade remains minimal. In 2015, the last full year U.S.-Iran trade remains minimal. In 2015, the last full year
before JCPOA implementation, the United States sold $281 million in goods to before JCPOA implementation, the United States sold $281 million in goods to
Iran and imported $10 million worth of Iranian products. The slight relaxation of Iran and imported $10 million worth of Iranian products. The slight relaxation of
the U.S. import ban stemming from the JCPOA likely accounted for the the U.S. import ban stemming from the JCPOA likely accounted for the
significant increase in imports in 2016 to $86 million. U.S. exports to Iran spiked significant increase in imports in 2016 to $86 million. U.S. exports to Iran spiked
to $440 million for 2018, primarily from a major increase in U.S. sales of to $440 million for 2018, primarily from a major increase in U.S. sales of
soybeans to Iran that year (about $318 million of that commodity). For 2019, the soybeans to Iran that year (about $318 million of that commodity). For 2019, the
first full year in which all U.S. sanctions were back into effect, U.S. exports to first full year in which all U.S. sanctions were back into effect, U.S. exports to
Iran fell to $73 million and imports from Iran were only about $1.4 million.Iran fell to $73 million and imports from Iran were only about $1.4 million. In 2020, U.S. exports to Iran were about $36 million and imports from Iran were about $4 million.
Iran’s Economic Coping Strategies
Iran has sought to try to mitigate the economic effect of sanctions. Iran has sought to try to mitigate the economic effect of sanctions.
  Export Diversification. Iran has promoted sales of petrochemicals and nonoil . Iran has promoted sales of petrochemicals and nonoil
products, and they constitute a steadily growing percentage of Iran’s revenue.107 products, and they constitute a steadily growing percentage of Iran’s revenue.107
Iran’s March 2020-2021 budget Iran’s March 2020-2021 budget ~~assumes that Iran will earn minimal oil revenues.~~
assumed almost no oil revenue.   Reallocation of Investment Funds and Import Substitution. Sanctions compelled . Sanctions compelled
some Iranian manufacturers to increase domestic production of some goods as some Iranian manufacturers to increase domestic production of some goods as
substitutes for imports. Supreme Leader Khamene’i publicly supports building a substitutes for imports. Supreme Leader Khamene’i publicly supports building a
“resistance economy” that is less dependent on imports and foreign investment. “resistance economy” that is less dependent on imports and foreign investment.
  IRGC in the Economy/Privatization. Since 2010, portions of Iran’s state-owned . Since 2010, portions of Iran’s state-owned
enterprises have been transferred to the control of quasi-governmental entities, enterprises have been transferred to the control of quasi-governmental entities,
including cleric-run foundations (including cleric-run foundations (bonyads), holding companies, or investment ), holding companies, or investment
groups. The IRGC’s corporate affiliates are assessed by some experts as groups. The IRGC’s corporate affiliates are assessed by some experts as
controlling at least 20% of Iran’s economy.108 Rouhani has sought to push the controlling at least 20% of Iran’s economy.108 Rouhani has sought to push the
IRGC out of Iran’s economy through divestment, but with limited success. IRGC out of Iran’s economy through divestment, but with limited success.

~~104 “Iran's rial hits new low against dollar as economy reels.” Reuters, September 15, 2020.~~
~~105 Ibid.~~
 Subsidy Reductions. Then-President Ahmadinejad (2005-2013) reduced generous subsidies while temporarily compensating families with cash payments. Gasoline prices were raised to levels similar to those in other regional countries. Rouhani has continued that policy, and he has improved collections of taxes.109 106 Figures in this paragraph is from the U.S Census Bureau. Foreign Trade Statistics database. 106 Figures in this paragraph is from the U.S Census Bureau. Foreign Trade Statistics database.
107 Testimony of Patrick Clawson before the Senate Banking Committee. January 21, 2015. 107 Testimony of Patrick Clawson before the Senate Banking Committee. January 21, 2015.
108 “How Trump’s terrorist designation of Iran’s revolutionary guard impacts its economy.” 108 “How Trump’s terrorist designation of Iran’s revolutionary guard impacts its economy.” CNBC, April 12, 2019. , April 12, 2019.
109 Patrick Clawson testimony, January 21, 2015, op. cit. Congressional Research Service Congressional Research Service
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~~ Subsidy Reductions. Then-President Ahmadinejad (2005-2013) reduced generous~~
~~subsidies while temporarily compensating families with small cash payments.~~
~~Gasoline prices were raised to levels similar to those in other regional countries.~~
~~Rouhani has continued that policy, and he has improved collections of taxes.109~~

Figure 1. Economic Indicators

Sources: IMF 2019, U.S. Energy Information Administration, OPEC. IMF 2019, U.S. Energy Information Administration, OPEC.
Effect on Energy Sector Development
Since 2011, there has been little foreign-led development activity at Iran’s various oil and gas Since 2011, there has been little foreign-led development activity at Iran’s various oil and gas
development sites; many foreign investors have resold their equity stakes to Iranian companies development sites; many foreign investors have resold their equity stakes to Iranian companies
that are less technically capable than international firms. The lifting of sanctions in 2016 that are less technically capable than international firms. The lifting of sanctions in 2016
prompted Iran to try to lure foreign investors back into the sector with more generous investment prompted Iran to try to lure foreign investors back into the sector with more generous investment
terms its “Iran Petroleum Contract.”110 Some new development agreements were signed but, as terms its “Iran Petroleum Contract.”110 Some new development agreements were signed but, as
noted above, major energy firms divested again in response to the U.S. exit from the JCPOA. noted above, major energy firms divested again in response to the U.S. exit from the JCPOA.

~~109 Patrick Clawson testimony, January 21, 2015, op. cit.~~
~~110 Thomas Erdbrink.“New Iran Battle Brews over Foreign Oil Titans.” New York Times, February 1, 2016.~~
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Appendix BAppendix B at the end of this report discusses various Iranian oil and gas fields and the fate of at the end of this report discusses various Iranian oil and gas fields and the fate of
post-1999 investments in them. post-1999 investments in them.
Iran’s development of its gas export sector has been slow. Iran still uses its gas mostly to reinject Iran’s development of its gas export sector has been slow. Iran still uses its gas mostly to reinject
into aging oil fields. However, Iran is exporting natural gas primarily to Turkey and Armenia. into aging oil fields. However, Iran is exporting natural gas primarily to Turkey and Armenia.
Sanctions have slowed Iran’s efforts to develop a liquefied natural gas (LNG) export business. Sanctions have slowed Iran’s efforts to develop a liquefied natural gas (LNG) export business.
With respect to gasoline, several suppliers stopped selling gasoline to Iran after CISADA (see With respect to gasoline, several suppliers stopped selling gasoline to Iran after CISADA (see
above) was enacted. In response, Iran expanded several of its refineries and, in 2017, Iranian above) was enacted. In response, Iran expanded several of its refineries and, in 2017, Iranian
110 Thomas Erdbrink.“New Iran Battle Brews over Foreign Oil Titans.” New York Times, February 1, 2016. Congressional Research Service 54 Iran Sanctions officials said that~~officials said~~ Iran had become self-sufficient in gasoline Iran had become self-sufficient in gasoline. Iran has exported some gasoline to Venezuela, seemingly confirming Iran’s claims of self-sufficiency. .
Human Rights-Related Effects
It is difficult to draw any direct relationship between sanctions and Iran’s human rights practices. It is difficult to draw any direct relationship between sanctions and Iran’s human rights practices.
Human rights reports by the State Department assess that there has been virtually no Human rights reports by the State Department assess that there has been virtually no
improvement in Iran’s practices in recent years.111 improvement in Iran’s practices in recent years.111
Since 2012, foreign firms have generally refrained from selling the Iranian government Since 2012, foreign firms have generally refrained from selling the Iranian government
equipment to monitor or censor social media use. However, the regime retains the ability to equipment to monitor or censor social media use. However, the regime retains the ability to
monitor and censor social media use, and it is also developing a progressively more advanced monitor and censor social media use, and it is also developing a progressively more advanced
cyber capability using indigenously-upgraded technology. cyber capability using indigenously-upgraded technology.
Humanitarian Effects
The COVID-19 pandemic The COVID-19 pandemic ~~has~~ put a spotlight on the extent to which sanctions might be affecting put a spotlight on the extent to which sanctions might be affecting
Iran’s response to the disease—despite the fact that humanitarian items are exempt from U.S. Iran’s response to the disease—despite the fact that humanitarian items are exempt from U.S.
sanctions. During 2012-2016, and since 2018, sanctions reportedly have limited Iran’s ability to sanctions. During 2012-2016, and since 2018, sanctions reportedly have limited Iran’s ability to
import expensive Western-made medicines, such as chemotherapy drugs and medicines for import expensive Western-made medicines, such as chemotherapy drugs and medicines for
multiple sclerosis. 112 multiple sclerosis. 112 ~~Other reports in 2019 indicated that global food traders halted supplying~~
~~Iran because of the absence of trade financing,113or, alternately, their shipments have been held at~~
~~Iranian docks until payments clear.~~ Some of the scarcity of medicines is caused by banks’ refusal Some of the scarcity of medicines is caused by banks’ refusal
to finance such sales, even though doing so is not subject to sanctions. to finance such sales, even though doing so is not subject to sanctions. ~~The State Department has~~
~~issued statements~~In 2020, the State Department asserted that the Iranian government exaggerates reports of the effects of U.S. sanctions that the Iranian government exaggerates reports of the effects of U.S. sanctions
on its medical imports,on its medical imports,~~114~~113 whereas other accounts say that Iranians, particularly those with whereas other accounts say that Iranians, particularly those with
connections to the government, take advantage of shortages by cornering the market for key connections to the government, take advantage of shortages by cornering the market for key
medicines. medicines.
U.S. COVID Response
The Trump Administration The Trump Administration ~~has undertaken~~undertook several steps to assist Iran’s response to the COVID- several steps to assist Iran’s response to the COVID-
19 pandemic and, in the process, perhaps parry calls to broadly ease sanctions on Iran.19 pandemic and, in the process, perhaps parry calls to broadly ease sanctions on Iran.~~115~~114
 In January 2020, before the COVID-19 spread had been acknowledged in Iran,  In January 2020, before the COVID-19 spread had been acknowledged in Iran,
the United States processed the first transactions under a “Swiss humanitarian the United States processed the first transactions under a “Swiss humanitarian
channel” under which U.S. medical equipment can be sold to buyers in Iran that channel” under which U.S. medical equipment can be sold to buyers in Iran that

~~111 Department of State. 2019 Country Reports on Human Rights, Released in 2020.~~
~~112 “Trump’s Sanctions Are Proving a Bitter Pill for Iran’s Sick.” Bloomberg News, November 20, 2018,~~
~~113 “Global Traders Halt New Iran Food Deals as U.S. Sanctions Bite.” Reuters, December 21, 2018.~~
~~114 State Department. Iran’s Sanctions Relief Scam., April 6, 2020.~~
~~115 For further analysis, see CRS Insight IN11279, COVID-19 and U.S. Iran Policy, by Kenneth Katzman.~~
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are determined to be using the items purely for the purposes intended. The are determined to be using the items purely for the purposes intended. The
channel was announced in October 2019, in partnership with Switzerlandchannel was announced in October 2019, in partnership with Switzerland, but has completed few transactions. .
 In February 2020, the Treasury Department clarified that Iran’s Central Bank  In February 2020, the Treasury Department clarified that Iran’s Central Bank
accounts abroad could be used for humanitarian purchases without risk of U.S. accounts abroad could be used for humanitarian purchases without risk of U.S.
sanction, and that donations could go to Iranians from U.S. donors. The steps sanction, and that donations could go to Iranians from U.S. donors. The steps
stopped short of steps taken in previous natural disasters in which the stopped short of steps taken in previous natural disasters in which the
Administration provided a 90 day general license for sales to Iran. Administration provided a 90 day general license for sales to Iran.
 In March 2020, the United States formally offered Iran assistance to help it cope  In March 2020, the United States formally offered Iran assistance to help it cope
with the pandemic. Iran refused the aid. with the pandemic. Iran refused the aid.
111 Department of State. 2020 Country Reports on Human Rights. Released March 2021. 112 “Trump’s Sanctions Are Proving a Bitter Pill for Iran’s Sick.” Bloomberg News, November 20, 2018, 113 State Department. Iran’s Sanctions Relief Scam., April 6, 2020. 114 For further analysis, see CRS Insight IN11279, COVID-19 and U.S. Iran Policy, by Kenneth Katzman. Congressional Research Service 55 Iran Sanctions  On the other hand, as noted, the Trump Administration ~~ On the other hand, as noted, the United States has apparently~~ prevailed on other prevailed on other
members of the IMF executive board to members of the IMF executive board to ~~deny Iran the~~hold up approving Iran’s requested $5 billion loan requested $5 billion loan
for its COVID-19 response. Some Members of Congress have called on the for its COVID-19 response. Some Members of Congress have called on the
Administration to support it.Administration to support it.~~116 The IMF has not announced a loan decision.~~115
Air Safety
In the aviation sector, some Iranian pilots complain publicly that U.S. sanctions caused Iran’s In the aviation sector, some Iranian pilots complain publicly that U.S. sanctions caused Iran’s
passenger airline fleet to deteriorate to the point of jeopardizing safety. Iran’s aviation safety passenger airline fleet to deteriorate to the point of jeopardizing safety. Iran’s aviation safety
record is widely assessed as relatively poor, but it is not clear if any issues were due to difficultly record is widely assessed as relatively poor, but it is not clear if any issues were due to difficultly
in acquiring U.S. spare parts. in acquiring U.S. spare parts.
 In February 2016, Iran Air—which was delisted from U.S. sanctions as of  In February 2016, Iran Air—which was delisted from U.S. sanctions as of
Implementation Day—announced it would purchase 118 Airbus commercial Implementation Day—announced it would purchase 118 Airbus commercial
aircraft at an estimated value of $27 billion. Airbus received an OFAC license aircraft at an estimated value of $27 billion. Airbus received an OFAC license
and three of the aircraft were delivered before the Treasury Department revoked and three of the aircraft were delivered before the Treasury Department revoked
its export licenses for the planes in 2018. its export licenses for the planes in 2018.
 In December 2016, Boeing and Iran Air finalized an agreement for the purchase  In December 2016, Boeing and Iran Air finalized an agreement for the purchase
of 80 passenger aircraft and the leasing of 29 others. Boeing received a specific of 80 passenger aircraft and the leasing of 29 others. Boeing received a specific
license for the transaction, which had an estimated value of $17 billion. None of license for the transaction, which had an estimated value of $17 billion. None of
the aircraft was delivered by the time the export licenses were revoked in 2018. the aircraft was delivered by the time the export licenses were revoked in 2018.
 In April 2017, Iran’s Aseman Airlines signed a tentative agreement to buy at least  In April 2017, Iran’s Aseman Airlines signed a tentative agreement to buy at least
30 Boeing MAX passenger aircraft. No U.S. license for this sale was announced 30 Boeing MAX passenger aircraft. No U.S. license for this sale was announced
prior to the U.S. exit from the JCPOA. The airline is owned by Iran’s civil prior to the U.S. exit from the JCPOA. The airline is owned by Iran’s civil
service pension fund but managed as a private company. service pension fund but managed as a private company.
 In June 2017, Airbus agreed to tentative sales of 45 A320 aircraft to Iran’s  In June 2017, Airbus agreed to tentative sales of 45 A320 aircraft to Iran’s
Airtour Airline, and of 28 A320 and A330 aircraft to Iran’s Zagros Airlines. No Airtour Airline, and of 28 A320 and A330 aircraft to Iran’s Zagros Airlines. No
U.S. license for the sale was announced prior to the U.S. exit from the JCPOA. U.S. license for the sale was announced prior to the U.S. exit from the JCPOA.
 ATR, owned by Airbus and Italy’s Leonardo, sold 20 aircraft to Iran Air. It  ATR, owned by Airbus and Italy’s Leonardo, sold 20 aircraft to Iran Air. It
delivered eight aircraft by the time of the U.S. JCPOA exit and was given delivered eight aircraft by the time of the U.S. JCPOA exit and was given
licenses to deliver another five before U.S. sanctions again took effect. licenses to deliver another five before U.S. sanctions again took effect.
Post-JCPOA Sanctions Legislation
JCPOA oversight and implications have been the subject of legislation. JCPOA oversight and implications have been the subject of legislation.
114th Congress The JCPOA stated that as long as Iran complies with its terms, the sanctions that were suspended or lifted shall not be reimposed on other bases. The Obama Administration asserted that sanctions enacted subsequent to the JCPOA that seek to limit Iran’s military power, its human rights abuses, or its support for militant groups would not violate the JCPOA. 115
~~116~~ Senator Robert Menendez: Menendez & Engel Propose Policies for Addressing COVID-19 in Iran. Press release, Senator Robert Menendez: Menendez & Engel Propose Policies for Addressing COVID-19 in Iran. Press release,
April 3, 2020; Feinstein urges Trump to reverse plan to block Iran request for $5B in IMF aid, claims it is in ‘our April 3, 2020; Feinstein urges Trump to reverse plan to block Iran request for $5B in IMF aid, claims it is in ‘our
national interest’ national interest’ Fox News, April 11, 2020. , April 11, 2020.
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~~114th Congress~~
~~The JCPOA stated that as long as Iran complies with the JCPOA, the sanctions that were~~
~~suspended or lifted shall not be re-imposed on other bases. The Obama Administration asserted~~
~~that some new sanctions that seek to limit Iran’s military power, its human rights abuses, or its~~
~~support for militant groups would not violate the JCPOA.~~
~~Iran Nuclear Agreement Review Act (P.L. 114-17)~~
~~The Iran Nuclear Agreement Review Act of 2015 (INARA, P.L. 114-17) provided for a~~
~~congressional review period after which Congress could pass legislation to disapprove of the~~
~~JCPOA. No such legislation of disapproval was enacted. There are several certification and~~
~~reporting requirements under INARA. The Trump Administration has not made any of the~~
~~required certification reports under the law since ceasing U.S. participation in the JCPOA in May~~
~~2018. It is not clear whether an administration of the presumptive winner of the 2020 election,~~
~~former Vice President Joseph Biden, would resume implementing all provisions of the INARA~~
~~law if it were to accomplish its stated intent to rejoin the JCPOA, or whether negotiated~~
~~modifications to the JCPOA would affect a resumption of INARA implementation.~~
 Material Breach Report~~. INARA required~~Iran Nuclear Agreement Review Act (P.L. 114-17) The Iran Nuclear Agreement Review Act of 2015 (INARA, P.L. 114-17) provided for a congressional review period after which Congress could pass legislation to disapprove of the JCPOA. No such legislation of disapproval was enacted. There are several certification and reporting requirements under INARA. Unless Iran and the United States make significant changes to the JCPOA in the course of negotiating a mutual return to full compliance with its terms, it does not appear that the JCPOA, even with relatively minor modifications, would require another congressional review.  Material Breach Report. INARA requires the Administration to report a the Administration to report a
potentially significant Iranian breach of the agreement within 10 days of potentially significant Iranian breach of the agreement within 10 days of
acquiring credible information of such. Within another 30 days, the President acquiring credible information of such. Within another 30 days, the President
must determine whether this is a material breach and whether Iran has cured it. must determine whether this is a material breach and whether Iran has cured it.
  Certification Report. INARA requires the President to certify, every 90 days, that . INARA requires the President to certify, every 90 days, that
Iran is “transparently, verifiably, and fully implementing” the agreement, and that Iran is “transparently, verifiably, and fully implementing” the agreement, and that
Iran has not taken any action to advance a nuclear weapons program. On October Iran has not taken any action to advance a nuclear weapons program. On October
13, 2017, the Administration declined to make that certification, on the grounds 13, 2017, the Administration declined to make that certification, on the grounds
that continued sanctions relief is not appropriate and proportionate to Iran’s that continued sanctions relief is not appropriate and proportionate to Iran’s
measures to terminate its illicit nuclear program. measures to terminate its illicit nuclear program. ~~No certification reports have~~
~~been issued since the Trump Administration took the United States out of the~~
The Trump Administration did not make any of the required certification reports under the law after ceasing U.S. participation in the JCPOA in May 2018. JCPOA in May 2018.
 If a breach is reported, or if the President does not certify compliance, Congress  If a breach is reported, or if the President does not certify compliance, Congress
may initiate within 60 days “expedited consideration” of legislation that would may initiate within 60 days “expedited consideration” of legislation that would
reimpose any Iran sanctions that the President had suspended. reimpose any Iran sanctions that the President had suspended.
  Semiannual Report. INARA requires an Administration report every 180 days on . INARA requires an Administration report every 180 days on
Iran’s nuclear program, including not only Iran’s compliance with its nuclear Iran’s nuclear program, including not only Iran’s compliance with its nuclear
commitments but also whether Iranian banks are involved in terrorism financing; commitments but also whether Iranian banks are involved in terrorism financing;
Iran’s ballistic missile advances; and whether Iran continued to support terrorism. Iran’s ballistic missile advances; and whether Iran continued to support terrorism.
Visa Restriction
The FY2016 Consolidated Appropriation (P.L. 114-113) contained a provision amending the Visa The FY2016 Consolidated Appropriation (P.L. 114-113) contained a provision amending the Visa
Waiver Program to require a visa to visit the United States for any person who has visited Iraq, Waiver Program to require a visa to visit the United States for any person who has visited Iraq,
Syria, or any terrorism list country (Iran and Syria, or any terrorism list country (Iran and ~~Sudan are the two aside from Syria still listed~~Syria are still listed, as is Cuba) in the ) in the
previous five previous five years. ~~years. The Obama Administration issued a letter to Iran stating it would implement~~
~~the provision in such a way as not to not impinge on sanctions relief, and allowances for Iranian~~
~~students studying in the United States were made in the implementing regulations.~~ Another Another
provision of that law required an Administration report to Congress on how Iran has used the provision of that law required an Administration report to Congress on how Iran has used the
benefits of sanctions relief. benefits of sanctions relief.
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Iran Sanctions Act Extension
The 114th Congress acted to extend ISA before its scheduled expiration on December 31, 2016. The 114th Congress acted to extend ISA before its scheduled expiration on December 31, 2016.
The Iran Sanctions Extension Act (H.R. 6297), which extended ISA until December 31, 2026, The Iran Sanctions Extension Act (H.R. 6297), which extended ISA until December 31, 2026,
without any other changes, passed the House on November 15 by a vote of 419-1 and then passed without any other changes, passed the House on November 15 by a vote of 419-1 and then passed
the Senate by 99-0. President Obama allowed the bill to become law without signing it (P.L. 114-the Senate by 99-0. President Obama allowed the bill to become law without signing it (P.L. 114-
277), even though the Administration said the extension was not necessary. 277), even though the Administration said the extension was not necessary.
Reporting Requirement on Iran Missile Launches
The conference report on the FY2017 National Defense Authorization Act (P.L. 114-328, Section The conference report on the FY2017 National Defense Authorization Act (P.L. 114-328, Section
1226) required quarterly reports to Congress on Iran’s missile launches the imposition of U.S. 1226) required quarterly reports to Congress on Iran’s missile launches the imposition of U.S.
sanctions with respect to Iran’s ballistic missile launches, until December 31, 2019. The sanctions with respect to Iran’s ballistic missile launches, until December 31, 2019. The
Congressional Research Service 57 Iran Sanctions conference report on the FY2018 NDAA (P.L. 115-91) extended the requirement until December conference report on the FY2018 NDAA (P.L. 115-91) extended the requirement until December
31, 2022. The report is to include efforts to sanction entities that assist those missile launches. 31, 2022. The report is to include efforts to sanction entities that assist those missile launches.
Some of the 114th Congress Legislation that was not Enacted
  Sanctions designations: The IRGC Terrorist Designation Act (H.R. 3646/S. 2094) : The IRGC Terrorist Designation Act (H.R. 3646/S. 2094)
required a report on whether the IRGC should be designated a Foreign Terrorist required a report on whether the IRGC should be designated a Foreign Terrorist
Organization (FTO). The Obama Administration argued that the law that set up Organization (FTO). The Obama Administration argued that the law that set up
the FTO designations (Section 219 of the Immigration and Nationality Act [8 the FTO designations (Section 219 of the Immigration and Nationality Act [8
U.S.C. 1189]) applies such designations only to U.S.C. 1189]) applies such designations only to ~~non-state~~nonstate groups. The IRGC groups. The IRGC
Sanctions Act (H.R. 4257) would have required certification that any entity to be Sanctions Act (H.R. 4257) would have required certification that any entity to be
“delisted” from sanctions is not a member, agent, affiliate, or owned by the “delisted” from sanctions is not a member, agent, affiliate, or owned by the
IRGC. The Iran Policy Oversight Act (S. 2119) and the Iran Terror Finance IRGC. The Iran Policy Oversight Act (S. 2119) and the Iran Terror Finance
Transparency Act (H.R. 3662) would have added certification requirements for Transparency Act (H.R. 3662) would have added certification requirements for
the Administration to remove designations of Iranian entities sanctioned. The the Administration to remove designations of Iranian entities sanctioned. The
House passed the latter bill but then vacated its vote. House passed the latter bill but then vacated its vote.
  Financial Transactions: H.R. 4992, which passed the House on July 14, 2016, by
~~a vote of 246-181would require foreign financial institutions to obtain a license~~
~~for dollar transactions with Iran. H.R. 3728 would amend ITRSHRA to make~~
~~mandatory sanctions against electronic payments systems such as SWIFT if they~~
~~were used by Iran.~~
 Proliferation: The Iran Ballistic Missile Sanctions Act of 2016 (S. 2725) would : The Iran Ballistic Missile Sanctions Act of 2016 (S. 2725) would
have required that several major Iranian economic sectors be subject to U.S. have required that several major Iranian economic sectors be subject to U.S.
sanctions, if those sectors were determined to provide support for Iran’s ballistic sanctions, if those sectors were determined to provide support for Iran’s ballistic
missile program. A similar bill, H.R. 5631, passed the House on July 14, 2016, by missile program. A similar bill, H.R. 5631, passed the House on July 14, 2016, by
a vote of 246-179. a vote of 246-179.
 The Justice for Victims of Iranian Terrorism Act (H.R. 3457/S. 2086) prohibited  The Justice for Victims of Iranian Terrorism Act (H.R. 3457/S. 2086) prohibited
the President from waiving U.S. sanctions until Iran completed paying judgments the President from waiving U.S. sanctions until Iran completed paying judgments
issued for victims of Iranian terrorism. The House passed it on October 1, 2015, issued for victims of Iranian terrorism. The House passed it on October 1, 2015,
by a vote of 251-173 despite Obama Administration opposition.by a vote of 251-173 despite Obama Administration opposition.~~117~~116
 Several bills and amendments in the 114th Congress sought to block financing for  Several bills and amendments in the 114th Congress sought to block financing for
the sale of the Boeing aircraft to Iran. H.R. 5715, H.R. 5711, and sections of the the sale of the Boeing aircraft to Iran. H.R. 5715, H.R. 5711, and sections of the
FY2017 Financial Services and General Government Appropriations Act (H.R. FY2017 Financial Services and General Government Appropriations Act (H.R.

~~117 For more information on the issue of judgments for victims of Iranian terrorism, see CRS Report RL31258,~~ ~~Suits~~
~~Against Terrorist States by Victims of Terrorism, by Jennifer K. Elsea.~~
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~~Iran Sanctions~~

5485). H.R. 5711 passed by the House on November 17, 2016, by a vote of 243-5485). H.R. 5711 passed by the House on November 17, 2016, by a vote of 243-
174. The Obama Administration opposed the bills. 174. The Obama Administration opposed the bills.
The Trump Administration and Iran Sanctions Legislation
~~Even before~~Before the Trump Administration withdrew the United States out of the JCPOA, Congress the Trump Administration withdrew the United States out of the JCPOA, Congress
acted on or considered additional Iran sanctions legislation.acted on or considered additional Iran sanctions legislation. ~~The following Iran sanctions~~
~~legislation was enacted or considered in the 115th Congress.~~
The Countering America’s Adversaries through Sanctions Act of 2017
(CAATSA, P.L. 115-44)
AIn the 115th Congress, a Senate bill, S. 722, which initially contained only Iran-related sanctions, was reported out by Senate bill, S. 722, which initially contained only Iran-related sanctions, was reported out by
the Senate Foreign Relations Committee after incorporating sanctions on Russia. It passed the the Senate Foreign Relations Committee after incorporating sanctions on Russia. It passed the
Senate on June 15, 2017, by a vote of 98-2. Subsequently, H.R. 3364, containing not only S.722 Senate on June 15, 2017, by a vote of 98-2. Subsequently, H.R. 3364, containing not only S.722
provisions but also sanctions on North Korea, passed both chambers (P.L. 115-44, August 2, provisions but also sanctions on North Korea, passed both chambers (P.L. 115-44, August 2,
2017). The main provisions of CAATSA, and its implementation, are discussed above. Section 2017). The main provisions of CAATSA, and its implementation, are discussed above. Section
108 requires an Administration review of all designated entities to 108 requires an Administration review of all designated entities to 116 For more information on the issue of judgments for victims of Iranian terrorism, see CRS Report RL31258, Suits Against Terrorist States by Victims of Terrorism, by Jennifer K. Elsea. Congressional Research Service 58 Iran Sanctions assess whether such entities are assess whether such entities are
contributing to Iran’s ballistic missile program or to Iranian support for international terrorism. contributing to Iran’s ballistic missile program or to Iranian support for international terrorism.
Major Legislation in the 115th Congress that was not Enacted
 H.R. 1638  H.R. 1638 and H.R. 4324. In November 2017, the House Financial Services . In November 2017, the House Financial Services Committee ordered Committee ordered
~~reported H.R. 1638,~~reported the bill, entitled the Iranian Leadership Asset Transparency Act, requiring the the Iranian Leadership Asset Transparency Act, requiring the
Treasury Secretary to report to Congress on the assets and equity interests held Treasury Secretary to report to Congress on the assets and equity interests held
by named Iranian persons, including the Supreme Leader. The Committee also by named Iranian persons, including the Supreme Leader. The Committee also
reported H.R. 4324, reported H.R. 4324, ~~Strengthening Oversight of Iran’s Access to Finance Act~~
requiring Administration reports on whether financing of Iranian commercial requiring Administration reports on whether financing of Iranian commercial
aircraft purchases posed money-laundering, proliferation or terrorism risks. aircraft purchases posed money-laundering, proliferation or terrorism risks.
 H.R. 5132. The Iranian Revolutionary Guard Corps Economic Exclusion Act  H.R. 5132. The Iranian Revolutionary Guard Corps Economic Exclusion Act
mandated Administration reports on whether specified categories of entities are mandated Administration reports on whether specified categories of entities are
owned or controlled by the IRGC, or conduct significant transactions with it. The owned or controlled by the IRGC, or conduct significant transactions with it. The
bill defined an entity as owned or controlled by the IRGC even if the IRGC’s bill defined an entity as owned or controlled by the IRGC even if the IRGC’s
ownership interest is less than 50%, and would have required a report on whether ownership interest is less than 50%, and would have required a report on whether
the Iran Airports Company violates E.O. 13224 by facilitating flight operations the Iran Airports Company violates E.O. 13224 by facilitating flight operations
by Mahan Air, which is a designated as a terrorism supporting SDN. by Mahan Air, which is a designated as a terrorism supporting SDN.
 H.R. 4591, S. 3431, and H.R. 4238. Several bills would have codified Executive  H.R. 4591, S. 3431, and H.R. 4238. Several bills would have codified Executive
Order 13438 by requiring the blocking of U.S.-based property and preventing Order 13438 by requiring the blocking of U.S.-based property and preventing
U.S. visas for persons determined to be threatening the stability of Iraq, U.S. visas for persons determined to be threatening the stability of Iraq,
mentioning specifically the Iraqi militia groups As’aib Ahl Al Haq and Harakat mentioning specifically the Iraqi militia groups As’aib Ahl Al Haq and Harakat
Hizballah Al Nujaba. H.R. 4591 passed the House on November 27, 2018. Hizballah Al Nujaba. H.R. 4591 passed the House on November 27, 2018.
116th Congress
Legislation introduced subsequent to the May 2018 U.S. withdrawal from the JCPOA appeared to Legislation introduced subsequent to the May 2018 U.S. withdrawal from the JCPOA appeared to
try to support implementation of the Administration’s maximum pressure try to support implementation of the Administration’s maximum pressure ~~campaign. The~~
~~following pertain to sanctions and not the broader issue of U.S.-Iran military confrontation~~strategy. .
 Several bills would impose sanctions on Iranian proxies in Iraq and elsewhere.  Several bills would impose sanctions on Iranian proxies in Iraq and elsewhere.
These include H.R. 361, the Iranian Proxies Terrorist Sanctions Act of 2019, and These include H.R. 361, the Iranian Proxies Terrorist Sanctions Act of 2019, and
H.R. 571, the Preventing Destabilization of Iraq Act of 2019. H.R. 571, the Preventing Destabilization of Iraq Act of 2019.
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~~Iran Sanctions~~

 The Iranian Revolutionary Guard Corps Exclusion Act (S. 925), similar to H.R.  The Iranian Revolutionary Guard Corps Exclusion Act (S. 925), similar to H.R.
5132 in the 115th Congress (see above) 5132 in the 115th Congress (see above) ~~has been~~was introduced in the Senate. introduced in the Senate.
 The Iran Ballistic Missiles and International Sanctions Enforcement Act (H.R.  The Iran Ballistic Missiles and International Sanctions Enforcement Act (H.R.
2118). The bill 2118). The bill ~~includes~~included provisions similar to H.R. 1698 in the 115th Congress. provisions similar to H.R. 1698 in the 115th Congress.
 The Holding Iranian Leaders Accountable Act of 2020 (H.R. 6081)  The Holding Iranian Leaders Accountable Act of 2020 (H.R. 6081) ~~requires~~required an an
Administration report on the bank holdings of specified Iranian leaders. Administration report on the bank holdings of specified Iranian leaders.
 The Block Iranian Access to U.S. Banks Act of 2020 (H.R. 6243) would  The Block Iranian Access to U.S. Banks Act of 2020 (H.R. 6243) would ~~prohibit~~
~~any U.S. license~~have prohibited U.S. licenses to provide financial services to the government of Iran. to provide financial services to the government of Iran.
Other Possible U.S. and International Sanctions~~118~~117
There are a number of other possible sanctions that might receive consideration—either in a There are a number of other possible sanctions that might receive consideration—either in a
global or multilateral framework. These possibilities are analyzed in CRS In Focus IF10801, global or multilateral framework. These possibilities are analyzed in CRS In Focus IF10801,
Possible Additional Sanctions on Iran, by Kenneth Katzman. , by Kenneth Katzman.

~~118~~117 See CRS In Focus IF10801, See CRS In Focus IF10801, Possible Additional Sanctions on Iran, by Kenneth Katzman. , by Kenneth Katzman.
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Appendix A. U.S., U.N., EU and Allied Country
Sanctions
EU and Other Allied
U.S. Sanctions
U.N. Sanctions
Countries
General Observation: Most Most
As of 2010, U.N. sanctions were As of 2010, U.N. sanctions were
EU closely aligned its sanctions EU closely aligned its sanctions
sweeping sanctions on Iran of sweeping sanctions on Iran of
intended to give countries intended to give countries
tightening with that of the United tightening with that of the United
virtually any country in the world virtually any country in the world
justification to cooperate with U.S. justification to cooperate with U.S.
States. Most EU sanctions lifted in States. Most EU sanctions lifted in
secondary sanctions. secondary sanctions.
accordance with the JCPOA, accordance with the JCPOA,
Post-JCPOA: Resolution 2231 is the Post-JCPOA: Resolution 2231 is the
although some sanctions on arms, although some sanctions on arms,
only operative Resolution on Iran. only operative Resolution on Iran.
dual-use items, and human rights dual-use items, and human rights
remain. remain.
Note: In October 2020, the Trump Note: In October 2020, the Trump
Administration triggered the Administration triggered the
Japan and South Korea sanctions Japan and South Korea sanctions
“snapback” of U.N. sanctions, but “snapback” of U.N. sanctions, but
became extensive but were almost became extensive but were almost
the Security Council and broader the Security Council and broader
entirely lifted in concert with the entirely lifted in concert with the
United Nations does not recognize United Nations does not recognize
JCPOA. JCPOA.
and has not implemented the and has not implemented the
snapback. snapback.
Ban on U.S. Trade with,
U.N. sanctions did not ban civilian U.N. sanctions did not ban civilian
No comprehensive EU ban on No comprehensive EU ban on
Investment in, and Financing
trade with Iran or general civilian trade with Iran or general civilian
trade in civilian goods with Iran trade in civilian goods with Iran
for Iran: Executive Order 12959 Executive Order 12959
sector investment in Iran. sector investment in Iran.
was imposed at any time. was imposed at any time.
and CISAD ban U.S. firms from and CISAD ban U.S. firms from
Japan and South Korea did not ban Japan and South Korea did not ban
exporting to Iran, importing from exporting to Iran, importing from
normal civilian trade with Iran. normal civilian trade with Iran.
Iran, or investing in Iran. Iran, or investing in Iran.
Sanctions on Foreign Firms
No U.N. equivalent. However, No U.N. equivalent. However,
The EU banned almost all dealings The EU banned almost all dealings
that Do Business with Iran’s
Resolution 1929 “not[es] the Resolution 1929 “not[es] the
with Iran’s energy sector after with Iran’s energy sector after
Energy Sector: Several laws and Several laws and
potential connection between Iran’s potential connection between Iran’s
2011. These sanctions now lifted, 2011. These sanctions now lifted,
orders mandate sanctions on orders mandate sanctions on
revenues derived from its energy revenues derived from its energy
but no oil imports from Iran since but no oil imports from Iran since
virtually any type of transaction virtually any type of transaction
sector and the funding of Iran’s sector and the funding of Iran’s
2018. 2018.
with/in Iran’s energy sector. with/in Iran’s energy sector.
proliferation-sensitive nuclear proliferation-sensitive nuclear
Japanese and South Korean Japanese and South Korean
activities.” This is interpreted as activities.” This is interpreted as
measures banned new energy measures banned new energy
providing U.N. support for providing U.N. support for
projects in Iran.. These sanctions projects in Iran.. These sanctions
countries to impose economic countries to impose economic
now lifted, but no Iranian oil being now lifted, but no Iranian oil being
sanctions on Iran. sanctions on Iran.
imported by either. imported by either.
Ban on Foreign Assistance:
No U.N. equivalent No U.N. equivalent
EU measures of July 2010, banned EU measures of July 2010, banned
U.S. foreign assistance to Iran— U.S. foreign assistance to Iran—
grants, aid, and concessional loans grants, aid, and concessional loans
other than purely humanitarian other than purely humanitarian
to Iran, and financing of enterprises to Iran, and financing of enterprises
aid—is banned under §620A of the aid—is banned under §620A of the
involved in Iran’s energy sector. involved in Iran’s energy sector.
Foreign Assistance Act. Iran is also Foreign Assistance Act. Iran is also
These sanctions now lifted. These sanctions now lifted.
routinely denied direct U.S. foreign routinely denied direct U.S. foreign
Japan and South Korea did not ban Japan and South Korea did not ban
aid under the annual foreign aid under the annual foreign
aid or lending to Iran. aid or lending to Iran.
operations appropriations acts. operations appropriations acts.
Ban on Arms Exports to Iran:
As per Resolution 1929 (paragraph As per Resolution 1929 (paragraph
EU policy bans sale to Iran of all EU policy bans sale to Iran of all
Iran is ineligible for U.S. arms Iran is ineligible for U.S. arms
8), as superseded by Resolution 8), as superseded by Resolution
types of military equipment, types of military equipment,
exports under several laws, as exports under several laws, as
2231, Security Council approval is 2231, Security Council approval is
regardless of U.N. resolutions. regardless of U.N. resolutions.
discussed in the report. discussed in the report.
required to sell Iran major weapons required to sell Iran major weapons
Japan and South Korean do not Japan and South Korean do not
systems. systems.
export arms to Iran. export arms to Iran.
U.N. Security Council as a whole U.N. Security Council as a whole
deems ban to have expired as deems ban to have expired as
scheduled on October 18, 2020. scheduled on October 18, 2020.
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EU and Other Allied
U.S. Sanctions
U.N. Sanctions
Countries
Restriction on Exports to Iran
U.N. resolutions on Iran banned the U.N. resolutions on Iran banned the
EU bans the sale to Iran of dual use EU bans the sale to Iran of dual use
of “Dual Use Items”:
export of many dual-use items to export of many dual-use items to
items to Iran, including ballistic items to Iran, including ballistic
Primarily under §6(j) of the Export Primarily under §6(j) of the Export
Iran. Resolution 2231 set up a Iran. Resolution 2231 set up a
missile technology, in line with missile technology, in line with
Administration Act (P.L. 96-72) and Administration Act (P.L. 96-72) and
procurement network for the P5+1 procurement network for the P5+1
U.N. resolutions. U.N. resolutions.
§38 of the Arms Export Control §38 of the Arms Export Control
to approve of all purchases for Iran’s Japan and S. Korea have announced to approve of all purchases for Iran’s Japan and S. Korea have announced
Act, there is a denial of license Act, there is a denial of license
ongoing nuclear program. ongoing nuclear program.
~~ful~~ full adherence to strict export adherence to strict export
applications to sell Iran goods that applications to sell Iran goods that
control regimes. control regimes.
could have military applications. could have military applications.
Sanctions Against Lending to
Resolution 1747 (paragraph 7) Resolution 1747 (paragraph 7)
The July 2010 measures prohibited The July 2010 measures prohibited
Iran:
requested, but did not mandate, that EU members from providing requested, but did not mandate, that EU members from providing
Under §1621 of the International Under §1621 of the International
countries and international financial countries and international financial
grants, aid, and concessional loans grants, aid, and concessional loans
Financial Institutions Act (P.L. 95- Financial Institutions Act (P.L. 95-
institutions refrain from making institutions refrain from making
to Iran, including through to Iran, including through
118), U.S. representatives to 118), U.S. representatives to
grants or loans to Iran, except for grants or loans to Iran, except for
international financial institutions. international financial institutions.
international financial institutions, international financial institutions,
development and humanitarian development and humanitarian
Sanctions lifted post-JCPOA. Sanctions lifted post-JCPOA.
such as the World Bank, are such as the World Bank, are
purposes. purposes.
Japan and South Korea banned Japan and South Korea banned
required to vote against loans to required to vote against loans to

medium- and long-term trade medium- and long-term trade
Iran by those institutions. Iran by those institutions.
No longer applicable No longer applicable
financing and financing guarantees. financing and financing guarantees.
Short-term credit was Short-term credit was ~~stil~~ still allowed. allowed.
These lifted post-JCPOA. These lifted post-JCPOA.
Sanctions Against the Sale of
Resolution 1737 (oper. paragraph Resolution 1737 (oper. paragraph
The EU measures imposed July 27, The EU measures imposed July 27,
Weapons of Mass Destruction-
12) imposed a worldwide freeze on 12) imposed a worldwide freeze on
2010, commit the EU to freezing 2010, commit the EU to freezing
Related Technology to Iran:
the assets and property of Iranian the assets and property of Iranian
the assets of WMD-related entities the assets of WMD-related entities
Several laws and regulations provide WMD-related entities named in an Several laws and regulations provide WMD-related entities named in an
named in the U.N. resolutions, as named in the U.N. resolutions, as
for sanctions against entities, Iranian for sanctions against entities, Iranian
Annex to the resolution. Each Annex to the resolution. Each
well as numerous other named well as numerous other named
or otherwise, that are determined or otherwise, that are determined
subsequent resolution expanded the subsequent resolution expanded the
Iranian entities. Most of these Iranian entities. Most of these
to be involved in or supplying Iran’s to be involved in or supplying Iran’s
list of Iranian entities subject to list of Iranian entities subject to
restrictions remain. restrictions remain.
WMD programs (asset freezing, ban these sanctions. WMD programs (asset freezing, ban these sanctions.
Japan and South Korea froze assets Japan and South Korea froze assets
on transaction with the entity). on transaction with the entity).
of U.N.-sanctioned entities. Most of U.N.-sanctioned entities. Most
of these restrictions have been of these restrictions have been
lifted. lifted.
Ban on Transactions with
No direct equivalent, but Resolution No direct equivalent, but many of No direct equivalent, but Resolution No direct equivalent, but many of
Terrorism Supporting Entities:
1747 (oper. paragraph 5) bans Iran 1747 (oper. paragraph 5) bans Iran
the Iranian entities named as the Iranian entities named as
FTO and E.O 13224 designations FTO and E.O 13224 designations
from exporting any arms. Resolution blocked by the EU, Japan, and from exporting any arms. Resolution blocked by the EU, Japan, and
ban transactions with entities ban transactions with entities
2231 continued that restriction until 2231 continued that restriction until
South Korea overlap or South Korea overlap or
determined by the Administration determined by the Administration
October 18, 2020. October 18, 2020.
complement Iranian entities named complement Iranian entities named
to be supporting terrorism. to be supporting terrorism.
by the United States. by the United States.
Numerous entities, including some Numerous entities, including some

of Iranian origin, have been of Iranian origin, have been
designated. designated.
Human Rights Sanctions:
No U.N. sanctions were imposed on The EU retains a ban on providing No U.N. sanctions were imposed on The EU retains a ban on providing
U.S. laws prohibi travel to the U.S., U.S. laws prohibi travel to the U.S.,
Iran for terrorism or human rights Iran for terrorism or human rights
equipment that can be used for equipment that can be used for
blocking of U.S.-based property, and abuses. blocking of U.S.-based property, and abuses.
internal repression, and has internal repression, and has
ban on transactions with Iranians ban on transactions with Iranians
sanctioned nearly 100 Iranians for sanctioned nearly 100 Iranians for
determined to be involved in determined to be involved in
human rights abuses. human rights abuses.
serious human rights abuses, or serious human rights abuses, or
Japan and South Korea sanction Japan and South Korea sanction
who sell Iran equipment to commit who sell Iran equipment to commit
named Iranians involved in WMD named Iranians involved in WMD
such abuses. such abuses.
programs. programs.
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EU and Other Allied
U.S. Sanctions
U.N. Sanctions
Countries
Restrictions on Iranian
Resolution 1803 and 1929 authorize Resolution 1803 and 1929 authorize
The July 2010 EU measures banned The July 2010 EU measures banned
Shipping:
countries to inspect cargoes carried countries to inspect cargoes carried
Iran Air Cargo from access to EU Iran Air Cargo from access to EU
Under Executive Order 13382, the Under Executive Order 13382, the
by Iran Air and Islamic Republic of by Iran Air and Islamic Republic of
airports and froze the EU-based airports and froze the EU-based
U.S. Department of the Treasury U.S. Department of the Treasury
Iran Shipping Lines (IRISL)—or any Iran Shipping Lines (IRISL)—or any
assets of IRISL and its affiliates. assets of IRISL and its affiliates.
has named Islamic Republic of Iran has named Islamic Republic of Iran
ships in national or international ships in national or international
Insurance and reinsurance for Insurance and reinsurance for
Shipping Lines and several affiliated Shipping Lines and several affiliated
waters—if there is an indication that Iranian firms are banned. These waters—if there is an indication that Iranian firms are banned. These
entities as entities whose U.S.-based the shipments include goods whose entities as entities whose U.S.-based the shipments include goods whose
sanctions were lifted with JCPOA. sanctions were lifted with JCPOA.
property is to be frozen. property is to be frozen.
export to Iran is banned. export to Iran is banned.
Japan and South Korean measures Japan and South Korean measures
These resolutions no longer apply. These resolutions no longer apply.
took similar action against IRISL took similar action against IRISL
and Iran Air. Sanctions now lifted. and Iran Air. Sanctions now lifted.
Banking Sanctions:
No direct equivalent No direct equivalent
The EU froze Iran Central Bank The EU froze Iran Central Bank
Iranian banks have been named as Iranian banks have been named as
However, two Iranian banks were However, two Iranian banks were
assets January 23, 2012, and assets January 23, 2012, and
proliferation or terrorism proliferation or terrorism
named as sanctioned entities under named as sanctioned entities under
banned all transactions with Iranian banned all transactions with Iranian
supporting entities under Executive supporting entities under Executive
the U.N. Security Council the U.N. Security Council
banks unless authorized on banks unless authorized on
Orders 13382 and 13224, and Orders 13382 and 13224, and
resolutions. U.N. restrictions on resolutions. U.N. restrictions on
October 15, 2012. October 15, 2012.
CISADA prohibits banking CISADA prohibits banking
Iranian banking now lifted. Iranian banking now lifted.
Brussels-based SWIFT expelled Brussels-based SWIFT expelled
relationships with U.S. banks for any relationships with U.S. banks for any
sanctioned Iranian banks from the sanctioned Iranian banks from the
foreign bank that conducts foreign bank that conducts
electronic payment transfer electronic payment transfer
transactions with Iran’s transactions with Iran’s
system. This restriction was lifted system. This restriction was lifted
Revolutionary Guard or with Revolutionary Guard or with
but then reimposed when the U.S. but then reimposed when the U.S.
sanctioned Iranian entities. sanctioned Iranian entities.
left the JCPOA. left the JCPOA.
FY2012 Defense Authorization (P.L. FY2012 Defense Authorization (P.L.
South Korea imposed the 40,000 South Korea imposed the 40,000
112-81) prevents U.S. accounts with 112-81) prevents U.S. accounts with
Euro threshhold requiring Euro threshhold requiring
foreign banks that process foreign banks that process
authorization. Japan and S. Korea authorization. Japan and S. Korea
transactions with Iran’s Central transactions with Iran’s Central
froze the assets of Iranian banks. froze the assets of Iranian banks.
Bank (with specified exemptions). Bank (with specified exemptions).
These sanctions lifted with JCPOA. These sanctions lifted with JCPOA.
Ballistic Missiles: U.S. : U.S.
Resolution 2231 “calls on” Iran not Resolution 2231 “calls on” Iran not
EU measures of July 2010 required EU measures of July 2010 required
proliferations laws provide for proliferations laws provide for
to develop or launch ballistic to develop or launch ballistic
adherence to this provision of adherence to this provision of
sanctions against foreign entities sanctions against foreign entities
missiles designed to be capable of missiles designed to be capable of
Resolution 1929. EU has retained Resolution 1929. EU has retained
that help Iran with its nuclear and that help Iran with its nuclear and
carrying a nuclear weapon. Expires carrying a nuclear weapon. Expires
ban on providing ballistic missile ban on providing ballistic missile
ballistic missile programs. ballistic missile programs.
October 18, 2023. October 18, 2023.
technology to Iran in post-JCPOA technology to Iran in post-JCPOA
period. period.

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Appendix B. Post-1999 Major Investments
in Iran’s Energy Sector
Company(ies)/Stat
Output/
Date
Field/Project
us (If Known)
Value
Goal
Feb. 1999 Feb. 1999
Doroud (oil)
Total (France)/ENI Total (France)/ENI
$1 $1 ~~bil ion~~billion
205,000 bpd 205,000 bpd
Total and ENI received “special rule” ISA exemption Total and ENI received “special rule” ISA exemption
(Italy) (Italy)
Apr. 1999 Apr. 1999
Balal (oil)
Total/ Bow Valley Total/ Bow Valley
$300 $300 ~~mil ion~~million
40,000 bpd 40,000 bpd
Dec./May Dec./May
Initial development completed in 2004 Initial development completed in 2004
(Canada)/ENI (Canada)/ENI
2016 2016
Dec. 2016: Thailand PTTEP signed agreement with Dec. 2016: Thailand PTTEP signed agreement with
Thailand PTTEP Thailand PTTEP
NIOC to study further development. NIOC to study further development.

Nov. 1999 Nov. 1999
Soroush and Nowruz (oil)
Royal Dutch Shell Royal Dutch Shell
$800 $800 ~~mil ion~~million
190,000 bpd 190,000 bpd
(Netherlands)/Japex (Netherlands)/Japex
Royal Dutch received special rule ISA exemption Royal Dutch received special rule ISA exemption
(Japan) (Japan)
Apr. 2000 Apr. 2000
Anaran bloc (oil)
Lukoil (Russia) and Lukoil (Russia) and
$105 $105 ~~mil ion~~million
65,000 65,000
Lukoil and Statoil invested in 2000 but abandoned Lukoil and Statoil invested in 2000 but abandoned
Statoil (Norway) Statoil (Norway)
work in 2009. Lukoil considering returning. work in 2009. Lukoil considering returning.
Jul. 2000 Jul. 2000
South Pars Phases 4 and 5 (gas)
ENI ENI
$1.9 $1.9 ~~bil ion~~
~~2 bil ion~~billion 2 billion cu. cu.
On stream in 2005. ENI given special rule exemption On stream in 2005. ENI given special rule exemption
ft./day (cfd) ft./day (cfd)
Mar. 2001 Mar. 2001
Caspian Sea oil exploration—construction of —construction of
GVA Consultants GVA Consultants
$225 $225 ~~mil ion~~million
NA NA
submersible submersible ~~dril ing~~drilling rig for Iranian partner rig for Iranian partner
(Sweden) (Sweden)
Jun. 2001 Jun. 2001
Darkhovin (oil)
ENI ENI
$1 $1 ~~bil ion~~billion
100,000 bpd 100,000 bpd
ENI exited in 2013 and doing so enabled the firm to ENI exited in 2013 and doing so enabled the firm to
Field in production Field in production
be exempted from U.S. sanctions be exempted from U.S. sanctions
May 2002 May 2002
Masjid-e-Soleyman (oil)
Sheer Energy Sheer Energy
$80 $80 ~~mil ion~~million
25,000 bpd 25,000 bpd
(Canada)/CNPC (Canada)/CNPC
(China))/ Naftgaran (China))/ Naftgaran
Engineering (Iran) Engineering (Iran)
Sept. 2002 Sept. 2002
South Pars Phases 9 and 10 (gas)
GS Engineering and GS Engineering and
$1.6 $1.6 ~~bil ion~~
~~2 bil ion~~billion 2 billion cfd cfd
On stream as of early 2009 On stream as of early 2009
Construction Corp. Construction Corp.
(South Korea) (South Korea)
Oct. 2002 Oct. 2002
South Pars Phases 6, 7, and 8
Statoil (Norway) Statoil (Norway)
$750 $750 ~~mil ion~~
~~3 bil ion~~million 3 billion cfd cfd
Field began producing late 2008; operational control Field began producing late 2008; operational control
handed to NIOC in 2009. Statoil got special rule handed to NIOC in 2009. Statoil got special rule
Jan. 2004 Jan. 2004
Azadegan (oil)—South and North
CNPC—N. Azadegan $200 CNPC—N. Azadegan $200 ~~mil ion~~million
260,000 bpd, 260,000 bpd,
Dec. 2016 Dec. 2016
Inpex (Japan) sold stake in 2010 Inpex (Japan) sold stake in 2010

(Inpex stake); (Inpex stake);
of which of which
China $2.5 China $2.5
80,000 is 80,000 is
CNPC (China)—N. Azadegan operator (vice Inpex) CNPC (China)—N. Azadegan operator (vice Inpex)
~~bil ion~~billion
from N. from N.
Royal Dutch Shell/Petronas (Malaysia)—MoU to Royal Dutch Shell/Petronas (Malaysia)—MoU to
Azadegan. Azadegan.
develop S. Azadegan develop S. Azadegan
Jan. 2004 Jan. 2004
Tusan Block
Petrobras (Brazil) Petrobras (Brazil)
$178 $178 ~~mil ion~~million

Oil found in block in Feb. 2009, but not in commercial Oil found in block in Feb. 2009, but not in commercial
quantity, according to the firm. quantity, according to the firm.
Oct. 2004 Oct. 2004
Yadavaran (oil)
Sinopec (China), deal Sinopec (China), deal
$2 $2 ~~bil ion~~billion
300,000 bpd 300,000 bpd
finalized Dec. 9, 2007 finalized Dec. 9, 2007
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Company(ies)/Stat
Output/
Date
Field/Project
us (If Known)
Value
Goal
2005 2005
Saveh bloc (oil)
PTT (Thailand) PTT (Thailand)

GAO report, cited below GAO report, cited below
Jun. 2006 Jun. 2006
Garmsar bloc (oil)
Sinopec (China) Sinopec (China)
$20 $20 ~~mil ion~~million

Deal finalized in June 2009 Deal finalized in June 2009
Jul. 2006 Jul. 2006
Arak Refinery expansion
Sinopec (China); JGC Sinopec (China); JGC
$959 $959 ~~mil ion~~million
Expansion to Expansion to

(Japan). Work (Japan). Work
(major initial (major initial
produce produce
continued by Hyundai expansion) continued by Hyundai expansion)
250,000 bpd 250,000 bpd
Heavy Industries (S. Heavy Industries (S.
Korea) Korea)
Sept. 2006 Sept. 2006
Khorramabad block (oil)
Norsk Hydro and Norsk Hydro and
$49 $49 ~~mil ion~~million
no estimates no estimates
Seismic data gathered, but no production is planned. Seismic data gathered, but no production is planned.
Statoil (Norway). Statoil (Norway).
(Statoil factsheet, May 2011) (Statoil factsheet, May 2011)
Dec. 2006 Dec. 2006
North Pars Gas Field (offshore gas). Includes gas Includes gas
China National China National
$16 $16 ~~bil ion~~billion
3.6 3.6 ~~bil ion~~billion cfd cfd
purchases Work suspended in 2011, resumed 2016, purchases Work suspended in 2011, resumed 2016,
Offshore Oil Co. Offshore Oil Co.
but current status of work unclear. but current status of work unclear.
Feb. 2007 Feb. 2007
LNG Tanks at Tombak Port
Daelim (S. Korea) Daelim (S. Korea)
$320 $320 ~~mil ion~~million
200,000 ton 200,000 ton
Contract to build three LNG tanks at Tombak, 30 Contract to build three LNG tanks at Tombak, 30
capacity capacity
miles north of Assaluyeh Port. miles north of Assaluyeh Port.
Feb. 2007 Feb. 2007
South Pars Phases 13 and 14
Royal Dutch Shell, Royal Dutch Shell,
$4.3 $4.3 ~~bil ion~~billion

Deadline to finalize (May 2009) not met; firms Deadline to finalize (May 2009) not met; firms
Repsol (Spain) Repsol (Spain)
submitted revised proposals to Iran in June 2009. submitted revised proposals to Iran in June 2009.
State Department said in September 2010, that Royal State Department said in September 2010, that Royal
Dutch Shell and Repsol would not pursue the project. Dutch Shell and Repsol would not pursue the project.
Mar. 2007 Mar. 2007
Esfahan refinery upgrade
Daelim (S. Korea) Daelim (S. Korea)

NA NA
Jul. 2007 Jul. 2007
S. Pars Phases 22, 23, and 24
Turkish Petroleum Turkish Petroleum
$12. $12. ~~bil ion~~
~~2 bil ion~~billion 2 billion cfd cfd
Pipeline to transport Iranian gas to Turkey, and on to Pipeline to transport Iranian gas to Turkey, and on to
Company (TPAO) Company (TPAO)
Europe and building three power plants in Iran. Europe and building three power plants in Iran.
Dec. 2007 Dec. 2007
Golshan and Ferdowsi onshore and offshore
Petrofield Subsidiary Petrofield Subsidiary
$15 $15 ~~bil ion~~billion
3.4 3.4 ~~bil ion~~billion cfd cfd
gas and oil fields and LNG plant
of SKS Ventures of SKS Ventures
of of
Contract modified but reaffirmed December 2008 Contract modified but reaffirmed December 2008
(Malaysia) (Malaysia)
gas/250,000 gas/250,000
(GAO reports; Oil Daily, January 14, 2008.) (GAO reports; Oil Daily, January 14, 2008.)
bpd of oil bpd of oil
2007 2007
~~Jofeir Field (oil)~~
Belarusneft (Belarus) Belarusneft (Belarus)
$500 $500 ~~mil ion~~million
40,000 bpd 40,000 bpd
Jofeir Field (oil) under contract to under contract to
GAO report cited below. Belarusneft, a subsidiary of GAO report cited below. Belarusneft, a subsidiary of
Naftiran. Naftiran.
Belneftekhim, sanctioned under ISA on March 29, Belneftekhim, sanctioned under ISA on March 29,
No production to No production to
2011. Naftiran sanctioned on September 29, 2010. 2011. Naftiran sanctioned on September 29, 2010.
date date
2008 2008
Dayyer Bloc (Persian Gulf, offshore, oil)
Edison (Italy) Edison (Italy)
$44 $44 ~~mil ion~~million

GAO reports. GAO reports.
Feb. 2008 Feb. 2008
Lavan field (offshore natural gas)
PGNiG (Polish Oil PGNiG (Polish Oil
$2 $2 ~~bil ion~~billion

and Gas Company, and Gas Company,
Poland), divested to Poland), divested to
Iranian firms in 2011 Iranian firms in 2011
Mar. 2008 Mar. 2008
Danan Field (on-shore oil)
Petro Vietnam Petro Vietnam

“PVEP Wins Bid to Develop Danan Field.” Iran Press “PVEP Wins Bid to Develop Danan Field.” Iran Press
Exploration and Exploration and
TV, March 11, 2008. TV, March 11, 2008.
Production Co. Production Co.
(Vietnam) (Vietnam)
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Company(ies)/Stat
Output/
Date
Field/Project
us (If Known)
Value
Goal
Apr. 2008 Apr. 2008
Iran’s Kish Gas Field
Oman (cofinancing of Oman (cofinancing of
$7 $7 ~~bil ion~~
~~1 bil ion~~billion 1 billion cfd cfd
Includes pipeline from Iran to Oman. Includes pipeline from Iran to Oman.
project) project)
Apr. 2008 Apr. 2008
Moghan 2 (onshore oil and gas, Ardebil
INA (Croatia), but INA (Croatia), but
$40-$140 $40-$140

province)
firm withdrew in firm withdrew in
~~mil ion~~million
2014 2014
2008 2008
Kermanshah petrochemical plant (new
Uhde (Germany) Uhde (Germany)

300,000 300,000
construction)
metric metric
GAO reports. GAO reports.
tons/yr tons/yr
Jun. 2008 Jun. 2008
Resalat Oilfield
Amona (Malaysia). Amona (Malaysia).
$1.5 $1.5 ~~bil ion~~billion
47,000 bpd 47,000 bpd
Status of work unclear. Status of work unclear.
Joined in June 2009 by Joined in June 2009 by
CNOOC and another CNOOC and another
China firm, COSL. China firm, COSL.
Jan. 2009 Jan. 2009
Bushehr Polymer Plants
Sasol (South Africa), Sasol (South Africa),

Capacity is 1 Capacity is 1
Production of polyethelene at two polymer plants in Production of polyethelene at two polymer plants in
but firm withdrew in but firm withdrew in
~~mil ion~~million tons tons
Bushehr Province. Product exported Bushehr Province. Product exported
2014 2014
per year. per year.
Mar. 2009 Mar. 2009
Phase 12 South Pars (gas)—Incl. LNG terminal )—Incl. LNG terminal
Oil and Natural Gas Oil and Natural Gas
$8 $8 ~~bil ion~~billion
20 20 ~~mil ion~~million
construction and Farsi Block gas field/Farzad-B bloc. construction and Farsi Block gas field/Farzad-B bloc.
Corp. of India Corp. of India
tonnes of tonnes of

(ONGC); Oil India (ONGC); Oil India
LNG annually LNG annually
Ltd., India Oil Corp. Ltd., India Oil Corp.
by 2012 by 2012
Iran expelled Indian firms from the field development Iran expelled Indian firms from the field development
Ltd., with Sonanagol Ltd., with Sonanagol
in October 2020 for in October 2020 for ~~non-performance~~nonperformance of contract. of contract.
(Angola) and PDVSA (Angola) and PDVSA
(Venezuela). (Venezuela).
Aug. 2009 Aug. 2009
Abadan refinery
Sinopec Sinopec
Up to $6 Up to $6

Upgrade and expansion; building a new refinery at Upgrade and expansion; building a new refinery at
~~bil ion~~billion if new if new
Hormuz on the Persian Gulf coast. Hormuz on the Persian Gulf coast.
refinery is refinery is
built built
Oct. 2009 Oct. 2009
South Pars Gas Field—Phases 6-8, Gas
G and S Engineering G and S Engineering
$1.4 $1.4 ~~bil ion~~billion

Sweetening Plant
and Construction and Construction
Contract signed but abrogated by S. Korean firm. Contract signed but abrogated by S. Korean firm.
(South Korea) (South Korea)
Nov. 2009 Nov. 2009
South Pars Phase 12—Part 2 and Part 3
Daelim (S. Korea)— Daelim (S. Korea)—
$4 $4 ~~bil ion~~billion ($2 ($2

Part 2; Tecnimont Part 2; Tecnimont
bn each part) bn each part)
(Italy)—Part 3 (Italy)—Part 3
Feb. Feb.
South Pars Phase 11
CNPC (China), with CNPC (China), with
$4.7 $4.7 ~~bil ion~~billion
1.8 1.8 ~~bil ion~~billion cu cu
2010/July 2010/July
Awarded to CNPC in 2010, but in July 2017, Total Awarded to CNPC in 2010, but in July 2017, Total
Iran Petropars Iran Petropars
ft/day ft/day
2017 2017
took over as operator, with CNPC as minority took over as operator, with CNPC as minority
partner (30%). In November 2018, Total exited and partner (30%). In November 2018, Total exited and
CNPC became operator. CNPC exited in Oct 2019. CNPC became operator. CNPC exited in Oct 2019.
2011 2011
Azar Gas Field
Gazprom (Russia) Gazprom (Russia)

Iran later cancelled Gazprom’s contract due to Iran later cancelled Gazprom’s contract due to
Gazprom’s failure to Gazprom’s failure to ~~fulfil~~ fulfill its commitments. its commitments.
Dec. 2011 Dec. 2011
Zagheh Oil Field
Tatneft (Russia) Tatneft (Russia)
$1 $1 ~~bil ion~~billion
55,000 55,000
barrels per barrels per
Preliminary deal signed December 2011 Preliminary deal signed December 2011
day day
Jul. 2016 Jul. 2016
Aban Oil Field
Zarubezhneft (Russia) Zarubezhneft (Russia)

Zarubezhneft signed a MoU to assess the field. Zarubezhneft signed a MoU to assess the field.
Jul. 2016 Jul. 2016
Paydar Garb Oil Field
Zarubezhneft (Russia) Zarubezhneft (Russia)

Zarubezhneft signed a MoU to assess the field. Zarubezhneft signed a MoU to assess the field.
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Company(ies)/Stat
Output/
Date
Field/Project
us (If Known)
Value
Goal
Nov. 2016 Nov. 2016
Parsi and Rag E-Sefid
Schlumberger Schlumberger

Schlumberger signed a MoU to assess the fields. Schlumberger signed a MoU to assess the fields.
(France) (France)
Nov. 2016 Nov. 2016
Sumar Oil Field
PGNiG (Poland) PGNiG (Poland)

PGNiG signed MoU to assess the field for six months. PGNiG signed MoU to assess the field for six months.
Nov. 2016 Nov. 2016
Karanj
Pergas (consortium of Pergas (consortium of

International Pergas Consortium signed a MoU to International Pergas Consortium signed a MoU to
firms from Norway, firms from Norway,
assess this field. assess this field.
Britain, and Iran) Britain, and Iran)
Dec. 2016 Dec. 2016
Changuleh Oil Field
Gazprom (Russia), Gazprom (Russia),

PTTEP (Thailand), and PTTEP (Thailand), and
Companies signed MoU’s to assess field. Companies signed MoU’s to assess field.
DNO (Norway) DNO (Norway)
Dec. 2016 Dec. 2016
Kish Gas Field
Royal Dutch Shell Royal Dutch Shell

Royal Dutch Shell signed MoU to assess the field Royal Dutch Shell signed MoU to assess the field
Dec. 2016 Dec. 2016
Chesmekosh Gas Field
Gazprom (Russia) and Gazprom (Russia) and

Gazprom signed MoU to assess the field Gazprom signed MoU to assess the field
Petronas (Malaysia) Petronas (Malaysia)
Mar. 2017 Mar. 2017
Shadegan Oil Field
Tatneft (Russia) Tatneft (Russia)

500,000 bpd 500,000 bpd
Khuzestan province, producing about 65,000 bpd. Khuzestan province, producing about 65,000 bpd.
max. max.
Sources: Various oil and gas journals, as well as CRS conversations with some U.S. and company officials. Some Various oil and gas journals, as well as CRS conversations with some U.S. and company officials. Some
information comes from various GAO reports, the latest of which was January 13, 2015 (GAO-15-258R). information comes from various GAO reports, the latest of which was January 13, 2015 (GAO-15-258R).
Notes: CRS has no mandate, authority, or means to determine violations of the Iran Sanctions Act, and no way CRS has no mandate, authority, or means to determine violations of the Iran Sanctions Act, and no way
to confirm the status of any of the reported investments. The investments are private agreements between Iran to confirm the status of any of the reported investments. The investments are private agreements between Iran
and the firms involved, which are not required to reveal the terms of their arrangements. Responsibility for a and the firms involved, which are not required to reveal the terms of their arrangements. Responsibility for a
project to develop Iran’s energy sector is part of ISA investment definition. project to develop Iran’s energy sector is part of ISA investment definition.
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Appendix C. Entities Sanctioned Under U.N.
Resolutions and EU Decisions

U.N. Security Council Resolutions
Entities in italics were “delisted” on Implementation Day. Entities in standard font to remain listed until Transition Day Entities in italics were “delisted” on Implementation Day. Entities in standard font to remain listed until Transition Day
(October (October 2023), unless removed earlier by Security Council. Persons listed are identified by the positions they held when 2023), unless removed earlier by Security Council. Persons listed are identified by the positions they held when
designated; some have since changed. designated; some have since changed.
Entities Sanctioned by Resolution 1737 (resolution no longer active)
- Farayand Technique (centrifuge - Farayand Technique (centrifuge
- Gen. Mohammad Mehdi Nejad Mouri - Gen. Mohammad Mehdi Nejad Mouri - Atomic Energy Organization of Iran
program) program)
(Malak Ashtar University of Defense (Malak Ashtar University of Defense
(AEIO)
Technology rector) Technology rector)
- Mesbah Energy Company (Arak
- Defense Industries Organization - Defense Industries Organization
- Bahmanyar Morteza Bahmanyar (AIO - Bahmanyar Morteza Bahmanyar (AIO supplier)
(DIO) (DIO)
official) official)
- Mohammad Qanadi, AEIO Vice
- 7th of Tir (DOI subordinate) - 7th of Tir (DOI subordinate)
- Reza Gholi Esmaeli (AOI official) - Reza Gholi Esmaeli (AOI official)
President
- Shahid Hemmat Industrial Group - Shahid Hemmat Industrial Group
- Ahmad Vahid Dastjerdi (Head of - Ahmad Vahid Dastjerdi (Head of
- Behman Asgarpour (Arak manager)
(SHIG)—missile program (SHIG)—missile program
AOI) AOI)
- Ehsan Monajemi (Natanz manager)
- Shahid Bagheri Industrial Group - Shahid Bagheri Industrial Group
- Maj. Gen. Yahya Rahim Safavi - Maj. Gen. Yahya Rahim Safavi
- Jafar Mohammadi (Adviser to AEIO)
(SBIG)—missile program (SBIG)—missile program
(Commander in Chief, IRGC) (Commander in Chief, IRGC)
- Dawood Agha Jani (Natanz official)
- Fajr Industrial Group—missile - Fajr Industrial Group—missile
- Gen. Hosein Salimi (Commander, - Gen. Hosein Salimi (Commander,
- Ali Hajinia Leilabadi (Director of Mesbah
program program
IRGC Air Force) IRGC Air Force)
Energy)

Entities/Persons Added by Resolution 1747 (resolution no longer active)
- Ammunition and Metallurgy - Ammunition and Metallurgy
- Brig. Gen. Qasem Soleimani (Qods - Brig. Gen. Qasem Soleimani (Qods
- - Karaj Nuclear Research Center
Industries Group (controls 7th of Tir) Industries Group (controls 7th of Tir)
Force commander) Force commander)
- - Novin Energy Company; Cruise Missile ; Cruise Missile
- Parchin Chemical Industries (branch - Parchin Chemical Industries (branch
- Fereidoun Abbasi-Davani (senior - Fereidoun Abbasi-Davani (senior
Industry Group Industry Group
of DIO) of DIO)
defense scientist) defense scientist)
- Kavoshyar Company (subsidiary of (subsidiary of
- Sanam Industrial Group (subordinate - Sanam Industrial Group (subordinate
- Mohasen Fakrizadeh-Mahabai - Mohasen Fakrizadeh-Mahabai
AEIO) AEIO)
to AIO) to AIO)
(defense scientist (defense scientist)
- Bank Sepah and and Bank Sepah
- Ya Mahdi Industries Group - Ya Mahdi Industries Group
- Mohsen Hojati (head of Fajr - Mohsen Hojati (head of Fajr
International PLC (funds AIO and (funds AIO and
- Sho’a Aviation (produces IRGC light - Sho’a Aviation (produces IRGC light
Industrial Group) Industrial Group)
subordinate entities in missile subordinate entities in missile
aircraft for asymmetric warfare) aircraft for asymmetric warfare)
- Ahmad Derakshandeh (head of Bank - Ahmad Derakshandeh (head of Bank
activities) activities) *
- Qods Aeronautics Industries - Qods Aeronautics Industries
Sepah) Sepah)
- Esfahan Nuclear Fuel Research and
(produces UAV’s, para-gliders for (produces UAV’s, para-gliders for
- Brig. Gen. Mohammad Reza Zahedi - Brig. Gen. Mohammad Reza Zahedi
Production Center and Esfahan Nuclear
IRGC asymmetric warfare) IRGC asymmetric warfare)
(IRGC ground forces commander) (IRGC ground forces commander)
Technology Center
- Pars Aviation Services Company - Pars Aviation Services Company
- Naser Maleki (head of SHIG); Brig. - Naser Maleki (head of SHIG); Brig.
- Seyed Jaber Safdari (Natanz manager) (Natanz manager)
(maintains IRGC Air Force equipment) Gen. Morteza Reza’i (Deputy (maintains IRGC Air Force equipment) Gen. Morteza Reza’i (Deputy
- - Amir Rahimi (head of Esfahan nuclear (head of Esfahan nuclear
- Gen. Mohammad Baqr Zolqadr - Gen. Mohammad Baqr Zolqadr
commander-in-chief, IRGC) commander-in-chief, IRGC)
facilities); Mehrdada Akhlaghi facilities); Mehrdada Akhlaghi
(IRGC officer and deputy Interior (IRGC officer and deputy Interior
- Vice Admiral Ali Akbar Ahmadiyan - Vice Admiral Ali Akbar Ahmadiyan
Ketabachi (head of SBIG) Ketabachi (head of SBIG)
Minister) Minister)
(chief of IRGC Joint Staff) (chief of IRGC Joint Staff)
- Brig. Gen. Mohammad Hejazi (Basij - Brig. Gen. Mohammad Hejazi (Basij
commander) commander)
* Bank Sepah and Bank Sepah International were delisted on Implementation Day by a separate decision the Security Council. Bank Sepah and Bank Sepah International were delisted on Implementation Day by a separate decision the Security Council.
They were not named on the Resolution 2231 attachment of entities to be delisted on that day. No information has been They were not named on the Resolution 2231 attachment of entities to be delisted on that day. No information has been
publicized whether Ahmad Derakshandeh, the head of Bank Sepah, was also delisted. publicized whether Ahmad Derakshandeh, the head of Bank Sepah, was also delisted.
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Entities Added by Resolution 1803 (resolution no longer active)
Requires that countries report when the Requires that countries report when the ~~fol owing~~following persons enter or transit their territories: persons enter or transit their territories:
- Amir Moayyed Alai (centrifuge program management) - Amir Moayyed Alai (centrifuge program management)
- M. Javad Karimi Sabet (head of Novin Energy) - M. Javad Karimi Sabet (head of Novin Energy)
- Mohammad Fedai Ashiani (Natanz complex technician) - Mohammad Fedai Ashiani (Natanz complex technician)
- Hamid-Reza Mohajerani (manager at Esfahan uranium - Hamid-Reza Mohajerani (manager at Esfahan uranium
- Abbas Rezaee Ashtiani (senior AEIO official) - Abbas Rezaee Ashtiani (senior AEIO official)
conversion facility) conversion facility)
- Haleh Bakhtiar - Haleh Bakhtiar
- Brig. Gen. Mohammad Reza Naqdi (military official, for - Brig. Gen. Mohammad Reza Naqdi (military official, for
- Morteza Behzad (centrifuge component production) - Morteza Behzad (centrifuge component production)
trying to circumvent U.N. sanctions) trying to circumvent U.N. sanctions)
- Mohammad Eslami (Defense Industries Training and - Mohammad Eslami (Defense Industries Training and
- Houshang Nobari (Natanz) - Houshang Nobari (Natanz)
Research Institute) Research Institute)
- Abbas Rashidi (Natanz) - Abbas Rashidi (Natanz)
- Seyyed Hussein Hosseini (AEIO, involved in Arak) - Seyyed Hussein Hosseini (AEIO, involved in Arak)
- Ghasem Soleymani (Saghand uranium mine) - Ghasem Soleymani (Saghand uranium mine)
Travel banned for five Iranians sanctioned under Resolutions 1737 and 1747. Travel banned for five Iranians sanctioned under Resolutions 1737 and 1747.
Adds entities to the sanctions list: Adds entities to the sanctions list:
- Electro Sanam Co. - Electro Sanam Co.
- Ettehad Technical Group (AIO front co.) - Ettehad Technical Group (AIO front co.)
- Abzar Boresh Kaveh Co. (centrifuge production) - Abzar Boresh Kaveh Co. (centrifuge production)
- Industrial Factories of Precision - Industrial Factories of Precision
- Barzaganin Tejaral Tavanmad Saccal - Barzaganin Tejaral Tavanmad Saccal
- Joza Industrial Co. - Joza Industrial Co.
- Jabber Ibn Hayan (AEIO laboratory) - Jabber Ibn Hayan (AEIO laboratory)
- Pishgam (Pioneer) Energy Industries
- Khorasan Metallurgy Industries - Khorasan Metallurgy Industries
-Tamas Co. (uranium enrichment) -Tamas Co. (uranium enrichment)
- Niru Battery Manufacturing Co. (Makes batteries for - Niru Battery Manufacturing Co. (Makes batteries for
- Safety Equipment Procurement (AIO front, missiles) - Safety Equipment Procurement (AIO front, missiles)
Iranian military and missile systems) Iranian military and missile systems)

Entities Added by Resolution 1929 (resolution no longer active)
Makes mandatory a previously nonbinding travel ban on most named Iranians of previous resolutions. Adds one individual Makes mandatory a previously nonbinding travel ban on most named Iranians of previous resolutions. Adds one individual
banned for travel—AEIO head banned for travel—AEIO head Javad Rahiqi.
- Amin Industrial Complex; Armament - Amin Industrial Complex; Armament
- Malek Ashtar University (subordinate -Shahid Sayyade Shirazi Industries (acts - Malek Ashtar University (subordinate -Shahid Sayyade Shirazi Industries (acts
Industries Group Industries Group
of Defense Technology and Science of Defense Technology and Science
on behalf of the DIO) on behalf of the DIO)
- Defense Technology and Science - Defense Technology and Science
Research Center, above) Research Center, above)
-Special Industries Group (DIO -Special Industries Group (DIO
Research Center (owned or Research Center (owned or
- Ministry of Defense Logistics Export - Ministry of Defense Logistics Export
subordinate) subordinate)
~~control ed~~controlled by Ministry of Defense) by Ministry of Defense)
(sells Iranian made arms to customers (sells Iranian made arms to customers
-Tiz Pars (cover name for SHIG) -Tiz Pars (cover name for SHIG)
- Doostan International Company - Doostan International Company
worldwide) worldwide)
-Yazd Metallurgy Industries -Yazd Metallurgy Industries
- Farasakht Industries - Farasakht Industries
- Mizan Machinery Manufacturing - Mizan Machinery Manufacturing
- Modern Industries Technique - Modern Industries Technique
- - First East Export Bank, PLC
- Pejman Industrial Services Corp.; - Pejman Industrial Services Corp.;
Company Company
- Kaveh Cutting Tools Company - Kaveh Cutting Tools Company
- Sabalan Company; Sahand Aluminum - Sabalan Company; Sahand Aluminum
- Nuclear Research Center for - Nuclear Research Center for
- M. Babaie Industries - M. Babaie Industries
Parts Industrial Company Parts Industrial Company
Agriculture and Medicine (research Agriculture and Medicine (research
-Shahid Karrazi Industries -Shahid Karrazi Industries
- Shahid Sattari Industries - Shahid Sattari Industries
component of the AEIO) component of the AEIO)
The The ~~fol owing~~following IRGC-affiliated firms (several are subsidiaries of Khatam ol-Anbiya, the main Guard construction affiliate): IRGC-affiliated firms (several are subsidiaries of Khatam ol-Anbiya, the main Guard construction affiliate):
- Fater Institute - Fater Institute
- Imensazan Consultant Engineers - Imensazan Consultant Engineers
- Oriental Oil Kish - Oriental Oil Kish
- Garaghe Sazendegi Ghaem - Garaghe Sazendegi Ghaem
Institute Institute
- Rah Sahel - Rah Sahel
- Gorb Karbala - Gorb Karbala
- Khatam ol-Anbiya - Khatam ol-Anbiya
- Rahab Engineering Institute - Rahab Engineering Institute
- Gorb Nooh - Gorb Nooh
- Makin - Makin
- Sahel Consultant Engineers - Sahel Consultant Engineers
- Hara Company - Hara Company
- Omran Sahel - Omran Sahel
- Sepanir - Sepanir
- Sepasad Engineering Company - Sepasad Engineering Company
The The ~~fol owing~~following entities determined to be owned or entities determined to be owned or ~~control ed~~controlled by Islamic Republic of Iran Shipping Lines (IRISL): Irano Hind by Islamic Republic of Iran Shipping Lines (IRISL): Irano Hind
Shipping Company; IRISL Benelux; and South Shipping Line Iran.Shipping Company; IRISL Benelux; and South Shipping Line Iran.

European Union Iran Designations
Terrorism-related
Hamid Hamid ~~Abdol ahi~~Abdollahi
Mansoor Arbabsiar—for alleged plot to assassinate Saudi Ambasador in Washington Mansoor Arbabsiar—for alleged plot to assassinate Saudi Ambasador in Washington
~~Asadol ah~~Asadollah Asadi—for alleged terrorist plot in Europe Asadi—for alleged terrorist plot in Europe
Hashemi Moghadam—for alleged terrorist plot in Europe Hashemi Moghadam—for alleged terrorist plot in Europe
Abdul Reza Shahlai—for alleged plot to assassinate Saudi Ambasador in Washington Abdul Reza Shahlai—for alleged plot to assassinate Saudi Ambasador in Washington
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Gholam Ali Shakuri—for alleged plot to assassinate Saudi Ambasador in Washington Gholam Ali Shakuri—for alleged plot to assassinate Saudi Ambasador in Washington
Qasem Soleimani—IRGC-QF commander Qasem Soleimani—IRGC-QF commander
Directorate for Internal Security of the Iranian Ministry of Intelligence and Security Directorate for Internal Security of the Iranian Ministry of Intelligence and Security
Hamas Hamas
~~Hezbol ah~~Hezbollah Military Wing Military Wing
Palestinian Islamic Jihad Palestinian Islamic Jihad
Human-Rights Related
87 persons, mostly IRGC, Basij, Law Enforcement Forces commanders, as well as security militia chiefs such as Hossein 87 persons, mostly IRGC, Basij, Law Enforcement Forces commanders, as well as security militia chiefs such as Hossein
Allahkaram of Ansar-e-Allahkaram of Ansar-e-~~Hezbol ah~~Hezbollah. List also includes judicial officials such as Seyeed Hassan Shariati (head of Mashhad judiciary); . List also includes judicial officials such as Seyeed Hassan Shariati (head of Mashhad judiciary);
Ghorban Ali Dorri-Najafabadi (former prosecutor-general); officials of Tehran revolutionary court; Supreme Court officials; Ghorban Ali Dorri-Najafabadi (former prosecutor-general); officials of Tehran revolutionary court; Supreme Court officials;
Evin prison officials; province-level prosecutors; and others. Evin prison officials; province-level prosecutors; and others.
The The ~~ful~~ full list is at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02011D0235-20180413&qid=list is at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02011D0235-20180413&qid=
1555351537619&from=EN 1555351537619&from=EN

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Appendix D. Entities Sanctioned under U.S. Laws
and Executive Orders
For every table below, names in For every table below, names in italics are entities and individuals that were delisted to are entities and individuals that were delisted to
implement the JCPOA. Under the JCPOA, entities in implement the JCPOA. Under the JCPOA, entities in boldface were to be delisted on Transition were to be delisted on Transition
Day (October 2023), had the United States remained in the JCPOA. Because of the U.S. Day (October 2023), had the United States remained in the JCPOA. Because of the U.S.
withdrawal from the JCPOA in 2018, all delisted entities were relisted on November 5, 2018. withdrawal from the JCPOA in 2018, all delisted entities were relisted on November 5, 2018.
Table D-1. Entities Designated Under U.S. Executive Order 13382 (Proliferation)
(many designations coincide with EU and (many designations coincide with EU and UNU.N. designations) designations)
Entity
Date Named
Shahid Hemmat Industrial Group (Iran); Shahid Bakeri Industrial Group (Iran); Atomic Energy Shahid Hemmat Industrial Group (Iran); Shahid Bakeri Industrial Group (Iran); Atomic Energy
June 2005 June 2005,
Organization of Iran (AEOI). AEOI and 23 subsidiaries remained delisted for secondary sanctions Organization of Iran (AEOI). AEOI and 23 subsidiaries remained delisted for secondary sanctions
under E.O. 13382 but under E.O. 13382 but ~~stil~~ still designated as Iran-owned or designated as Iran-owned or ~~control ed~~controlled entities. entities.
Novin Energy Company (Iran) and (Iran) and Mesbah Energy Company (Iran) (Iran)
January 2006 January 2006
Four Chinese entities: Beijing Alite Technologies, LIMMT Economic and Trading Company, China Four Chinese entities: Beijing Alite Technologies, LIMMT Economic and Trading Company, China
June 2006 June 2006
Great Wall Industry Corp, and China National Precision Machinery Import/Export Corp. Great Wall Industry Corp, and China National Precision Machinery Import/Export Corp.
Sanam Industrial Group (Iran) and Ya Mahdi Industries Group (Iran) Sanam Industrial Group (Iran) and Ya Mahdi Industries Group (Iran)
July 2006 July 2006
Bank Sepah (Iran)
January 2007 January 2007
Kalaye Electic Company
February 2007 February 2007
Defense Industries Organization (Iran) Defense Industries Organization (Iran)
March 2007 March 2007
Pars Trash (Iran, nuclear program), (Iran, nuclear program), Farayand Technique (Iran, nuclear program), Fajr Industries (Iran, nuclear program), Fajr Industries
June 2007 June 2007
Group (Iran, missile program), Mizan Machine Manufacturing Group (missile program). Group (Iran, missile program), Mizan Machine Manufacturing Group (missile program).
Aerospace Industries Organization (AIO) (Iran); Korea Mining and Development Corp. (N. Korea). Aerospace Industries Organization (AIO) (Iran); Korea Mining and Development Corp. (N. Korea).
September 2007 September 2007
Islamic Revolutionary Guard Corps (IRGC); Ministry of Defense and Armed Forces Logistics; Islamic Revolutionary Guard Corps (IRGC); Ministry of Defense and Armed Forces Logistics; Bank
October 21, 2007 October 21, 2007
Melli (Iran’s largest bank, widely used by Guard); Bank Melli Iran Zao (Moscow); Melli Bank PC (Iran’s largest bank, widely used by Guard); Bank Melli Iran Zao (Moscow); Melli Bank PC
(U.K.); (U.K.); Bank Kargoshaee; ; Arian Bank (joint venture between Melli and Bank Saderat). Based in (joint venture between Melli and Bank Saderat). Based in
Afghanistan; Afghanistan; Bank Mellat (provides bank ing services to Iran’s nuclear sector); (provides bank ing services to Iran’s nuclear sector); Mellat Bank SB CJSC
(Armenia). (Armenia). Persia International Bank PLC (U.K.); Khatam ol Anbiya Gharargah Sazendegi Nooh (main (U.K.); Khatam ol Anbiya Gharargah Sazendegi Nooh (main
IRGC construction arm); Oriental Oil Kish (Iranian oil firm); Ghorb Karbala; Ghorb Nooh IRGC construction arm); Oriental Oil Kish (Iranian oil firm); Ghorb Karbala; Ghorb Nooh
(synonymous with Khatam ol Anbiya); Sepasad Engineering Company (IRGC construction affiliate); (synonymous with Khatam ol Anbiya); Sepasad Engineering Company (IRGC construction affiliate);
Omran Sahel (IRGC construction affiliate); Sahel Consultant Engineering (IRGC affiliate); Hara Omran Sahel (IRGC construction affiliate); Sahel Consultant Engineering (IRGC affiliate); Hara
Company; Gharargahe Sazandegi Ghaem Company; Gharargahe Sazandegi Ghaem
Individuals: Bahmanyar Morteza Bahmanyar (AIO, Iran missile official; Ahmad Vahid Dastjerdi (AIO Individuals: Bahmanyar Morteza Bahmanyar (AIO, Iran missile official; Ahmad Vahid Dastjerdi (AIO
head); Reza Gholi Esmaeli (AIO); Morteza Reza’i (deputy IRGC commander); Mohammad Hejazi head); Reza Gholi Esmaeli (AIO); Morteza Reza’i (deputy IRGC commander); Mohammad Hejazi
(Basij commander); Ali Akbar Ahmadian (Chief of IRGC Joint Staff); Hosein Salimi (IRGC Air Force (Basij commander); Ali Akbar Ahmadian (Chief of IRGC Joint Staff); Hosein Salimi (IRGC Air Force
commander). Resolution 1737; Qasem Soleimani (Qods Force commander). commander). Resolution 1737; Qasem Soleimani (Qods Force commander).
Future Bank (Bahrain-based but allegedly (Bahrain-based but allegedly ~~control ed~~controlled by Bank Melli) by Bank Melli)
March 12, 2008 March 12, 2008
Yahya Rahim Safavi (former IRGC Commander in Chief); Mohsen Fakrizadeh-Mahabadi (senior Yahya Rahim Safavi (former IRGC Commander in Chief); Mohsen Fakrizadeh-Mahabadi (senior
July 8, 2008 July 8, 2008
nuclear scientist); nuclear scientist); Dawood Agha-Jani (head of Natanz facility); Mohsen Hojati (head of Fajr (head of Natanz facility); Mohsen Hojati (head of Fajr
Industries/missile program; Mehrdada Akhlaghi Ketabachi (heads Shahid Bakeri Industrial Group); Industries/missile program; Mehrdada Akhlaghi Ketabachi (heads Shahid Bakeri Industrial Group);
Naser Maliki (heads Shahid Hemmat Industrial Group); Naser Maliki (heads Shahid Hemmat Industrial Group); Tamas Company uranium enrichment); uranium enrichment);
Shahid Sattari Industries; 7th of Tir (centrifuge technology); Ammunition and Metallurgy Industries Shahid Sattari Industries; 7th of Tir (centrifuge technology); Ammunition and Metallurgy Industries
Group (partner of 7th of Tir); Parchin Chemical Industries (chemicals for ballistic missile programs) Group (partner of 7th of Tir); Parchin Chemical Industries (chemicals for ballistic missile programs)
Karaj Nuclear Research Center; Karaj Nuclear Research Center; Esfahan Nuclear Fuel Research and Production Center (NFRPC); (NFRPC); Jabber August 12, 2008 August 12, 2008
Ibn Hayyan (reports to AEIO); Safety Equipment Procurement Company; Joza Industrial Company (reports to AEIO); Safety Equipment Procurement Company; Joza Industrial Company
(front company for SHIG) (front company for SHIG)
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Entity
Date Named
Islamic Republic of Iran Shipping Lines (IRISL) and 18 affiliates, including (IRISL) and 18 affiliates, including Val Fajr 8; ; Kazar; ; Irinvestship; ;
September 10, September 10,
Shipping Computer Services; ; Iran o Misr Shipping; ; Iran o Hind; ; IRISL Marine Services; ; Iriatal Shipping; ;
2008 2008
South Shipping; ; IRISL Multimodal; Oasis; ; Oasis; IRISL Europe; IRISL Benelux; ; IRISL Benelux; IRISL China; ; Asia Marine Network; ;
CISCO Shipping; and ; and IRISL Malta
Firms affiliated to the Ministry of Defense: Armament Industries Group; Farasakht Industries; Iran Firms affiliated to the Ministry of Defense: Armament Industries Group; Farasakht Industries; Iran
September 17, September 17,
Aircraft Manufacturing Industrial Co.; Iran Communications Industries; Iran Electronics Industries; Aircraft Manufacturing Industrial Co.; Iran Communications Industries; Iran Electronics Industries;
2008 2008
and Shiraz Electronics Industries (SEI) and Shiraz Electronics Industries (SEI)
Export Development Bank of Iran (EDBI). Provides financial services to Iran’s Ministry of Defense and (EDBI). Provides financial services to Iran’s Ministry of Defense and
October 22, 2008 October 22, 2008
Armed Forces Logistics; Armed Forces Logistics; Banco Internacional de Desarollo, C.A., Venezuelan-based Iranian bank, , Venezuelan-based Iranian bank,
sanctioned as an affiliate of the Export Development Bank. sanctioned as an affiliate of the Export Development Bank.
Assa Corporation (alleged front for Bank Melli in New York property management, see text) (alleged front for Bank Melli in New York property management, see text)
Dec. 17, 2008 Dec. 17, 2008
11 Bank Melli affiliates: 11 Bank Melli affiliates: Bank Melli Iran Investment (BMIIC); Bank Melli Printing and Publishing; ; Melli
March 3, 2009 March 3, 2009
Investment Holding; g; Mehr Cayman Ltd.; .; Cement Investment and Development; ; Mazandaran Cement Co.; .;
Shomal Cement; ; Mazandaran Textile; ; Melli Agrochemical; ; First Persian Equity Fund; BMIIC Intel General ; BMIIC Intel General
TradingTrading
IRGC General Rostam Qasemi (head of Khatem ol-Anbiya) and several linked entities: Fater IRGC General Rostam Qasemi (head of Khatem ol-Anbiya) and several linked entities: Fater
February 10, February 10,
Engineering Institute, Imensazen Consultant Engineers Institute, Makin Institute, and Rahab Institute Engineering Institute, Imensazen Consultant Engineers Institute, Makin Institute, and Rahab Institute
2010 2010
Mohammad Ali Jafari, IRGC Commander-in-Chief; IRGC Air Force; IRGC Missile Command; Rah Mohammad Ali Jafari, IRGC Commander-in-Chief; IRGC Air Force; IRGC Missile Command; Rah
June 16, 2010 June 16, 2010
Sahel and Sepanir Oil and Gas Engineering (for ties to Khatem ol-Anibya); Mohammad Reza Naqdi Sahel and Sepanir Oil and Gas Engineering (for ties to Khatem ol-Anibya); Mohammad Reza Naqdi
(Head of the IRGC’s Basij militia); Ahmad Vahedi (Defense Minister); (Head of the IRGC’s Basij militia); Ahmad Vahedi (Defense Minister); Javedan Mehr Toos, , Javad
Karimi Sabet (atomic energy procurement brokers) Naval Defense Missile Industry Group (SAIG, (atomic energy procurement brokers) Naval Defense Missile Industry Group (SAIG,
affiliate of Aircraft Industries Org that manages missile programs); affiliate of Aircraft Industries Org that manages missile programs); Post Bank of Iran.
Five IRISL affiliates: Five IRISL affiliates: Hafiz Darya Shipping Co.; .; Soroush Sarzamin Asatir Ship Management Co.; .; Safiran
Payam Darya; and Hong Kong-based ; and Hong Kong-based Seibow Limited and and Seibow Logistics. .
27 vessels linked to IRISKL and 71 new names of already designated IRISL ships. 27 vessels linked to IRISKL and 71 new names of already designated IRISL ships.
Several Iranian entities were also designated as owned or Several Iranian entities were also designated as owned or ~~control ed~~controlled by Iran under E.O. 13599. by Iran under E.O. 13599.
Europaisch-Iranische Handelsbank (EIH) for financial services to Bank Sepah, Mellat, EDBI, and others. Sept. 7, 2010 (EIH) for financial services to Bank Sepah, Mellat, EDBI, and others. Sept. 7, 2010
Pearl Energy Company (formed by First East Export Bank, a subsidiary of Bank Mellat, (formed by First East Export Bank, a subsidiary of Bank Mellat, Pearl Energy
November 30, November 30,
Services, SA, , Ali Afzali (high official of First East Export Bank), IRISL front companies: high official of First East Export Bank), IRISL front companies: Ashtead Shipping, 2010 , 2010
Byfleet Shipping, , Cobham Shipping, Dorking Shipping, , Effingham Shipping, , Farnham Shipping, , Gomshall
Shipping, and , and Horsham Shipping (all located in the Isle of Man).- IRISL and affiliate officials: (all located in the Isle of Man).- IRISL and affiliate officials:
Mohammad Hosein Dajmar, , Gholamhossein Golpavar, , Hassan Jalil Zadeh, and , and Mohammad Haji Pajand. .
Bonyad (foundation) Taavon Sepah, for providing services to the IRGC; Ansar Bank (for providing Bonyad (foundation) Taavon Sepah, for providing services to the IRGC; Ansar Bank (for providing
December 21, December 21,
financial services to the IRGC); Mehr Bank (same justification as above); financial services to the IRGC); Mehr Bank (same justification as above); Moallem Insurance Company 2010 2010
(for providing marine insurance to IRISL, Islamic Republic of Iran Shipping Lines) (for providing marine insurance to IRISL, Islamic Republic of Iran Shipping Lines)
Bank of Industry and Mine (BIM) )
May 17, 2011 May 17, 2011
Tidewater Middle East Company; Iran Air; Mehr-e Eqtesad Iranian Investment Co. Tidewater Middle East Company; Iran Air; Mehr-e Eqtesad Iranian Investment Co.
June 23, 2011 June 23, 2011
For proscribed nuclear activities: By State—Nuclear Reactor Fuels Company; For proscribed nuclear activities: By State—Nuclear Reactor Fuels Company; Noor Afzar Gostar
November 21, November 21,
Company; ; Fulmen Group; ; Yasa Part. By Treasury—. By Treasury—Javad Rahiqi; ; Modern Industries
2011 2011
Technique Company; ; Iran Centrifuge Technology Company (TESA); Neka Novin;
Parto Sanat; ; Paya Partov; ; Simatic Development Co
Iran Maritime Industrial Company SADRA (owned by Khatem-ol-Anbiya, with offices in Venezuela); Iran Maritime Industrial Company SADRA (owned by Khatem-ol-Anbiya, with offices in Venezuela);
March 28, 2012 March 28, 2012
Deep Offshore Technology PJS; Deep Offshore Technology PJS; Malship Shipping Agency and Modality Ltd (Malta-based affiliates of (Malta-based affiliates of
IRISL); IRISL); Seyed Alaeddin Sadat Rasool (IRISL legal adviser); (IRISL legal adviser); Ali Ezati (IRISL) (IRISL)
Electronic Components Industries Co. (ECI) and Information Systems Iran (ISIRAN); Advanced Electronic Components Industries Co. (ECI) and Information Systems Iran (ISIRAN); Advanced
July 12, 2012 July 12, 2012
Information and Communication Technology Center (AICTC) and Hamid Reza Rabiee (AICTC); Information and Communication Technology Center (AICTC) and Hamid Reza Rabiee (AICTC);
Digital Medical Lab (DML) and Value Laboratory; Ministry of Defense Logistics Export (MODLEX); Digital Medical Lab (DML) and Value Laboratory; Ministry of Defense Logistics Export (MODLEX);
Daniel Frosh (Austria) and International General Resourcing FZE (UAE, Iran missile assistance) Daniel Frosh (Austria) and International General Resourcing FZE (UAE, Iran missile assistance)
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Entity
Date Named
National Iranian Oil Company; Tehran Gostaresh, company owned by Bonyad Taavon Sepah; Imam ; Tehran Gostaresh, company owned by Bonyad Taavon Sepah; Imam
November 8, November 8,
Hossein University (IRGC); Hossein University (IRGC); ~~Baghyatol ah~~Baghyatollah Medical Sciences University (services to IRGC) Medical Sciences University (services to IRGC)
2012 2012
Atomic Energy Organization of Iran (AEOI) chief Atomic Energy Organization of Iran (AEOI) chief Fereidoun Abbasi Davani; ; Seyed Jaber Safdari
December 13, December 13,
of Novin Energy (affiliate of AEOI); of Novin Energy (affiliate of AEOI); Morteza Ahmadi Behzad (services to AEOI); (services to AEOI); Pouya Control——
2012 2012
provides goods and services for uranium enrichment; provides goods and services for uranium enrichment; Iran Pooya (centrifuge materials); entrifuge materials); Aria
Nikan Marine Industry (goods for nuclear program); goods for nuclear program); Amir Hossein Rahimyar (procurer for (procurer for
Iran nuclear program); Iran nuclear program); Mohammad Reza Rezvanianzadeh (nuclear program); nuclear program); Faratech (heavy water (heavy water
reactor project); reactor project); Neda Industrial Group (equipment for Natanz facility); (equipment for Natanz facility); Tarh O Palayesh——
(heavy water reactor); (heavy water reactor); Towlid Abzar Boreshi Iran (nuclear program supplier). (nuclear program supplier).
SAD Import Export Company (for shipping arms and other goods to Syria’s armed forces); Marine SAD Import Export Company (for shipping arms and other goods to Syria’s armed forces); Marine
December 21, December 21,
Industries Organization (affiliate of Iran Ministry of Defense and Armed Forces Logistics); Mustafa Industries Organization (affiliate of Iran Ministry of Defense and Armed Forces Logistics); Mustafa
2012 2012
Esbati (acting for Marine Industries); Chemical Industries and Development of Materials Group Esbati (acting for Marine Industries); Chemical Industries and Development of Materials Group
(affiliate of Defense Industries Org); Doostan International Company (provided services to Iran (affiliate of Defense Industries Org); Doostan International Company (provided services to Iran
Aerospace Industries Org, which oversees Iran missile industries). Aerospace Industries Org, which oversees Iran missile industries).
Babak Morteza Zanjani—chairmen of Sorinet Group that finances Iran oil sales abroad; —chairmen of Sorinet Group that finances Iran oil sales abroad; International
April 11, 2013 April 11, 2013
Safe Oil—provides support to NIOC and NICO; —provides support to NIOC and NICO; Sorinet Commercial Trust Bankers (Dubai) and (Dubai) and First
Islamic Investment Bank (Malaysia)—finance NIOC and NICO; (Malaysia)—finance NIOC and NICO; Kont Kosmetik and and Kont Investment
Bank——~~control ed~~controlled by Babak Zanjani; by Babak Zanjani; Naftiran Intertrade Company Ltd. (owned by NIOC). . (owned by NIOC).
Iranian-Venezuelan Bi-National Bank (IVBB), for activities on behalf of the Export Development Bank for activities on behalf of the Export Development Bank
May 9, 2013 May 9, 2013
of Iran that was sanctioned on October 22, 2008 (see above). EDBI was sanctioned for providing of Iran that was sanctioned on October 22, 2008 (see above). EDBI was sanctioned for providing
financial services to Iran’s Ministry of Defense. financial services to Iran’s Ministry of Defense. Aluminat, for providing centrifuge components to , for providing centrifuge components to
Kalaye Electric Co.; Pars Amayesh Sanaat Kish; Kalaye Electric Co.; Pars Amayesh Sanaat Kish; Pishro Systems Research Company (nuclear (nuclear
research and development); research and development); Taghtiran Kashan Company; and Sambouk Shipping FZC (UAE) ; and Sambouk Shipping FZC (UAE)
For supporting Iran Air, the IRGC, and NIOC: For supporting Iran Air, the IRGC, and NIOC: Aban Air; ; Ali Mahdavi (part owner of Aban Air); (part owner of Aban Air); DFS
May 23, 2013 May 23, 2013
Worldwide; ; Everex; Bahareh Mirza Hossein Yazdi; ; Farhad Ali Parvaresh; ; Petro Green; Hossein Vaziri. ; Hossein Vaziri.
For helping Iran’s nuclear program: For helping Iran’s nuclear program: Farhad Bujar; ; Zolal Iran Company; ; Andisheh Zolal Co. .
For helping MODAFL: Reza Mozaffarinia.For helping MODAFL: Reza Mozaffarinia.
Bukovnya AE (Ukraine) for leasing aircraft to Iran Air. (Ukraine) for leasing aircraft to Iran Air.
May 31, 2013 May 31, 2013
Several Iranian firms and persons: Several Iranian firms and persons: Eyvaz Technic Manufacturing Company; The Exploration ; The Exploration
December 12, December 12,
and Nuclear Raw Materials Company; and Nuclear Raw Materials Company; Maro Sanat Company; Navid Composite Material ; Navid Composite Material
2013 2013
Company; Negin Parto Khavar; Neka Novin officials Company; Negin Parto Khavar; Neka Novin officials Iradj Mohammadi Kahvarin and and
Mahmoud Mohammadi Dayeni; Neka Novin alisaes including Kia Nirou; Qods Aviation ; Neka Novin alisaes including Kia Nirou; Qods Aviation
Industries (operated by IRGC, produces UAVs, paragliders, etc); Iran Aviation Industries Industries (operated by IRGC, produces UAVs, paragliders, etc); Iran Aviation Industries
Organization; Reza Amidi; Fan Pardazan; Ertebat Gostar Novin.Organization; Reza Amidi; Fan Pardazan; Ertebat Gostar Novin.
Ali Canko (Turkey) and Tiva Sanat Group, (IRGC-Navy boats); Ali Canko (Turkey) and Tiva Sanat Group, (IRGC-Navy boats); Advance Electrical and
February 6, 2014 February 6, 2014
Industrial Technologies and and Pere Punti (Spain), for nuclear procurement; (Spain), for nuclear procurement; Ulrich Wipperman
and Deutsche Forfait (Germany), and Deutsche Forfait Americas (U.S.) for NIOC oil deals.and Deutsche Forfait (Germany), and Deutsche Forfait Americas (U.S.) for NIOC oil deals.
Eight China-based front companies and Karl Lee (aka Li Fangwei): Sinotech Industry Co. Ltd.; Eight China-based front companies and Karl Lee (aka Li Fangwei): Sinotech Industry Co. Ltd.;
April 29, 2014 April 29, 2014
MTTO Industry and Trade Limited; Success Move Ltd.; Sinotech Dalian Carbon and Graphite MTTO Industry and Trade Limited; Success Move Ltd.; Sinotech Dalian Carbon and Graphite
Manufacturing Corporation; Dalian Zhongchuang Char-White Co., Ltd.; Karat Industry Co., Ltd.; Manufacturing Corporation; Dalian Zhongchuang Char-White Co., Ltd.; Karat Industry Co., Ltd.;
Dalian Zhenghua Maoyi Youxian Gongsi; and Tereal Industry and Trade Ltd.Dalian Zhenghua Maoyi Youxian Gongsi; and Tereal Industry and Trade Ltd.
By State: By State: Organization of Defensive Innovation and Research (nuclear research); Nuclear (nuclear research); Nuclear
April 29, 2014 April 29, 2014
Science and Technology Research Institute (Arak reactor); Science and Technology Research Institute (Arak reactor); Jahan Tech Rooyan Pars: and : and
(by both State (by both State
Mandegar Baspar Kimiya Company (carbon fiber for Iran’s nuclear program). (carbon fiber for Iran’s nuclear program).
and Treasury) and Treasury)
By Treasury: By Treasury: Mohammad Javad Imarad and and Arman Imanirad (aluminum for Iran’s nuclear (aluminum for Iran’s nuclear
programprogram); Nefertiti Shipping (IRISL’s agent in Egypt); Sazeh Morakab (services to SHIG, and Iran’s (IRISL’s agent in Egypt); Sazeh Morakab (services to SHIG, and Iran’s
Aircraft Manufacturing Industrial Co., HESA); Ali Gholami and Marzieh Bozorg (Sazeh Morakab). Aircraft Manufacturing Industrial Co., HESA); Ali Gholami and Marzieh Bozorg (Sazeh Morakab).
SHIG aliases identified: Sahand Aluminum Parts Co and Ardalan Machineries Co.SHIG aliases identified: Sahand Aluminum Parts Co and Ardalan Machineries Co.
11 ballistic missile-related entities: Mabrooka Trading Co LLC (UAE); Hossein : Mabrooka Trading Co LLC (UAE); Hossein
January 17, 2016 January 17, 2016
Pournaghshband; Chen Mingfu; Anhui Land Group (Hong Kong); Candid General Trading; Rahim Pournaghshband; Chen Mingfu; Anhui Land Group (Hong Kong); Candid General Trading; Rahim

Reza Farghadani; Sayyed Javad Musavi; Seyed Mirahmad Nooshin; Sayyed Medhi Farahi (deputy Reza Farghadani; Sayyed Javad Musavi; Seyed Mirahmad Nooshin; Sayyed Medhi Farahi (deputy
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Entity
Date Named
director of MODAFL); Seyed Mohammad Hashemi; Mehrdada Akhlaghi Ketabachi. Musavi has director of MODAFL); Seyed Mohammad Hashemi; Mehrdada Akhlaghi Ketabachi. Musavi has
worked with North Korean officials on ballistic missiles. worked with North Korean officials on ballistic missiles.
Two Iranian entities subordinate to SHIG: Shahid Nuri Industries and Shahid Movahed subordinate to SHIG: Shahid Nuri Industries and Shahid Movahed
March 24, 2016 March 24, 2016
Industries. Updating of prior IRGC Missile Command designation to include IRGC Al Ghadir Missile Industries. Updating of prior IRGC Missile Command designation to include IRGC Al Ghadir Missile
Command (specific IRGC element with operational control of Iran’s missile program). Command (specific IRGC element with operational control of Iran’s missile program).
17 ballistic missile-related Entities. . ~~Abdol ah~~Abdollah Asgharzadeh Network (supporting SHIG): Asgharzadeh Network (supporting SHIG):
February 3, 2017 February 3, 2017
~~Abdol ah~~Abdollah Asgharzadeh; Tenny Darian; East Start Company; Ofog Sabze Company; Richard Yue Asgharzadeh; Tenny Darian; East Start Company; Ofog Sabze Company; Richard Yue

(China); Cosailing Business Trading Company (China); Jack Qin (China); Ningbo New Century (China); Cosailing Business Trading Company (China); Jack Qin (China); Ningbo New Century
Import and Export Co. Ltd (China); and Carol Zhou (China). Gulf-Based Rostamian Network Import and Export Co. Ltd (China); and Carol Zhou (China). Gulf-Based Rostamian Network
(supporting SHIG and AIO): MKS International; Kambiz Rostamian; Royal Pearl General Trading. (supporting SHIG and AIO): MKS International; Kambiz Rostamian; Royal Pearl General Trading.
Iran-Based Network Working with Navid Composite and Mabrooka Trading: Ervin Danesh Aryan Iran-Based Network Working with Navid Composite and Mabrooka Trading: Ervin Danesh Aryan
Company; Mostafa Zahedi; Mohammad Magham. Ghodrat Zargair and Zist Tajhiz Pooyesh Company; Mostafa Zahedi; Mohammad Magham. Ghodrat Zargair and Zist Tajhiz Pooyesh
Company (supporting Mabrooka Trading): Ghodrat Zargari, and Zist Tajhiz Pooyesh Company. Company (supporting Mabrooka Trading): Ghodrat Zargari, and Zist Tajhiz Pooyesh Company.
Ballistic missile-related entities. Rahim Ahmadi (linked to Shahid Bakeri Industrial Group); . Rahim Ahmadi (linked to Shahid Bakeri Industrial Group);
May 17, 2017 May 17, 2017
Morteza Farasatpour (Defense Industries Organization); Matin Sanat Nik Andishan (supporting Morteza Farasatpour (Defense Industries Organization); Matin Sanat Nik Andishan (supporting

SHIG); and Ruan Ruling and three associated Chinese companies (missile guidance): Shanghai Gang SHIG); and Ruan Ruling and three associated Chinese companies (missile guidance): Shanghai Gang
Quan Trade Company, Shanghai North Begins International, and Shanghai North Transway Quan Trade Company, Shanghai North Begins International, and Shanghai North Transway
International Trading Company. International Trading Company.
12 IRGC/military and ballistic missile entities Treasury: Rayan Roshd Afzar Company (IRGC Treasury: Rayan Roshd Afzar Company (IRGC
July 18, 2017 July 18, 2017
drone and censorship equipment); Mohsen Parsajam, Seyyed Reza Ghasemi, and Farshad drone and censorship equipment); Mohsen Parsajam, Seyyed Reza Ghasemi, and Farshad

Hekemzadeh; Qeshm Madkandaloo Cooperative Co., Ramor Group (Turkey) and Resit Tavan of Hekemzadeh; Qeshm Madkandaloo Cooperative Co., Ramor Group (Turkey) and Resit Tavan of
Ramor Group (supplying IRGC-Navy); Emily Liu, Abascience Tech Co. Ltd, Raybeam Optronics Co. Ramor Group (supplying IRGC-Navy); Emily Liu, Abascience Tech Co. Ltd, Raybeam Optronics Co.
Ltd., Raytronic Corporation Ltd., and Sunway Tech Co. Ltd (all China), for supporting MODAFL. Ltd., Raytronic Corporation Ltd., and Sunway Tech Co. Ltd (all China), for supporting MODAFL.
State: IRGC Aerospace Force Self Sufficiency Jihad Org and IRGC Research and Self Sufficiency State: IRGC Aerospace Force Self Sufficiency Jihad Org and IRGC Research and Self Sufficiency
Jihad Org—both for supporting Iran ballistic missile program. Jihad Org—both for supporting Iran ballistic missile program.
Missile entities related to Iran Simorgh space launch: six subordinates to Shahid Hemmat : six subordinates to Shahid Hemmat
July 28, 2017 July 28, 2017
Industrial Group (SHIG): Shaid Karimi Industries; Shahid Rastegar Industries; Shahid Cheraghi Industrial Group (SHIG): Shaid Karimi Industries; Shahid Rastegar Industries; Shahid Cheraghi

Industries; Shahid Varamini Industries; Shahid Kalhor Industries; and Amir Al Mo’Menin Industries. Industries; Shahid Varamini Industries; Shahid Kalhor Industries; and Amir Al Mo’Menin Industries.
Suppliers to Iran’s Naval Defence Missile Industry Group (SAIG): Shahid Alamolhoda Shahid Alamolhoda
October 13, 2017 October 13, 2017
Industries; Rastafann Ertebat Engineering Company, Fanamoj. For supporting Iran’s military: Wuhan Industries; Rastafann Ertebat Engineering Company, Fanamoj. For supporting Iran’s military: Wuhan

Sanjiang Import and Export Company Sanjiang Import and Export Company
Five ballistic missile entities (owned or Five ballistic missile entities (owned or ~~control ed~~controlled by Shahid Bakeri Industrial Group, SBIG) : Shahid by Shahid Bakeri Industrial Group, SBIG) : Shahid
January 4, 2018 January 4, 2018
Kharrazi Industries; Shahid Sanikhani Industries; Shahid Moghaddam Industries; Shahid Eslami Kharrazi Industries; Shahid Sanikhani Industries; Shahid Moghaddam Industries; Shahid Eslami

Research Center; and Shahid Shustari Industries. Research Center; and Shahid Shustari Industries.
Green Wave Telecommunications (Malaysia) and Morteza Razavi (for supporting Fanamoj, Green Wave Telecommunications (Malaysia) and Morteza Razavi (for supporting Fanamoj,
January 12, 2018 January 12, 2018
designated on October 13, 2017); Iran Helicopter Support and Renewal Company (PANHA) and designated on October 13, 2017); Iran Helicopter Support and Renewal Company (PANHA) and
Iran Aircraft Industries (SAHA) (military aviation industry); Shi Yuhua (China) (navigation Iran Aircraft Industries (SAHA) (military aviation industry); Shi Yuhua (China) (navigation
equipment); Pardazan System Namad Arman (PASNA)(for procuring lead zirconium tritanate (PZT) equipment); Pardazan System Namad Arman (PASNA)(for procuring lead zirconium tritanate (PZT)
for Iranian military); and Bochuang Ceramic Inc. and Zhu Yuequn (China) for selling Iran PZT. for Iranian military); and Bochuang Ceramic Inc. and Zhu Yuequn (China) for selling Iran PZT.
Sayyed Mohammad Ali Haddadnezhad Tehrani, for supporting the IRGC Research and Self- Sayyed Mohammad Ali Haddadnezhad Tehrani, for supporting the IRGC Research and Self-
May 22, 2018 May 22, 2018
Sufficiency Jihad Organization to improve Houthi missile capabilities Sufficiency Jihad Organization to improve Houthi missile capabilities
Bank Tejarat (for providing servides to support Bank Sepah); Trade Capital Bank (Belarus); Morteza Nov. 5, 2018 Bank Tejarat (for providing servides to support Bank Sepah); Trade Capital Bank (Belarus); Morteza Nov. 5, 2018
Ahmadali Behzad (for acting on behalf of Pishro Company. Ahmadali Behzad (for acting on behalf of Pishro Company.
31 individuals/entities connected to Iran’s Organization of Defense Innovation and
March 22, 2019 March 22, 2019
Research (SPND), Shahid Karimi Group (missiles and explosives); Mohammad Reza Mehdipur, Shahid Karimi Group (missiles and explosives); Mohammad Reza Mehdipur,
Akbar Motallebizadeh, Jalal Emami Gharah Hajjlu, and Sa’id Borji. Shahid Chamran Group (electron Akbar Motallebizadeh, Jalal Emami Gharah Hajjlu, and Sa’id Borji. Shahid Chamran Group (electron
acceleration, pulse power, wave generation); Sayyed Ashgar Hashemitabar. Shahid Fakhar acceleration, pulse power, wave generation); Sayyed Ashgar Hashemitabar. Shahid Fakhar
Moghaddam Group (explosion simulators, neutron monitoring systems): Moghaddam Group (explosion simulators, neutron monitoring systems): ~~Ruhol ah~~Ruhollah Ghaderi Barmi, Ghaderi Barmi,
and Mohammad Javad Safari. Ten entities that research lasers, plasma technology, satellites, and Mohammad Javad Safari. Ten entities that research lasers, plasma technology, satellites,
biotechnology, and other technologies for SPND: Sheikh Baha’i Science and Technology Research biotechnology, and other technologies for SPND: Sheikh Baha’i Science and Technology Research
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Entity
Date Named
Center, Shahid Avini Group, Shahid Baba’i Group, Shahid Movahhed Danesh Group, Abu Reihan Center, Shahid Avini Group, Shahid Baba’i Group, Shahid Movahhed Danesh Group, Abu Reihan
Group, Shahid Kazemi Group, Shahid Shokri Science and Technology Research Group, Heidar Group, Shahid Kazemi Group, Shahid Shokri Science and Technology Research Group, Heidar
Karar Research Group, Shahid Zeinoddin Group, Bu Ali Group, and Sadra Research Center. For Karar Research Group, Shahid Zeinoddin Group, Bu Ali Group, and Sadra Research Center. For
acting on behalf of SPND: Gholam Reza Eta’ati, Mansur Asgari, and Reza Ebrahimi. SPND front acting on behalf of SPND: Gholam Reza Eta’ati, Mansur Asgari, and Reza Ebrahimi. SPND front
companies and officials: Pulse Niru and officials Mohammad Mahdi Da’emi Attaran and Mohsen companies and officials: Pulse Niru and officials Mohammad Mahdi Da’emi Attaran and Mohsen
Shafa’i; Kimiya Pakhsh Shargh and officials Mehdi Masoumian, and Mohammad Hossein Haghighian; Shafa’i; Kimiya Pakhsh Shargh and officials Mehdi Masoumian, and Mohammad Hossein Haghighian;
and Paradise Medical Pioneers Company. and Paradise Medical Pioneers Company.
Petrochemicals Network: Persian Gulf Petrochemical Industries Company (PGPIC), for : Persian Gulf Petrochemical Industries Company (PGPIC), for
June 7, 2019 June 7, 2019
supporting Khatem ol-Anbiya, and 39 PGPIC subsidiaries and agents: Arvand Petrochemical Co.; supporting Khatem ol-Anbiya, and 39 PGPIC subsidiaries and agents: Arvand Petrochemical Co.;
Bandar Imam Abniroo Petrochemical Co (PC).; Bandar Imam Besparan PC; Bandar Imam Bandar Imam Abniroo Petrochemical Co (PC).; Bandar Imam Besparan PC; Bandar Imam
Faravaresh PC; Bandar Imam Kharazmi PC; Bandar Imam Kimiya PC; Bandar Imam PC; Bu Al Sina Faravaresh PC; Bandar Imam Kharazmi PC; Bandar Imam Kimiya PC; Bandar Imam PC; Bu Al Sina
PC; Fajr PC; Hengam PC; Hormoz Urea Fertilizer Co.; Iranian Investment Petrochemical Group PC; Fajr PC; Hengam PC; Hormoz Urea Fertilizer Co.; Iranian Investment Petrochemical Group
Co.; Karoun PC; Khouzestan PC; Lordegan Urea Fertilizer Co.; Mobin PC; Modabberan Eqtesad Co.; Karoun PC; Khouzestan PC; Lordegan Urea Fertilizer Co.; Mobin PC; Modabberan Eqtesad
Co.; Nouri PC; Pars PC; Pazargad Non Industrial Operation Co.; Persian Gulf Apadana PC; Persian Co.; Nouri PC; Pars PC; Pazargad Non Industrial Operation Co.; Persian Gulf Apadana PC; Persian
Gulf Bid Boland Gas Refinery Co.; Persian Gulf Petrochemical Industry Commercial Co.; Persian Gulf Bid Boland Gas Refinery Co.; Persian Gulf Petrochemical Industry Commercial Co.; Persian
Gulf Fajr Yadavaran Gas Refinery Co.; Petrochemical Industries Development Management Co.; Gulf Fajr Yadavaran Gas Refinery Co.; Petrochemical Industries Development Management Co.;
Rahavaran Fonoon PC; Shaid Tondgoyan PC; Urmia PC; Hemmat PC; Petrochemical Non-Industrial Rahavaran Fonoon PC; Shaid Tondgoyan PC; Urmia PC; Hemmat PC; Petrochemical Non-Industrial
Operations and Services Co.; Ilam PC; Gachsaran Polymer Industries; Dah Dasht Petrochemical Operations and Services Co.; Ilam PC; Gachsaran Polymer Industries; Dah Dasht Petrochemical
Industries; Broojen PC; NPC International (UK); NPC Alliance Corp. (Philippines); Atlas Ocean and Industries; Broojen PC; NPC International (UK); NPC Alliance Corp. (Philippines); Atlas Ocean and
Petrochemical (UAE); and Naghmeh FZE (UAE). Petrochemical (UAE); and Naghmeh FZE (UAE).
Missile Proliferation Entities: Hamid Dehghan, Pishtazan Kavosh Gostar Boshra LLC (PKGB), : Hamid Dehghan, Pishtazan Kavosh Gostar Boshra LLC (PKGB),
August 28, 2019 August 28, 2019
Ebtekar Sanat Ilya, Hadi Dehghan, Shaghayegh Akhaei, Mahdi Ebrahimzadeh, Shafagh Senobar Yazd, Ebtekar Sanat Ilya, Hadi Dehghan, Shaghayegh Akhaei, Mahdi Ebrahimzadeh, Shafagh Senobar Yazd,
and Green Industries (Hong Kong). Also designated: Asre Sanat Eshragh Company and Seyed and Green Industries (Hong Kong). Also designated: Asre Sanat Eshragh Company and Seyed
Hossein Shariat for procuring aluminum alloy for Iran. Hossein Shariat for procuring aluminum alloy for Iran.
Iranian Space Entities: Astronautics Research Institute, Iran Space Agency, Iran Space Research : Astronautics Research Institute, Iran Space Agency, Iran Space Research
September 3, September 3,
Center. Center.
2019 2019
Nuclear managers: Majid Agha’i, managing director of AEOI and Amjad Sazgar—for engaging in Majid Agha’i, managing director of AEOI and Amjad Sazgar—for engaging in
May 27, 2020 May 27, 2020
activities involving uranium enrichment in Iran activities involving uranium enrichment in Iran
Iran Shipping Companies: Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping : Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping
June 8, 2020 June 8, 2020
Company (Shanghai). For transporting items related to Iran’s ballistic missile program. Designations Company (Shanghai). For transporting items related to Iran’s ballistic missile program. Designations
took effect after a 180 day delay to allow Iran to find alternative sources to ship food and medicine. took effect after a 180 day delay to allow Iran to find alternative sources to ship food and medicine.
Entities Affiliated with or Subordinate to Iran’s Atomic Energy Organization (AEIO): September 21, AEIO; affiliates—Nuclear Science and Technology Research Institute (NSTRI); Advanced 2020 Technologies Company of Iran (IATC), Mesbah Energy Company. Missile entities: Mammut Industrial Group (Mammut Industries) and its subsidiary Mammut Diesel. Numerous individuals employed by these entities. For Ilicit Procurement of Electronic Components. Hoda Trading (Iran); Proma Industry Co., Nov 10. 2020 Hoda Trading (Iran); Proma Industry Co., Nov 10. 2020
Ltd. (Hong Kong); DES International Co,Ltd. (Hong Kong); DES International Co, , Ltd. (UAE, Singapore, Taiwan); Mohammad Ltd. (UAE, Singapore, Taiwan); Mohammad
Soltanmohammadi; Naz Technology Co. Ltd (China); Soltech Industry Co. Ltd (Brunei); Shis Mei Soltanmohammadi; Naz Technology Co. Ltd (China); Soltech Industry Co. Ltd (Brunei); Shis Mei
(Amber) Sun; Chin-Hua (Jinee) Huang; Mohammad Banihashemi; Artin San’at Tabaan Company(Amber) Sun; Chin-Hua (Jinee) Huang; Mohammad Banihashemi; Artin San’at Tabaan Company
~~Entities Affiliated with or Subordinate to Iran’s Atomic Energy Organization (AEIO):~~
~~October 8, 2020~~
~~AEIO; affiliates - Nuclear Science and Technology Research Institute (NSTRI); Advanced~~
~~Technologies Company of Iran (IATC), Mesbah Energy Company. Missile entities: Mammut~~
~~Industrial Group (Mammut Industries) and its subsidiary Mammut Diesel. Numerous individuals~~
~~employed by these entities.~~ Shahid Meisami Group and Mehran Babri. For acting on behalf of Iranian Organization of Innovation December 3, and Research (SPND) 2020

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Iran Sanctions

Table D-2. Iran-Related Entities Sanctioned Under Executive Order 13224
(Terrorism Entities)
Entity
Date Named
Martyr’s Foundation (Bonyad Shahid), a major Iranian foundation (bonyad)—for providing financial Martyr’s Foundation (Bonyad Shahid), a major Iranian foundation (bonyad)—for providing financial
July 25, 2007 July 25, 2007
support to support to ~~Hezbol ah~~Hezbollah and PIJ; and PIJ; ~~Goodwil~~ Goodwill Charitable Organization, a Martyr’s Foundation office in Charitable Organization, a Martyr’s Foundation office in
Dearborn, Michigan; Al Qard Al Hassan—part of Dearborn, Michigan; Al Qard Al Hassan—part of ~~Hezbol ah~~Hezbollah’s financial infrastructure (and associated ’s financial infrastructure (and associated
with previously designated with previously designated ~~Hezbol ah~~Hezbollah entities Husayn al-Shami, Bayt al-Mal, and Yousser Company entities Husayn al-Shami, Bayt al-Mal, and Yousser Company
for Finance and Investment); Qasem Aliq—for Finance and Investment); Qasem Aliq—~~Hezbol ah~~Hezbollah official, director of Martyr’s Foundation official, director of Martyr’s Foundation
Lebanon branch, and head of Jihad al-Bina (Lebanese construction company run by Lebanon branch, and head of Jihad al-Bina (Lebanese construction company run by ~~Hezbol ah~~Hezbollah); );
Ahmad al-Shami (liaison between Ahmad al-Shami (liaison between ~~Hezbol ah~~Hezbollah and Martyr’s Foundation chapter in Michigan). and Martyr’s Foundation chapter in Michigan).
IRGC-Qods Force and Bank Saderat (allegedly used to funnel Iranian money to IRGC-Qods Force and Bank Saderat (allegedly used to funnel Iranian money to ~~Hezbol ah~~Hezbollah, Hamas, , Hamas,
October 21, 2007 October 21, 2007
PIJ, and other Iranian supported terrorist groups) PIJ, and other Iranian supported terrorist groups)
Al Qaeda operatives in Iran: Saad bin Laden; Mustafa Hamid; Muhammad Rab’a al-Bahtiyti; Alis Saleh Al Qaeda operatives in Iran: Saad bin Laden; Mustafa Hamid; Muhammad Rab’a al-Bahtiyti; Alis Saleh
January 16, 2009 January 16, 2009
Husain. Husain.
Qods Force senior officers: Hushang Allahdad, Hossein Musavi,Hasan Mortezavi, and Mohammad Qods Force senior officers: Hushang Allahdad, Hossein Musavi,Hasan Mortezavi, and Mohammad
August 3, 2010 August 3, 2010
Reza Zahedi; Iranian Committee for the Reconstruction of Lebanon, and its director Hesam Reza Zahedi; Iranian Committee for the Reconstruction of Lebanon, and its director Hesam
Khoshnevis, for supporting Lebanese Khoshnevis, for supporting Lebanese ~~Hezbol ah~~Hezbollah; Imam Khomeini Relief Committee Lebanon branch, ; Imam Khomeini Relief Committee Lebanon branch,
and its director Ali Zuraik; Razi Musavi, a Syrian based Iranian official supporting and its director Ali Zuraik; Razi Musavi, a Syrian based Iranian official supporting ~~Hezbol ah~~Hezbollah. .
Liner Transport Kish (for providing shipping services to transport weapons to Lebanese Liner Transport Kish (for providing shipping services to transport weapons to Lebanese ~~Hezbol ah~~Hezbollah) )
December 21, 2010 December 21, 2010
Qasem Soleimani (Qods Force commander); Hamid Qasem Soleimani (Qods Force commander); Hamid ~~Abdol ahi~~Abdollahi (Qods force); Abdul Reza Shahlai (Qods force); Abdul Reza Shahlai
October 11, 2011 October 11, 2011
(Qods Force); Ali Gholam Shakuri (Qods Force); Manssor Arbabsiar (alleged plotter) (Qods Force); Ali Gholam Shakuri (Qods Force); Manssor Arbabsiar (alleged plotter)
Mahan Air (for transportation services to Qods Force) Mahan Air (for transportation services to Qods Force)
October 12, 2011 October 12, 2011
Ministry of Intelligence and Security of Iran (MOIS) Ministry of Intelligence and Security of Iran (MOIS)
February 16, 2012 February 16, 2012
Five entities/persons for weapons shipments to Syria and an October 2011 shipment to Gambia, Five entities/persons for weapons shipments to Syria and an October 2011 shipment to Gambia,
March 27, 2012 March 27, 2012
intercepted in Nigeria: Yas Air; Behineh Air (Iranian trading company); Ali Abbas Usman Jega intercepted in Nigeria: Yas Air; Behineh Air (Iranian trading company); Ali Abbas Usman Jega
(Nigeria); Qods Force officers: Esmail Ghani, Sayyid Ali Tabatabaei, and Hosein Aghajani. (Nigeria); Qods Force officers: Esmail Ghani, Sayyid Ali Tabatabaei, and Hosein Aghajani.
Mohammad Minai, senior Qods Force member involved in Iraq; Karim Muhsin al-Ghanimi, leader of Mohammad Minai, senior Qods Force member involved in Iraq; Karim Muhsin al-Ghanimi, leader of
November 8, 2012 November 8, 2012
Kata’ib Kata’ib ~~Hezbol ah~~Hezbollah (KH) militia in Iraq; Sayiid Salah Hantush al-Maksusi, senior KH member; and (KH) militia in Iraq; Sayiid Salah Hantush al-Maksusi, senior KH member; and
Riyad Jasim al-Hamidawi, Iran based KH member. Riyad Jasim al-Hamidawi, Iran based KH member.
Ukraine-Mediterranean Airlines (Um Air, Ukraine) for helping Mahan Air and Iran Air conduct Ukraine-Mediterranean Airlines (Um Air, Ukraine) for helping Mahan Air and Iran Air conduct ~~il icit~~illicit
May 31, 2013 May 31, 2013
activities; Rodrigue Elias Merhej (owner of Um Air); Kyrgyz Trans Avia (KTA, Kyrgyzstan) for activities; Rodrigue Elias Merhej (owner of Um Air); Kyrgyz Trans Avia (KTA, Kyrgyzstan) for
leasing aircraft to Mahan Air; Lidia Kim, director of KTA; Sirjanco (UAE), front for Mahan Air; leasing aircraft to Mahan Air; Lidia Kim, director of KTA; Sirjanco (UAE), front for Mahan Air;
Hamid Arabnejad, managing director of Mahan Air. Hamid Arabnejad, managing director of Mahan Air.
Several persons/entities in UAE aiding Mahan Air (see above): Blue Sky Aviation FZE; Avia Trust Several persons/entities in UAE aiding Mahan Air (see above): Blue Sky Aviation FZE; Avia Trust
February 6, 2014 February 6, 2014
FZE; Hamidreza Malekouti Pour; Pejman Mahmood Kosrayanifard; and Gholamreza Mahmoudi. FZE; Hamidreza Malekouti Pour; Pejman Mahmood Kosrayanifard; and Gholamreza Mahmoudi.
Several IRGC-Qods Force offices in Afghanistan: Sayyed Kamal Musavi; Alireza Hemmati; Akbar Several IRGC-Qods Force offices in Afghanistan: Sayyed Kamal Musavi; Alireza Hemmati; Akbar
Seyed Alhosseini; and Mahmud Afkhami Rashidi. Seyed Alhosseini; and Mahmud Afkhami Rashidi.
Iran-based Al Qaeda facilitator (supporting movement of Al Qaeda affiliated fightes to Syria): Iran-based Al Qaeda facilitator (supporting movement of Al Qaeda affiliated fightes to Syria):
Olimzhon Adkhamovich Sadikov (aka Jafar al-Uzbeki or Jafar Muidinov). Olimzhon Adkhamovich Sadikov (aka Jafar al-Uzbeki or Jafar Muidinov).
Meraj Air (for delivering weapons to Syria); Caspian Air (transporting personnel and weapons to Meraj Air (for delivering weapons to Syria); Caspian Air (transporting personnel and weapons to
August 29, 2014 August 29, 2014
Syria); Sayyed Jabar Hosseini (manager of Liner Transport Kish which IRGC uses); Pioneer Logistics Syria); Sayyed Jabar Hosseini (manager of Liner Transport Kish which IRGC uses); Pioneer Logistics
(Turkey, helps Mahan Air); Asian Aviation Logistics (Thailand, helps Mahan Air). Pouya Air (Turkey, helps Mahan Air); Asian Aviation Logistics (Thailand, helps Mahan Air). Pouya Air
Al Naser Airlines (Iraq) for transferring nine aircraft to Mahan Air, which is a 13224 designee: Issam Al Naser Airlines (Iraq) for transferring nine aircraft to Mahan Air, which is a 13224 designee: Issam
May 21, 2015 May 21, 2015
Shamout, a Syrian businessman, and his company Sky Blue Bird Aviation, for the same transaction. Shamout, a Syrian businessman, and his company Sky Blue Bird Aviation, for the same transaction.
Four U.K.-based and two UAE-based entities for supporting Mahan Air. U.K.: Jeffrey John James Four U.K.-based and two UAE-based entities for supporting Mahan Air. U.K.: Jeffrey John James
March 24, 2016 March 24, 2016
Ashfield; Aviation Capital Solutions; Aircraft, Avionics, Parts and Support Ltd (AAPS); John Edward Ashfield; Aviation Capital Solutions; Aircraft, Avionics, Parts and Support Ltd (AAPS); John Edward
Meadows (for acting on behalf of AAPS). UAE: Grandeur General Trading FZE and HSI Trading FZE. Meadows (for acting on behalf of AAPS). UAE: Grandeur General Trading FZE and HSI Trading FZE.
Eight IRGC-QF and Hezbollah-related entities. Lebanon-Based IRGC-QF Network: Hasan . Lebanon-Based IRGC-QF Network: Hasan
February 3, 2017 February 3, 2017
Dehghan Ebrahimi (IRGC-QF operative in Beirut supporting Dehghan Ebrahimi (IRGC-QF operative in Beirut supporting ~~Hezbol ah~~Hezbollah); Muhammad Abd-al-Amir ); Muhammad Abd-al-Amir
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Iran Sanctions

Entity
Date Named
Farhat; Yahya al-hajj; Maher Trading and Construction Company (laundering funds and smuggling Farhat; Yahya al-hajj; Maher Trading and Construction Company (laundering funds and smuggling
goods to goods to ~~Hezbol ah~~Hezbollah); Reem Phamaceutical; Mirage for Engineering and Trading; Mirage for Waste ); Reem Phamaceutical; Mirage for Engineering and Trading; Mirage for Waste
Management and Environmental Services. Ali Sharifi (procuring spare parts for the IRGC-QF). Management and Environmental Services. Ali Sharifi (procuring spare parts for the IRGC-QF).
Islamic Revolutionary Guard Corps (IRGC) Islamic Revolutionary Guard Corps (IRGC)
October 13, 2017 October 13, 2017
Six entities involved in IRGC-QF counterfeiting: Reza Heidari; Pardazesh Tasvir Rayan Co. (Rayan Six entities involved in IRGC-QF counterfeiting: Reza Heidari; Pardazesh Tasvir Rayan Co. (Rayan
November 20, 2017 November 20, 2017
Printing); ForEnt Technik and Printing Trade Center GmbH (Germany); Mahmoud Seif; Tejarat Printing); ForEnt Technik and Printing Trade Center GmbH (Germany); Mahmoud Seif; Tejarat
Almas Mobin Holding (parent of Rayan Printing). Almas Mobin Holding (parent of Rayan Printing).
Nine individuals and entities, disrupted by U.S.-UAE joint action, attempting to acquire
May 10, 2018 May 10, 2018
dollars in UAE to provide to the IRGC-QF: Individuals: Mas’ud Nikbakht, Sa’id Najafpur, and : Individuals: Mas’ud Nikbakht, Sa’id Najafpur, and
Mohammad Khoda’i (financial activities for IRGC-QF); Mohammadreza Valadzaghard, Meghdad Mohammad Khoda’i (financial activities for IRGC-QF); Mohammadreza Valadzaghard, Meghdad
Amini, and Foad Salehi (Amini, and Foad Salehi (~~il icit~~illicit financial assistance to the IRGC-QF). Entities: Jahan Aras Kish financial assistance to the IRGC-QF). Entities: Jahan Aras Kish
(transferring funds for the IRGC-QF, Rashed Exchange (converting currency for the IRGC-QF), and (transferring funds for the IRGC-QF, Rashed Exchange (converting currency for the IRGC-QF), and
Khedmati and Company Joint Partnership, for being owned by Khedmati and Khoda’i. Khedmati and Company Joint Partnership, for being owned by Khedmati and Khoda’i.
Persons and entities providing IRGC-QF funds to Hezbollah: Central Bank Governor : Central Bank Governor
May 15, 2018 May 15, 2018
~~Valiol ah~~Valiollah Seif; Aras Habib and his Iraq-based Al Bilad Islamic Bank; and Muhammad Qasir Seif; Aras Habib and his Iraq-based Al Bilad Islamic Bank; and Muhammad Qasir
Four persons for helping the Houthi missile program through the IRGC Aerospace Aerospace
May 22, 2018 May 22, 2018
Forces Al Ghadir Missile Command: Mahmud Bagheri Kazemabad; Mohammad Agha Ja’fari; Javad Forces Al Ghadir Missile Command: Mahmud Bagheri Kazemabad; Mohammad Agha Ja’fari; Javad
Bordbar Shir Amin; and Mehdi Azarpisheh (IRGC-QF affiliate) Bordbar Shir Amin; and Mehdi Azarpisheh (IRGC-QF affiliate)
Twenty-one entities linked to the Basij (including Basij firms that fund child soldiers in Syria): including Basij firms that fund child soldiers in Syria):
October 16, 2018 October 16, 2018
Bonyad Taavon Basij (economic conglomerate); Mehr Eqtesad Bank; Bank Mellat; Mehr Eqtesad Bonyad Taavon Basij (economic conglomerate); Mehr Eqtesad Bank; Bank Mellat; Mehr Eqtesad
Iranian Investment Company; Tadbirgaran Atiyeh Investment Company; Negin Sahel Royal Iranian Investment Company; Tadbirgaran Atiyeh Investment Company; Negin Sahel Royal
Company; Mehr Eqtesad Financial Group; Technotar Engineering Company; Iran Tractor Company; Mehr Eqtesad Financial Group; Technotar Engineering Company; Iran Tractor
Manufacturing Company; Taktar Investment Company; Iran’s Zinc Mines Development Company; Manufacturing Company; Taktar Investment Company; Iran’s Zinc Mines Development Company;
Calcimin (owned by Iran Zinc Mines; Bandar Abbas Zinc Production Company; Qeshm Zinc Calcimin (owned by Iran Zinc Mines; Bandar Abbas Zinc Production Company; Qeshm Zinc
Smelting and Reduction Company; Zanjan Acid Production Company; Parsian Catalyst Chemical Smelting and Reduction Company; Zanjan Acid Production Company; Parsian Catalyst Chemical
Company; Esfehan’s Mobarakeh Steel Company (largest in Middle East); Andisheh Mehvaran Company; Esfehan’s Mobarakeh Steel Company (largest in Middle East); Andisheh Mehvaran
Investment Company; Parsian Bank; Sina Bank; and Bahman Group. Investment Company; Parsian Bank; Sina Bank; and Bahman Group.
IRGC-QF personnel supporting the Taliban: Mohammad Ebrahim Owhadi and Esma’il Razavi : Mohammad Ebrahim Owhadi and Esma’il Razavi
October 23, 2018 October 23, 2018
Banks and other Entities. Many of these were also redesignated under EO13382. Bank Melli; . Many of these were also redesignated under EO13382. Bank Melli;
November 5, 2018 November 5, 2018
Arian Bank; Bank Kargoshaee; Melli Bank PLC; Tose-E Develoment Company; Behshahr Industrial Arian Bank; Bank Kargoshaee; Melli Bank PLC; Tose-E Develoment Company; Behshahr Industrial
(in concert with (in concert with
Development Corp.; Cement Industry and Development Company; Melli International Building and Development Corp.; Cement Industry and Development Company; Melli International Building and
reimposition of reimposition of
Industry Company; BMIIC International General Trading LLC; Shomal Cement Company; Persian Industry Company; BMIIC International General Trading LLC; Shomal Cement Company; Persian
JCPOA-related JCPOA-related
Gulf Sabz Karafarinan; Mir Business Bank; Export Development Bank of Iran (EDBI); EDBI Stock Gulf Sabz Karafarinan; Mir Business Bank; Export Development Bank of Iran (EDBI); EDBI Stock
sanctions) sanctions)
Exchange; EDBI Exchange Brokerage; Banco Internacional de Exchange; EDBI Exchange Brokerage; Banco Internacional de ~~Desarrol o~~Desarrollo, C.A.; Iran-Venezuela Bi-, C.A.; Iran-Venezuela Bi-
National Bank; Day Bank; Atieh Sazan Day; Buali Investment Company; Tejarat Gostar Fardad; Day National Bank; Day Bank; Atieh Sazan Day; Buali Investment Company; Tejarat Gostar Fardad; Day
Exchange Company; Day Leasing Co.; Day Brokerage Co.; Tose-e Didar Iran Holding Co.; Royay-e Exchange Company; Day Leasing Co.; Day Brokerage Co.; Tose-e Didar Iran Holding Co.; Royay-e
Roz Kish Investment Co; Day E-Commerce; Tose-e Donya Shahr Kohan Co.; Damavand Power Roz Kish Investment Co; Day E-Commerce; Tose-e Donya Shahr Kohan Co.; Damavand Power
Generation Co,; Omid Bonyan Day Insurance Services; Omran Va Maskan Abad Day Co.; Day Generation Co,; Omid Bonyan Day Insurance Services; Omran Va Maskan Abad Day Co.; Day
Iranian Financial and Accounting Services Co.; Persian International Bank PLC; First East Export Iranian Financial and Accounting Services Co.; Persian International Bank PLC; First East Export
Bank PLC; Mellat Bank Close Joint-Stock Co.; Bank Tejarat; and Trade Capital Bank (Belarus). Bank PLC; Mellat Bank Close Joint-Stock Co.; Bank Tejarat; and Trade Capital Bank (Belarus).
Four Four ~~Hezbol ah~~Hezbollah and IRGC-QF-related individuals who operate in Iraq : Shibl Mushin ‘Ubayd Al- and IRGC-QF-related individuals who operate in Iraq : Shibl Mushin ‘Ubayd Al-
November 13, 2018 November 13, 2018
Zaydi; Yusuf Hashim; Adnan Hussein Kawtharani; Muhammad ‘Abd-Al-Hadi Farhat Zaydi; Yusuf Hashim; Adnan Hussein Kawtharani; Muhammad ‘Abd-Al-Hadi Farhat
Individuals involved in a network through which Iran provides oil to Syria and funds
November 20, 2018 November 20, 2018
Hezbollah and Hamas: Mohamed Amer Alchwiki (also designated under E.O. 13582 for providing : Mohamed Amer Alchwiki (also designated under E.O. 13582 for providing
financial support to Syria); Global Vision Group (also designated under E.O. 13582); Rasul Sajjad and financial support to Syria); Global Vision Group (also designated under E.O. 13582); Rasul Sajjad and
Hossein Yaghoobi (for assisting the IRGC-QF); and Muhammad Qasim al-Bazzal (for assisting Hossein Yaghoobi (for assisting the IRGC-QF); and Muhammad Qasim al-Bazzal (for assisting
~~Hezbol ah~~Hezbollah). ).
Also designated under E.O. 13582 as part of the network: Promsyrioimport; Andrey Dogaev; Mir Also designated under E.O. 13582 as part of the network: Promsyrioimport; Andrey Dogaev; Mir
Business Bank; and Tadbir Kish Medical and Pharmaceutical Company Business Bank; and Tadbir Kish Medical and Pharmaceutical Company
Iran-recruited Afghan and Pakistani-staffed militia entities fighting in Syria: Fatemiyoun : Fatemiyoun
January 24, 2019 January 24, 2019
Division and Zaynabiyoun Brigade. Qeshm Fars Air and Flight Travel LLC—Mahan Air affiliates—for Division and Zaynabiyoun Brigade. Qeshm Fars Air and Flight Travel LLC—Mahan Air affiliates—for
weapons deliveries into Syria. weapons deliveries into Syria.
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Iran Sanctions

Entity
Date Named
Iraq-related entities: Harakat al-Nujaba (HAN), Iraqi Shia militia; and HAN leader Akram Abbas : Harakat al-Nujaba (HAN), Iraqi Shia militia; and HAN leader Akram Abbas
March 5, 2019 March 5, 2019
al-Kabi (previously sanctioned in 2008 when he headed a Mahdi Army “special group” militia) al-Kabi (previously sanctioned in 2008 when he headed a Mahdi Army “special group” militia)
25 individuals and entities that illicitly moved funds via the IRGC-controlled Ansar Bank
March 26, 2019 March 26, 2019
and Ansar Exchange: MODAFL; Ansar Bank, its managing director : MODAFL; Ansar Bank, its managing director ~~Ayatol ah~~Ayatollah Ebrahimi, and Ebrahimi, and
affiliates Iranian Atlas Company, Ansar Bank Brokerage Company, and Ansar Information affiliates Iranian Atlas Company, Ansar Bank Brokerage Company, and Ansar Information
Technology; Ansar Exchange, its managing director Alireza Atabaki, and UAE-based facilitators Reza Technology; Ansar Exchange, its managing director Alireza Atabaki, and UAE-based facilitators Reza
Sakan, Mohammad Vakili and the Vakili-owned Atlas Exchange; Zagros Pardis Kish for helping Sakan, Mohammad Vakili and the Vakili-owned Atlas Exchange; Zagros Pardis Kish for helping
MODAFL acquire vehicles in UAE, and its manager Iman Sedaghat; Sakan General Trading (UAE), its MODAFL acquire vehicles in UAE, and its manager Iman Sedaghat; Sakan General Trading (UAE), its
owner, Rez Sakan and Iran-based affiliate Sakan Exchange; Hital Exchange and its owner Seyyed owner, Rez Sakan and Iran-based affiliate Sakan Exchange; Hital Exchange and its owner Seyyed
Mohammad Reza Ale Ali; Golden Commodities General Trading (UAE), its owner Asadolah Seifi; Mohammad Reza Ale Ali; Golden Commodities General Trading (UAE), its owner Asadolah Seifi;
Seifi-owned UAE firm The Best Leader General Trading; Sulayman Sakan and his firm Atlas Doviz Seifi-owned UAE firm The Best Leader General Trading; Sulayman Sakan and his firm Atlas Doviz
Ticaret A.S. (Turkey) for assisting Atlas Exchange; Ali Shams Mulavi—Turkey-based facilitator for Ticaret A.S. (Turkey) for assisting Atlas Exchange; Ali Shams Mulavi—Turkey-based facilitator for
Ansar Exchange and UAE-based Naria General Trading; Lebra Moon General Trading (UAE). Ansar Exchange and UAE-based Naria General Trading; Lebra Moon General Trading (UAE).
Iraq-based entities facilitating IRGC-QF access to Iraq’s financial system: South Wealth : South Wealth
June 12, 2019 June 12, 2019
Resources Company (aka Manabea Tharwat al-Janoob General Trading Co.); Makki Kazim ‘Abd l Resources Company (aka Manabea Tharwat al-Janoob General Trading Co.); Makki Kazim ‘Abd l
Hamid Al Asadi; and Muhammed Husayn Salih al-Hasani Hamid Al Asadi; and Muhammed Husayn Salih al-Hasani
Eight IRGC Commanders: IRGC Navy Commander Ali Reza Tangsiri; IRGC Aerospace : IRGC Navy Commander Ali Reza Tangsiri; IRGC Aerospace
June 24, 2019 June 24, 2019
Commander Amirali Hajizadeh; IRGC Ground Forces Commander Mohammad Pakpour; and five Commander Amirali Hajizadeh; IRGC Ground Forces Commander Mohammad Pakpour; and five
IRGC Navy district commaners: Abbas Gholamshahi (district 1); Ramezan Zirahi (district 2); IRGC Navy district commaners: Abbas Gholamshahi (district 1); Ramezan Zirahi (district 2);
~~Yadol ah~~Yadollah Badin (district 3); Mansur Ravankar (district 4); and Ali Ozma’I (district 5) Badin (district 3); Mansur Ravankar (district 4); and Ali Ozma’I (district 5)
Hezbollah Parliamentarians: Two : Two ~~Hezbol ah~~Hezbollah parliamentarians for using their parliamentary parliamentarians for using their parliamentary
July 9, 2019 July 9, 2019
positions to advance positions to advance ~~Hezbol ah~~Hezbollah objectives and “bolstering Iran’s malign activities”: Amin Sherri and objectives and “bolstering Iran’s malign activities”: Amin Sherri and
Muhammad Hasan Ra’d (who is also a member of Muhammad Hasan Ra’d (who is also a member of ~~Hezbol ah~~Hezbollah’s Shura Council). Also designated: head ’s Shura Council). Also designated: head
of of ~~Hezbol ah~~Hezbollah security and liaison to Lebanon’s security services Wafiq Safa. security and liaison to Lebanon’s security services Wafiq Safa.
Financial Institutions used by Hezbollah (all in Lebanon): Jammal Trust Bank SAL; Trust Jammal Trust Bank SAL; Trust
August 29, 2019 August 29, 2019
Insurance SAL; Trust Insurance Services SAL; Trust Life Insurance Company SAL Insurance SAL; Trust Insurance Services SAL; Trust Life Insurance Company SAL
Financial Facilitators Moving Funds from IRGC-QF to Hamas: Muahmmad Sarur; Kamal : Muahmmad Sarur; Kamal
August 29, 2019 August 29, 2019
Abdelrahman Aref Awad; Fawaz Mahmud Ali Nasser; Muhammad Al-Ayy. Designations made in Abdelrahman Aref Awad; Fawaz Mahmud Ali Nasser; Muhammad Al-Ayy. Designations made in
partnership with the Sultanate of Oman partnership with the Sultanate of Oman
Oil Tanker Seized and Released by Gibraltar: Adrian Darya 1 and Akhilesh Kumar (ship and : Adrian Darya 1 and Akhilesh Kumar (ship and
August 30, 2019 August 30, 2019
captain, for carrying oil to Syria) captain, for carrying oil to Syria)
Iran Oil Shipping Network: 16 entities and 10 persons, including: Rostam Qasemi (former Oil : 16 entities and 10 persons, including: Rostam Qasemi (former Oil
September 4, 2019 September 4, 2019
Minister, now head of Iranian-Syrian Economic Relations Development Committee); Mehdi Group Minister, now head of Iranian-Syrian Economic Relations Development Committee); Mehdi Group
and subsidiaries (India)—Bushra Ship Management Private Limited, Khadija Ship Management Private and subsidiaries (India)—Bushra Ship Management Private Limited, Khadija Ship Management Private
Limited, Vaniya Ship Management. Kish P and I Club shipping insurer (Iran). Hokoul SAL Offshore, Limited, Vaniya Ship Management. Kish P and I Club shipping insurer (Iran). Hokoul SAL Offshore,
Talaqi Group, Nagham Al Hayat, Tawafuk, ALUMIX (Lebanon) for supplying Syrian state owned Talaqi Group, Nagham Al Hayat, Tawafuk, ALUMIX (Lebanon) for supplying Syrian state owned
Sytrol oil company under IRGC-QF auspices. Sytrol oil company under IRGC-QF auspices.
Persons and Entities Facilitating Funding from IRGC-QF Muhammad Sa’id Izadi (head of Muhammad Sa’id Izadi (head of
September 10, 2019 September 10, 2019
Palestinian Office of the IRGC-QF contingent in Lebanon); Zaher Jabarin (Turkey-based Hamas Palestinian Office of the IRGC-QF contingent in Lebanon); Zaher Jabarin (Turkey-based Hamas
liaison with the IRGC-QF); Redin Exchange (Turkey-based financial channel for IRGC-QF funding of liaison with the IRGC-QF); Redin Exchange (Turkey-based financial channel for IRGC-QF funding of
Hamas and Hamas and ~~Hezbol ah~~Hezbollah); Marwan Mahdi Salah Al Rawi (CEO of Redin Exchange); Ismael Tash (deputy ); Marwan Mahdi Salah Al Rawi (CEO of Redin Exchange); Ismael Tash (deputy
CEO of Redin and facilitator of money transfers from Iran to Hamas); SMART (Ithalat Ihracat Dis CEO of Redin and facilitator of money transfers from Iran to Hamas); SMART (Ithalat Ihracat Dis
Ticaret Limited Sirketi, import-export company associated with Redin) Ticaret Limited Sirketi, import-export company associated with Redin)
Central Bank. Central Bank of Iran, National Development Fund of Iran, and Etemad Tejarate Pars Central Bank of Iran, National Development Fund of Iran, and Etemad Tejarate Pars
September 20, 2019 September 20, 2019
Co. For funneling funds to the IRGC. MODAFL, and Lebanese Co. For funneling funds to the IRGC. MODAFL, and Lebanese ~~Hezbol ah~~Hezbollah. National Development . National Development
Fund, a sovereign wealth fund, is primarily involved in rural electrification and development. Fund, a sovereign wealth fund, is primarily involved in rural electrification and development.
IRGC-QF Shipping Network to Yemen: Abdolhossein Khedri; Khedri Jahan Darya Co; : Abdolhossein Khedri; Khedri Jahan Darya Co;
December 11, 2019 December 11, 2019
Maritime Silk Road LLC. Mahan Air Sales Agents: Gatewick LLC (Dubai); Jahan Destination Travel Maritime Silk Road LLC. Mahan Air Sales Agents: Gatewick LLC (Dubai); Jahan Destination Travel
and Tourism LLC (Dubai); and Gomei Ai Services Co. (Hong Kong) and Tourism LLC (Dubai); and Gomei Ai Services Co. (Hong Kong)
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Iran Sanctions

Entity
Date Named
Hezbollah Individuals and Entities: Three individuals and 12 entities linked to the Martyr’s : Three individuals and 12 entities linked to the Martyr’s
February 26, 2020 February 26, 2020
Foundation, which is part of Foundation, which is part of ~~Hezbol ah~~Hezbollah’s support network. Entities sanctioned included Atlas ’s support network. Entities sanctioned included Atlas
Holdings and its affiliates involved in medical equipment, pharmaceuticals, paints, and tourismHoldings and its affiliates involved in medical equipment, pharmaceuticals, paints, and tourism
Iran and Iraq-based front companies controlled or supporting the IRGC-QF Individuals Individuals
March 26, 2020 March 26, 2020
and entities including: Reconstruction Organization of the Holy Shrines in Iraq; Kosar Company; and entities including: Reconstruction Organization of the Holy Shrines in Iraq; Kosar Company;
Alireza Fadakar (IRGC-QF commander in Najaf); Al Khamael Maritime Services (partly owned by Alireza Fadakar (IRGC-QF commander in Najaf); Al Khamael Maritime Services (partly owned by
QF); Mada’in Novin Traders; Sayyed Yaser Musavir (QF official helping Iraqi Shia militias); Shaykh QF); Mada’in Novin Traders; Sayyed Yaser Musavir (QF official helping Iraqi Shia militias); Shaykh
Adnan al-Hamidawi (special operations commander for Kata’ib Adnan al-Hamidawi (special operations commander for Kata’ib ~~Hezbol ah~~Hezbollah militia); militia);
For Supporting Mahan Airlines: Parthia CargoParthia Cargo (UAE); Delta Parts Supply FZC; and Parthia (UAE); Delta Parts Supply FZC; and Parthia
August 19. 2020 August 19. 2020
owner Amin Mahdavi owner Amin Mahdavi
Former Lebanese Ministers for supporting Hezbollah: Yusuf Finyanus and Ali Hassan Khalil Yusuf Finyanus and Ali Hassan Khalil
September 8, 2020 September 8, 2020
Hezbollah Companies and Person: Arch Consulting; Meamar Construction; Arch Consulting; Meamar Construction; ~~Hezbol ah~~Hezbollah
September 17, 2020 September 17, 2020
Executive Council member Sultan Khalifah As’ad Executive Council member Sultan Khalifah As’ad
Hezbollah Central Council Members: Nabil Qaouk and Hassan al-Baghdadi Nabil Qaouk and Hassan al-Baghdadi
October 22, 2020 October 22, 2020
Iran Ambassador to Iraq. Iraj Masjedi, for being a member of IRGC-QF, acting on its behalf October 22, 2020 Oil Sector Entities Supporting the IRGC-QF/Gas Shipments to Venezuela: IranIran Ministry Ministry
October 26, 2020 October 26, 2020
of Petroleum; of Petroleum; National Iranian Oil Company (NIOC); National Iranian Tanker Company (NITC); National Iranian Oil Company (NIOC); National Iranian Tanker Company (NITC);
two UAE based-front companies (Atlas Ship Management and Atlantic Ship Management); Minister two UAE based-front companies (Atlas Ship Management and Atlantic Ship Management); Minister
of Petroleum Bijan Zanganeh; NIOC senior officials including Director Masoud Karbasian; and of Petroleum Bijan Zanganeh; NIOC senior officials including Director Masoud Karbasian; and
various Ministry of Petroleum Affililiates. various Ministry of Petroleum Affililiates.
For shipments to Venezuela: Mobin International Ltd (UAE); Mobin Holding Ltd (UK; and Oman For shipments to Venezuela: Mobin International Ltd (UAE); Mobin Holding Ltd (UK; and Oman
Fuel Trading Ltd (UK). Fuel Trading Ltd (UK).

IRGC-QF Envoy to Houthis. Hasan Irlu. Also designated: Iran’s Al Mustafa International December 8, 2020 University for recruiting for the IRGC-QF and Yousel Ali Murai for involvement in IRGC-QF operations in the region. Saraya al-Mukhtar. Bahrain Shia underground dissident group reportedly backed by IRGC-QF December 15, 2020
Table D-3. Determinations and Sanctions under the Iran Sanctions Act
Entity
Date Named
Total SA (France); Gazprom (Russia); and Petronas (Malaysia)—$2 Total SA (France); Gazprom (Russia); and Petronas (Malaysia)—$2 ~~bil ion~~billion project to develop South Pars gas project to develop South Pars gas
May 18, 1998 May 18, 1998
field. ISA violation determined but sanctions waived in line with U.S.-EU agreement for EU to cooperate on field. ISA violation determined but sanctions waived in line with U.S.-EU agreement for EU to cooperate on
antiterrorism and antiproliferation issues and not file a complaint at the WTO. antiterrorism and antiproliferation issues and not file a complaint at the WTO. Violation determined but
sanctions waived. .
Naftiran Intertrade Co. (NICO), Iran and Switzerland. Sanctioned for activities to develop Iran’s energy Naftiran Intertrade Co. (NICO), Iran and Switzerland. Sanctioned for activities to develop Iran’s energy
~~Sept. 30, 2010~~
September 30, sector. sector.
2010 Total (France); Statoil (Norway); ENI (Italy); and Royal Dutch Shell. Total (France); Statoil (Norway); ENI (Italy); and Royal Dutch Shell.
~~Sept. 30, 2010~~
September 30, Exempted under ISA “special rule” for pledging to wind down work on Iran energy fields.
2010 Inpex (Japan) Inpex (Japan)
~~Nov. 17, 2010~~
November 17, Exempted under the Special rule for divesting its remaining 10% stake in Azadegan oil field. .
2010 Belarusneft (Belarus, subsidiary of Belneftekhim) Sanctioned for $500 Belarusneft (Belarus, subsidiary of Belneftekhim) Sanctioned for $500 ~~mil ion~~million contract with NICO (see contract with NICO (see
March 29, 2011 March 29, 2011
above) to develop Jofeir oil field. Other subsidiaries of Belneftekhim were sanctioned in 2007 under E.O. above) to develop Jofeir oil field. Other subsidiaries of Belneftekhim were sanctioned in 2007 under E.O.
13405 (Belarus sanctions). 13405 (Belarus sanctions).
Petrochemical Commercial Company International (PCCI) of Bailiwick of Jersey and Iran; Royal Oyster Petrochemical Commercial Company International (PCCI) of Bailiwick of Jersey and Iran; Royal Oyster
May 24, 2011 May 24, 2011
Group (UAE); Tanker Pacific (Singapore); Allvale Maritime (Liberia); Societie Anonyme Monegasque Et Group (UAE); Tanker Pacific (Singapore); Allvale Maritime (Liberia); Societie Anonyme Monegasque Et
Congressional Research Service 78 Iran Sanctions Entity Date Named Aerienne (SAMAMA, Monaco); Speedy Ship (UAE/Iran); Associated Shipbroking (Monaco); and Petroleos de Aerienne (SAMAMA, Monaco); Speedy Ship (UAE/Iran); Associated Shipbroking (Monaco); and Petroleos de
Venezuela (PDVSA, Venezuela). Venezuela (PDVSA, Venezuela).
Sanctioned under CISADA amendment to ISA imposing sanctions for selling gasoline to Iran or helping Iran Sanctioned under CISADA amendment to ISA imposing sanctions for selling gasoline to Iran or helping Iran
import gasoline. Allvale Maritime and SAMAMA determinations were issued on September 13, 2011, to import gasoline. Allvale Maritime and SAMAMA determinations were issued on September 13, 2011, to
“clarify” the May 24 determinations that had named Ofer Brothers Group. The two, as well as Tanker “clarify” the May 24 determinations that had named Ofer Brothers Group. The two, as well as Tanker
~~Congressional Research Service~~
79

~~Iran Sanctions~~

~~Entity~~
~~Date Named~~
Pacific, are affiliated with a Europe-based trust linked to deceased Ofer brother Sami Ofer, and not Ofer Pacific, are affiliated with a Europe-based trust linked to deceased Ofer brother Sami Ofer, and not Ofer
Brothers Group based in Israel. U.S.-based subsidiaries of PDVSA, such as Citgo, were not sanctioned. Brothers Group based in Israel. U.S.-based subsidiaries of PDVSA, such as Citgo, were not sanctioned.
Zhuhai Zhenrong Co. (China); Kuo Oil Pte Ltd. (Singapore); FAL Oil Co. (UAE) Zhuhai Zhenrong Co. (China); Kuo Oil Pte Ltd. (Singapore); FAL Oil Co. (UAE)
January 12, 2012 January 12, 2012
Sanctioned for brokering sales or making sales to Iran of gasoline. Sanctioned for brokering sales or making sales to Iran of gasoline.
Sytrol (Syria), for sales of gasoline to Iran. Sytrol (Syria), for sales of gasoline to Iran.
August 12, 2012 August 12, 2012
Dr. Dimitris Cambis; Impire Shipping; Kish Protection and Indemnity (Iran); and Bimeh Markasi-Central Dr. Dimitris Cambis; Impire Shipping; Kish Protection and Indemnity (Iran); and Bimeh Markasi-Central
March 14, 2013 March 14, 2013
Insurance of Iran (CII, Iran). Sanctioned under ISA provision on owning vessels that transport Iranian oil or Insurance of Iran (CII, Iran). Sanctioned under ISA provision on owning vessels that transport Iranian oil or
providing insurance for the shipments. providing insurance for the shipments.
Tanker Pacific; SAMAMA; and Allvale Maritime Tanker Pacific; SAMAMA; and Allvale Maritime
April 12, 2013 April 12, 2013
Sanctions lifted. Sanctions lifted. Special rule applied after “reliable assurances” they will not engage in similar activity in the future.
Ferland Co. Ltd. (Cyprus and Ukraine) Ferland Co. Ltd. (Cyprus and Ukraine)
May 31, 2013 May 31, 2013
Sanctioned for cooperating with National Iranian Tanker Co. to Sanctioned for cooperating with National Iranian Tanker Co. to ~~il icitly~~illicitly sell Iranian crude oil. sell Iranian crude oil.
Dettin SPA (Italy) For providing goods and services to Iran’s petrochemical industry. Dettin SPA (Italy) For providing goods and services to Iran’s petrochemical industry.
August 29, 2014 August 29, 2014

Table D-4. Entities Sanctioned Under the Iran North Korea Syria Nonproliferation
Act or Executive Order 12938 for Iran-Specific Violations
These designations expired after two years, unless redesignated. The designations included in this table These designations expired after two years, unless redesignated. The designations included in this table
are those that were applied specifically for proliferation activity involving Iran. are those that were applied specifically for proliferation activity involving Iran.
Entity
Date Named
Baltic State Technical University and Glavkosmos, both of Russia. Baltic State Technical University and Glavkosmos, both of Russia.
July 30, 1998 July 30, 1998
(both designations revoked in 2010) (both designations revoked in 2010)
D. Mendeleyev University of Chemical Technology of Russia and Moscow Aviation Institute (removed May D. Mendeleyev University of Chemical Technology of Russia and Moscow Aviation Institute (removed May
January 8, 1999 January 8, 1999
21, 2010) 21, 2010)
Changgwang Sinyong Corp. (North Korea) Changgwang Sinyong Corp. (North Korea)
January 2, 2001 January 2, 2001
Changgwang Sinyong Corp. (North Korea) and Jiangsu Yongli Chemicals and Technology Import-Export Changgwang Sinyong Corp. (North Korea) and Jiangsu Yongli Chemicals and Technology Import-Export
June 14, 2001 June 14, 2001
(China) (China)
Three entities from China for proliferation to Iran Three entities from China for proliferation to Iran
January 16, 2002 January 16, 2002
Armen Sargsian and Lizen Open Joint Stock Co. (Armenia); Cuanta SA and Mikhail Pavlovich Vladov Armen Sargsian and Lizen Open Joint Stock Co. (Armenia); Cuanta SA and Mikhail Pavlovich Vladov
May 9, 2002 May 9, 2002
(Moldova); and eight China entities for proliferation involving Iran (Moldova); and eight China entities for proliferation involving Iran
Norinco (China). For alleged missile technology sale to Iran. Norinco (China). For alleged missile technology sale to Iran.
May 2003 May 2003
Taiwan Foreign Trade General Corporation (Taiwan) Taiwan Foreign Trade General Corporation (Taiwan)
July 4, 2003 July 4, 2003
Tula Instrument Design Bureau (Russia). For alleged sales of laser-guided Tula Instrument Design Bureau (Russia). For alleged sales of laser-guided ~~artil ery~~artillery shells to Iran. (Also shells to Iran. (Also
September 17, September 17,
designated under Executive Order 12938) designated under Executive Order 12938)
2003 2003
13 entities from Russia, China, Belarus, Macedonia, North Korea, UAE, and Taiwan. 13 entities from Russia, China, Belarus, Macedonia, North Korea, UAE, and Taiwan.
April 1, 2004 April 1, 2004
14 entities from China, North Korea, Belarus, India (two nuclear scientists, Dr. Surendar and Dr. Y.S.R. 14 entities from China, North Korea, Belarus, India (two nuclear scientists, Dr. Surendar and Dr. Y.S.R.
September 23, September 23,
Prasad), Russia, Spain, and Ukraine. Prasad), Russia, Spain, and Ukraine.
2004 2004 Congressional Research Service 79 Iran Sanctions Entity Date Named
14 entities, mostly from China, for supplying of Iran’s missile program. Designations included North Korea’s 14 entities, mostly from China, for supplying of Iran’s missile program. Designations included North Korea’s
December 2004 December 2004
Changgwang Sinyong and China’s Norinco and Great Wall Industry Corp, sanctioned previously. Others Changgwang Sinyong and China’s Norinco and Great Wall Industry Corp, sanctioned previously. Others
and January 2005 and January 2005
sanctioned included North Korea’s Paeksan Associated Corporation, and Taiwan’s Ecoma Enterprise Co. sanctioned included North Korea’s Paeksan Associated Corporation, and Taiwan’s Ecoma Enterprise Co.
Nine entities, including from China (Norinco, Hondu Aviation, Dalian Sunny Industries, Zibo Chemet Nine entities, including from China (Norinco, Hondu Aviation, Dalian Sunny Industries, Zibo Chemet
December 23, December 23,
Equipment); India (Sabero Organicx Chemicals and Sandhya Organic Chemicals); and Austria (Steyr Equipment); India (Sabero Organicx Chemicals and Sandhya Organic Chemicals); and Austria (Steyr
2005 2005
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~~Iran Sanctions~~

~~Entity~~
~~Date Named~~
Mannlicher Gmbh). Sanctions against Dr. Surendar of India (see September 29, 2004) were ended because Mannlicher Gmbh). Sanctions against Dr. Surendar of India (see September 29, 2004) were ended because
of information exonerating him. of information exonerating him.
Two Indian chemical companies (Balaji Amines and Prachi Poly Products); two Russian firms Two Indian chemical companies (Balaji Amines and Prachi Poly Products); two Russian firms
July 28, 2006 July 28, 2006
(Rosobornexport and aircraft manufacturer Sukhoi); two North Korean entities (Korean Mining and (Rosobornexport and aircraft manufacturer Sukhoi); two North Korean entities (Korean Mining and
Industrial Development, and Korea Pugang Trading); and one Cuban entity (Center for Genetic Engineering Industrial Development, and Korea Pugang Trading); and one Cuban entity (Center for Genetic Engineering
and Biotechnology). and Biotechnology).
Abu Hamadi (Iraq); Aerospace Logistics Services (Mexico); Al Zargaa Optical and Electronics (Sudan); Abu Hamadi (Iraq); Aerospace Logistics Services (Mexico); Al Zargaa Optical and Electronics (Sudan);
December 28, December 28,
Alexey Safonov (Russia); Arif Durrani (Pakistan)China National Aero Technology Import-Export (China); Alexey Safonov (Russia); Arif Durrani (Pakistan)China National Aero Technology Import-Export (China);
2006 2006
China National Electronic Import Export (China); Defense Industries Org. (Iran); Giad Industrial Complex China National Electronic Import Export (China); Defense Industries Org. (Iran); Giad Industrial Complex
(Sudan); Iran Electronics Industry (Iran); Kal al-Zuhiry (Iraq); Kolomna Design Bureau of Machine Building (Sudan); Iran Electronics Industry (Iran); Kal al-Zuhiry (Iraq); Kolomna Design Bureau of Machine Building
(Russia); NAB Export Co. (Iran); Rosoboronexport (Russia); Sanam Industrial Group (Iran); Target (Russia); NAB Export Co. (Iran); Rosoboronexport (Russia); Sanam Industrial Group (Iran); Target
Airfreight (Malaysia); Tula Design Bureau of Instrument Building (Russia); Yarmouk Industrial Complex Airfreight (Malaysia); Tula Design Bureau of Instrument Building (Russia); Yarmouk Industrial Complex
(Sudan) Zibo Chemet Equipment Co. (China) (Sudan) Zibo Chemet Equipment Co. (China)
Rosobornexport, Tula Design, and Komna Design Office of Machine Building, and Alexei Safonov (Russia); Rosobornexport, Tula Design, and Komna Design Office of Machine Building, and Alexei Safonov (Russia);
January 2007 January 2007
Zibo Chemical, China National Aerotechnology, and China National Electrical (China). Korean Mining and Zibo Chemical, China National Aerotechnology, and China National Electrical (China). Korean Mining and
Industrial Development (North Korea) for WMD/advanced weapons sales to Iran and Syria. Industrial Development (North Korea) for WMD/advanced weapons sales to Iran and Syria.
14 entities, including Lebanese 14 entities, including Lebanese ~~Hezbol ah~~Hezbollah. Some were penalized for transactions with Syria. For assisting . Some were penalized for transactions with Syria. For assisting
April 17, 2007 April 17, 2007
Iran: Shanghai Non-Ferrous Metals Pudong Development Trade Company (China); Iran’s Defense Industries Iran: Shanghai Non-Ferrous Metals Pudong Development Trade Company (China); Iran’s Defense Industries
Organization; Sokkia Company (Singapore); Challenger Corporation (Malaysia); Target Airfreight (Malaysia); Organization; Sokkia Company (Singapore); Challenger Corporation (Malaysia); Target Airfreight (Malaysia);
Aerospace Logistics Services (Mexico); and Arif Durrani (Pakistani national). Aerospace Logistics Services (Mexico); and Arif Durrani (Pakistani national).
China Xinshidai Co.; China Shipbuilding and Offshore International Corp.; Huazhong CNC (China); IRGC; China Xinshidai Co.; China Shipbuilding and Offshore International Corp.; Huazhong CNC (China); IRGC;
October 23, 2008 October 23, 2008
Korea Mining Development Corp. (North Korea); Korea Taesong Trading Co. (NK); Yolin/ Korea Mining Development Corp. (North Korea); Korea Taesong Trading Co. (NK); Yolin/~~Yul in~~Yullin Tech, Inc. Tech, Inc.
(South Korea); Rosoboronexport (Russia sate arms export agency); Sudan Master Technology; Sudan (South Korea); Rosoboronexport (Russia sate arms export agency); Sudan Master Technology; Sudan
Technical Center Co; Army Supply Bureau (Syria); R and M International FZCO (UAE); Venezuelan Military Technical Center Co; Army Supply Bureau (Syria); R and M International FZCO (UAE); Venezuelan Military
Industries Co. (CAVIM). (Rosoboronexport removed May 21, 2010.) Industries Co. (CAVIM). (Rosoboronexport removed May 21, 2010.)
BelTechExport (Belarus); Dalian Sunny Industries (China); Defense Industries Organization (Iran); Karl Lee; BelTechExport (Belarus); Dalian Sunny Industries (China); Defense Industries Organization (Iran); Karl Lee;
July 14, 2010 July 14, 2010
Shahid Bakeri Industries Group (SBIG); Shanghai Technical By-Products International (China); Zibo Chemet Shahid Bakeri Industries Group (SBIG); Shanghai Technical By-Products International (China); Zibo Chemet
Equipment (China) Equipment (China)
16 entities: Belarus: Belarusian Optical Mechanical Association; Beltech Export; China: Karl Lee; Dalian 16 entities: Belarus: Belarusian Optical Mechanical Association; Beltech Export; China: Karl Lee; Dalian
May 23, 2011 May 23, 2011
Sunny Industries; Dalian Zhongbang Chemical Industries Co.; Xian Junyun Electronic; Iran: Milad Jafari; DIO; Sunny Industries; Dalian Zhongbang Chemical Industries Co.; Xian Junyun Electronic; Iran: Milad Jafari; DIO;
IRISL; IRGC Qods Force; SAD Import-Export; SBIG; North Korea: Tangun Trading; Syria: Industrial IRISL; IRGC Qods Force; SAD Import-Export; SBIG; North Korea: Tangun Trading; Syria: Industrial
Establishment of Defense; Scientific Studies and Research Center; Venezuela: CAVIM. Establishment of Defense; Scientific Studies and Research Center; Venezuela: CAVIM.
Belvneshpromservice (Belarus); Dalian Sunny Industries (China); Defense Industries Organization (Iran); Karl December 20, Belvneshpromservice (Belarus); Dalian Sunny Industries (China); Defense Industries Organization (Iran); Karl December 20,
Lee (China); SAD Import-Export (Iran); Zibo Chemet Equipment Co. (Iran); F Lee (China); SAD Import-Export (Iran); Zibo Chemet Equipment Co. (Iran); F
2011 2011
Al Zargaa Engineering Complex (Sudan); BST Technology and Trade Co. (China); China Precision Machinery February 5, 2013 Al Zargaa Engineering Complex (Sudan); BST Technology and Trade Co. (China); China Precision Machinery February 5, 2013
Import and Export Co. (China); Dalian Sunny Industries (China); Iran Electronics Industries (Iran); Karl Lee Import and Export Co. (China); Dalian Sunny Industries (China); Iran Electronics Industries (Iran); Karl Lee
(China); Marine Industries Organization (Iran); Milad Jafari (Iran); Poly Technologies (China); Scientific and (China); Marine Industries Organization (Iran); Milad Jafari (Iran); Poly Technologies (China); Scientific and
Industrial Republic Unitary Enterprise (Belarus); SMT Engineering (Sudan); TM Services Ltd. (Belarus); Industrial Republic Unitary Enterprise (Belarus); SMT Engineering (Sudan); TM Services Ltd. (Belarus);
Venezuelan Military Industry Co. (CAVIM, Venezuela). Venezuelan Military Industry Co. (CAVIM, Venezuela).
Al Zargaa Engineering Complex (Sudan); Belvneshpromservice (Belarus); HSC Mic NPO Mashinostroyenia Al Zargaa Engineering Complex (Sudan); Belvneshpromservice (Belarus); HSC Mic NPO Mashinostroyenia
December 19, December 19,
(Russia); Russian Aircraft Corporation (MiG); Giad Heavy Industries Complex (Sudan); Sudan Master (Russia); Russian Aircraft Corporation (MiG); Giad Heavy Industries Complex (Sudan); Sudan Master
2014. 2014.
Technologies (Sudan); Military Industrial Corps. (Sudan); Yarmouk Industrial Complex (Sudan); Venezuelan Technologies (Sudan); Military Industrial Corps. (Sudan); Yarmouk Industrial Complex (Sudan); Venezuelan
Military Industry Co. (CAVIM, Venezula) Military Industry Co. (CAVIM, Venezula)
BST Technology and Trade Co. (China); Dalian Sunny Industries (China); Li Fang Wei (China); Tianjin BST Technology and Trade Co. (China); Dalian Sunny Industries (China); Li Fang Wei (China); Tianjin
August 28, 2015 August 28, 2015
Flourish Chemical Co. (China); Qods Force Commander Qasem Soleimani; IRGC; Rock Chemie (Iran); Flourish Chemical Co. (China); Qods Force Commander Qasem Soleimani; IRGC; Rock Chemie (Iran);
Polestar Trading Co. Ltd. (North Korean entity in China); RyonHap-2 (North Korea) Tula Instrument Polestar Trading Co. Ltd. (North Korean entity in China); RyonHap-2 (North Korea) Tula Instrument
Congressional Research Service 80 Iran Sanctions Entity Date Named Design Bureau (Russia); Joint Stock Co. Katod (Russia); JSC Mic NPO Mashinostroyenia (Russia); Design Bureau (Russia); Joint Stock Co. Katod (Russia); JSC Mic NPO Mashinostroyenia (Russia);
Rosoboronexport (Russia) Russian Aircraft Corp. MiG (Russia); Sudanese Armed Forces (Sudan); Vega Rosoboronexport (Russia) Russian Aircraft Corp. MiG (Russia); Sudanese Armed Forces (Sudan); Vega
Aeronautics (Sudan); Yarmouk Complex (Sudan); Aeronautics (Sudan); Yarmouk Complex (Sudan); ~~Hezbol ah~~Hezbollah; Eliya General Trading (UAE). (Designations ; Eliya General Trading (UAE). (Designations
that applied to Syria or North Korea not included.)that applied to Syria or North Korea not included.)
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~~Iran Sanctions~~

~~Entity~~
~~Date Named~~
Asaib Ahl Haq (Iraqi Asaib Ahl Haq (Iraqi ~~Shi te~~Shiite militia); Katai’b militia); Katai’b ~~Hezbol ah~~Hezbollah (Iraqi militia); IRGC; Shahid Moghadam-Yazd Marine (Iraqi militia); IRGC; Shahid Moghadam-Yazd Marine
June 28, 2016 June 28, 2016
Industries (Iran); Shiraz Electronic Industries (Iran); Industries (Iran); Shiraz Electronic Industries (Iran); ~~Hezbol ah~~Hezbollah; Military Industrial Corp. (Sudan); Khartoum ; Military Industrial Corp. (Sudan); Khartoum

Industrial Complex (Sudan); Khartoum Military Industrial Complex (Sudan); Luwero Industries (Uganda) Industrial Complex (Sudan); Khartoum Military Industrial Complex (Sudan); Luwero Industries (Uganda)
11 entities sanctions for transfers of sensitive items to Iran’s ballistic missile program (all China except as 11 entities sanctions for transfers of sensitive items to Iran’s ballistic missile program (all China except as
March 21, 2017 March 21, 2017
specified: Beijing Zhong Ke Electric Co.; Dalian Zenghua Maoyi Youxian Gongsi; Jack Qin; Jack Wang; Karl specified: Beijing Zhong Ke Electric Co.; Dalian Zenghua Maoyi Youxian Gongsi; Jack Qin; Jack Wang; Karl
Lee; Ningbo New Century Import and Export Co.; Shenzhen Yataida High-Tech Company; Sinotech Dalian Lee; Ningbo New Century Import and Export Co.; Shenzhen Yataida High-Tech Company; Sinotech Dalian
Carbon and Graphite Corp.; Sky Rise Technology (aka Reekay); Saeng Pil Trading Corp. (North Korea); Carbon and Graphite Corp.; Sky Rise Technology (aka Reekay); Saeng Pil Trading Corp. (North Korea);
Mabrooka Trading (UAE) Mabrooka Trading (UAE)
For transferring items for Iran ballistic missile program: Luo Dingwen, Gaobeidian Kaituo Precise Instrument September 23, Co. Ltd; Raybeam Optronics Co. Ltd; and Tungsten (Ziamen) Manu and Sales Corp. 2020 For transferring items for Iran ballistic missile program: Chengdu Best New Materials Co., Ltd.; Zibo Elim November 6, 2020 Trade Co. Ltd.; Nilco Group; Joint Stock Co. Elecon Table D-5. Entities Designated under the Iran-Iraq Arms Non-Proliferation Act
of 1992
(all designations have expired or were lifted) (all designations have expired or were lifted)
Entity
Date Named
Mohammad al-Khatib (Jordan); Protech Consultants Private (India) Mohammad al-Khatib (Jordan); Protech Consultants Private (India)
December 13, December 13,
2003 2003
China Machinery and Electric Equipment Import and Export Corp. (China); China Machinery and Equipment China Machinery and Electric Equipment Import and Export Corp. (China); China Machinery and Equipment
July 9, 2002 July 9, 2002
Import-Export Co. (China); China National Machinery and Equipment Import-Export Co. (China); China Import-Export Co. (China); China National Machinery and Equipment Import-Export Co. (China); China
Shipbuilding Trading Co. (China); CMEC Machinery (China); Hans Raj Shiv (India); Jiangsu Youngli Chemicals Shipbuilding Trading Co. (China); CMEC Machinery (China); Hans Raj Shiv (India); Jiangsu Youngli Chemicals
and Technology Import-Export Co. (China); Q.C. Chen (China); Wha Cheong Tai Co. Ltd. (China). and Technology Import-Export Co. (China); Q.C. Chen (China); Wha Cheong Tai Co. Ltd. (China).

Table D-6. Entities Designated as Threats to Iraqi Stability under Executive Order
13438 (July 17, 2007)
Entity
Date Named
Ahmad Forouzandeh. Commander of the Qods Force Ramazan Headquarters, accused of Ahmad Forouzandeh. Commander of the Qods Force Ramazan Headquarters, accused of
January 8, 2008 January 8, 2008
fomenting sectarian violence in Iraq and of organizing training in Iran for Iraqi fomenting sectarian violence in Iraq and of organizing training in Iran for Iraqi ~~Shi te~~Shiite militia militia
fighters; Abu Mustafa al-Sheibani. Iran based leader of network that funnels Iranian arms to fighters; Abu Mustafa al-Sheibani. Iran based leader of network that funnels Iranian arms to
~~Shi te~~Shiite militias in Iraq; Isma’il al-Lami (Abu Dura). militias in Iraq; Isma’il al-Lami (Abu Dura). ~~Shi te~~Shiite militia leader, breakaway from Sadr militia leader, breakaway from Sadr
Mahdi Army; Al Zawra Television Station and its owner, Mishan al-Jabburi. Mahdi Army; Al Zawra Television Station and its owner, Mishan al-Jabburi.
Abdul Reza Shahlai, a deputy commander of the Qods Force; Akram Abbas Al Kabi, leader Abdul Reza Shahlai, a deputy commander of the Qods Force; Akram Abbas Al Kabi, leader
September 16, 2008 September 16, 2008
of Mahdi Army “Special Groups”; Harith Al Dari, Sunnis Islamist leader (Secretary General of Mahdi Army “Special Groups”; Harith Al Dari, Sunnis Islamist leader (Secretary General
of the Muslim Scholars’ Association; Ahmad Hassan Kaka Al Ubaydi, ex-Baathist leader of of the Muslim Scholars’ Association; Ahmad Hassan Kaka Al Ubaydi, ex-Baathist leader of
Sunni insurgents; Al Ray Satellite TV Channel, and Suraqiya for Media and Broadcasting, Sunni insurgents; Al Ray Satellite TV Channel, and Suraqiya for Media and Broadcasting,
owned by Mish’an Al Jabburi (see above), and Raw’a Al Usta (wife of Al Jabburi). owned by Mish’an Al Jabburi (see above), and Raw’a Al Usta (wife of Al Jabburi).
Khata’ib Khata’ib ~~Hezbol ah~~Hezbollah (Mahdi splinter group); Abu Mahdi al-Muhandis. (Muhandis was (Mahdi splinter group); Abu Mahdi al-Muhandis. (Muhandis was ~~kil ed~~killed in in
July 2, 2009 July 2, 2009
the U.S. strike of January 3, 2020, that the U.S. strike of January 3, 2020, that ~~kil ed~~killed IRGC-Qf commander Qasem Soleimani.) IRGC-Qf commander Qasem Soleimani.)

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Table D-7. Iranians Designated Under Executive Order 13553 on Human Rights
Abusers (September 29, 2010)
These persons are named in a semiannual report to Congress, required under CISADA. Virtually all of the These persons are named in a semiannual report to Congress, required under CISADA. Virtually all of the
persons on this list, and those listed under Executive order 13628 (below) are designated as human rights persons on this list, and those listed under Executive order 13628 (below) are designated as human rights
abusers by the European Union, whose list contains 87 individuals, including several province-level abusers by the European Union, whose list contains 87 individuals, including several province-level
prosecutors prosecutors
Entity
Date Named
Eight persons: IRGC Commander Mohammad Ali Jafari; Minister of Interior at time of June Eight persons: IRGC Commander Mohammad Ali Jafari; Minister of Interior at time of June
September 29, September 29,
2009 elections Sadeq Mahsouli; Minister of 2009 elections Sadeq Mahsouli; Minister of ~~Intelligence~~Intel igence at time of elections Qolam Hossein at time of elections Qolam Hossein
2010 2010
Mohseni-Ejei; Tehran Prosecutor General at time of elections Saeed Mortazavi; Minister of Mohseni-Ejei; Tehran Prosecutor General at time of elections Saeed Mortazavi; Minister of
Intelligence Heydar Moslehi; Former Defense Minister Mostafa Mohammad Najjar; Deputy Intelligence Heydar Moslehi; Former Defense Minister Mostafa Mohammad Najjar; Deputy
National Police Chief Ahmad Reza Radan; Basij (security militia) Commander at time of National Police Chief Ahmad Reza Radan; Basij (security militia) Commander at time of
elections Hossein Taeb elections Hossein Taeb
Two persons: Tehran Prosecutor General Abbas Dowlatabadi (appointed August 2009), for Two persons: Tehran Prosecutor General Abbas Dowlatabadi (appointed August 2009), for
February 23, 2011 February 23, 2011
indicting large numbers of protesters; Basij forces commander Mohammad Reza Naqdi indicting large numbers of protesters; Basij forces commander Mohammad Reza Naqdi
(headed Basij intelligence during 2009 protests) (headed Basij intelligence during 2009 protests)
Four entities: Islamic Revolutionary Guard Corps (IRGC); Basij Resistance Force; Law Four entities: Islamic Revolutionary Guard Corps (IRGC); Basij Resistance Force; Law
June 9, 2011 June 9, 2011
Enforcement Forces (LEF); LEF Commander Ismail Ahmad Moghadam Enforcement Forces (LEF); LEF Commander Ismail Ahmad Moghadam
Two persons: Chairman of the Joint Chiefs of Staff Hassan Firouzabadi; Deputy IRGC Two persons: Chairman of the Joint Chiefs of Staff Hassan Firouzabadi; Deputy IRGC
December 13, 2011 December 13, 2011
Commander Commander ~~Abdol ah~~Abdollah Araghi Araghi
One entity: Ministry of Intelligence and Security of Iran (MOIS) One entity: Ministry of Intelligence and Security of Iran (MOIS)
February 16, 2012 February 16, 2012
One person: Ashgar Mir-Hejazi for human rights abuses on/after June 12, 2009, and for One person: Ashgar Mir-Hejazi for human rights abuses on/after June 12, 2009, and for
May 30, 2013 May 30, 2013
providing material support to the IRGC and MOIS. providing material support to the IRGC and MOIS.
One entity: Abyssec, for training the IRGC in cyber tradecraft and supporting its One entity: Abyssec, for training the IRGC in cyber tradecraft and supporting its
December 30, 2014 December 30, 2014
development of offensive information operations capabilities. development of offensive information operations capabilities.
One entity and One person: Tehran Prisons Organization. For severe beating of prisoners One entity and One person: Tehran Prisons Organization. For severe beating of prisoners
April 13, 2017 April 13, 2017
at Evin Prison in April 2014; Sohrab Soleimani (brother of IRGC-QF commander) as head of at Evin Prison in April 2014; Sohrab Soleimani (brother of IRGC-QF commander) as head of
Tehran Prisoners Organization at the time of the attack above. Heads State Prisons Tehran Prisoners Organization at the time of the attack above. Heads State Prisons
Organization. Organization.
Persons and entities designated Persons and entities designated ~~fol owing~~following repression of December 2017-January 2018 repression of December 2017-January 2018
January 12, 2018 January 12, 2018
protests: Judiciary head Sadeq Amoli Larijani (highest-ranking Iranian official sanctioned by protests: Judiciary head Sadeq Amoli Larijani (highest-ranking Iranian official sanctioned by
the United States); Rajaee Shahr Prison; and Gholmreza Ziaei the United States); Rajaee Shahr Prison; and Gholmreza Ziaei
Ansar-e Ansar-e ~~Hezbol ah~~Hezbollah internal security militia designations: Ansar-e internal security militia designations: Ansar-e ~~Hezbol ah~~Hezbollah; Ansar leaders ; Ansar leaders
May 30, 3018 May 30, 3018
Abdolhamid Mohtasham; Hossein Allahkaram; and Hamid Ostad. Evin Prison. Abdolhamid Mohtasham; Hossein Allahkaram; and Hamid Ostad. Evin Prison.
Ghavamin Bank (for assisting Iran’s Law Enforcement Forces, LEF) Ghavamin Bank (for assisting Iran’s Law Enforcement Forces, LEF)
November 5, 2018 November 5, 2018
Fatemiyoun Division and Zaynabiyoun Brigade Fatemiyoun Division and Zaynabiyoun Brigade
January 24, 2019 January 24, 2019
Abdolreza Rahmani Fazli (Interior Minister); LEF officials Hossain Ashtari Fard, Ayoub Abdolreza Rahmani Fazli (Interior Minister); LEF officials Hossain Ashtari Fard, Ayoub
May 20, 2020 May 20, 2020
Soleimani, Mohsen Fathi Zadeh, Yahya Mahmoodzadeh, Hamidreza Ashraq, and Mohammad Soleimani, Mohsen Fathi Zadeh, Yahya Mahmoodzadeh, Hamidreza Ashraq, and Mohammad
Ali Noorinajad; Hassan Shavarpour Najafabadi (IRGC Vali Asr base commander): LEF Ali Noorinajad; Hassan Shavarpour Najafabadi (IRGC Vali Asr base commander): LEF
Cooperative Foundation and its manager Habil Darvis. Cooperative Foundation and its manager Habil Darvis.
For Cyber violations: against Iranian dissidents and perceived threats: Advanced Persistent For Cyber violations: against Iranian dissidents and perceived threats: Advanced Persistent
September 17, September 17,
Threat 39; Rana Intelligence Computing, and 45 individuals associated with the activity Threat 39; Rana Intelligence Computing, and 45 individuals associated with the activity
2020 2020
Minister of Minister of ~~Intelligence~~Intel igence and Security Mahmoud Alavi and Security Mahmoud Alavi
November 18, November 18,
2020 2020
For helping the MOIS in the abduction and probable death of former FBI agent Robert December 14, 2020 Levinson: Mohammad Baseri and Ahmad Khazai Congressional Research Service Congressional Research Service
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Table D-8. Iranian Entities Sanctioned Under Executive Order 13572 for Repression
of the Syrian People
(April 29, 2011)
Entity
Date Named
Revolutionary Guard—Qods Force (IRGC-QF) Revolutionary Guard—Qods Force (IRGC-QF)
April 29, 2011 April 29, 2011
Qasem Soleimani (Qods Force Commander); Mohsen Chizari (Commander of Qods Force Qasem Soleimani (Qods Force Commander); Mohsen Chizari (Commander of Qods Force
May 18, 2011 May 18, 2011
operations and training) operations and training)
Ministry of Intelligence and Security (MOIS) Ministry of Intelligence and Security (MOIS)
February 16, 2012 February 16, 2012

Table D-9. Iranian Entities Sanctioned Under Executive Order 13606
(GHRAVITY, April 23, 2012)
Entity
Date Named
Ministry of Intelligence and Security (MOIS); IRGC (Guard Cyber Defense Command); Law Ministry of Intelligence and Security (MOIS); IRGC (Guard Cyber Defense Command); Law
April 23, 2012 April 23, 2012
Enforcement Forces; Datak Telecom Enforcement Forces; Datak Telecom
IRGC Electronic Warfare and Cyber Defense Organization IRGC Electronic Warfare and Cyber Defense Organization
January 12, 2018 January 12, 2018
Hanista Programming Group. For operating technology that monitors or tracks computers Hanista Programming Group. For operating technology that monitors or tracks computers
May 30, 2018 May 30, 2018

Table D-10. Entities Sanctioned Under Executive Order 13608 Targeting Sanctions
Evaders (May 1, 2012)
Entity
Date Named
Ferland Company Ltd. for helping NITC deceptively . for helping NITC deceptively ~~sel~~ sell Iranian crude oil Iranian crude oil
May 31, 2013 May 31, 2013
Three persons based in the Republic of Georgia: Pourya Nayebi, Houshang Hosseinpour, and
February 6, 2014 February 6, 2014
Houshang Farsoudeh.
Eight firms owned or controlled by the three: Caucasus Energy (Georgia); Orchidea Gulf Trading
(UAE and/or Turkey); Georgian Business Development (Georgia and/or UAE); Great Business Deals
(Georgia and/or UAE); KSN Foundation (Lichtenstein); New York General Trading (UAE); New York
Money Exchange (UAE and/or Georgia); and European Oil Traders (Switzerland).
Evren Kayakiran (Turkey) for directing employees to provide U.S. products and services to Evren Kayakiran (Turkey) for directing employees to provide U.S. products and services to
February 7, 2019 February 7, 2019
Iran Iran

Table D-11. Entities Named as Iranian Government Entities Under Executive Order
13599 (February 5, 2012)
Hundreds of entities—many of which are names and numbers of individual ships and aircraft—were Hundreds of entities—many of which are names and numbers of individual ships and aircraft—were
designated under this order to implement the JCPOA, and removed from the list of SDNs, in order that designated under this order to implement the JCPOA, and removed from the list of SDNs, in order that
secondary sanctions not apply. Those entities are in italics. Others were designated as owned or secondary sanctions not apply. Those entities are in italics. Others were designated as owned or
controlled by the government of Iran before the JCPOA. As of November 5, 2018, all the entities controlled by the government of Iran before the JCPOA. As of November 5, 2018, all the entities
designated under E.O. 13599 are subject to secondary sanctions. designated under E.O. 13599 are subject to secondary sanctions.
Entity
Date Named
Two insurance companies: Two insurance companies: Bimeh Iran Insurance Company (U.K.) Ltd. and and Iran Insurance
June 16, 2010 June 16, 2010
Company. .
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Iran Sanctions

Entity
Date Named
20 Petroleum and Petrochemical Entities: 20 Petroleum and Petrochemical Entities: MSP Kala Naft Co. Tehran; ; Kala Limited; ; Kala
Pension Trust Limited; ; National Iranian Oil Company PTE Ltd; ; Iranian Oil Company (U.K.) Ltd.; .;
NIOC International Affairs (London) Ltd.; .; Naftiran Trading Services Co. (NTS) Ltd.; .; NICO
Engineering Ltd.; .; National Petrochemical Company; ; Iran Petrochemical Commercial Company; ; NPC
International Ltd.; .; Intra Chem Trading Gmbh; ; Petrochemical Commercial Company International
Ltd.; .; P.C.C. (Singapore) Private Ltd.; .; Petrochemical Commercial Company FZE; ; Petrochemical
Commercial Company (U.K.) Ltd.; .; PetroIran Development Company (PEDCO) Ltd.; .; Petropars Ltd.; .;
Petropars International FZE; ; Petropars U.K. Ltd.
Central Bank of Iran (aka Bank Markazi) (aka Bank Markazi)
February 12, 2012 February 12, 2012
Shipping Companies Shipping Companies: Arash Shipping Enterprises Ltd.; Arta Shipping Enterprises Ltd.; Asan
July 12, 2012 July 12, 2012
Shipping Enterprise Ltd.; Caspian Maritime Ltd.; Danesh Shipping Co. Ltd.; Davar Shipping Co. Ltd.;
Dena Tankers FZE; Good Luck Shipping LLC; Hadi Shipping Company Ltd.; Haraz Shipping
Company Ltd.; Hatef Shipping Company Ltd.; Hirmand Shipping Company Ltd,; Hoda Shipping
Company Ltd.; Homa Shipping Company Ltd.; Honar Shipping Company Ltd.; Mehran Shipping
Company Ltd.; Mersad Shipping Company Ltd.; Minab Shipping Company Ltd.; Pars Petrochemical
Shipping Company; Proton Petrochemicals Shipping Ltd; Saman Shipping Company Ltd.; Sarv
Shipping Company Ltd.; Sepid Shipping Company Ltd.; Sima Shipping Company Ltd.; Sina Shipping
Company Ltd.; TC Shipping Company Ltd.
Energy FirmsEnergy Firms: Petro Suisse Intertrade Company (Switzerland); (Switzerland); Hong Kong Intertrade Company
(Hong Kong); (Hong Kong); Noor Energy (Malaysia); (Malaysia); Petro Energy Intertrade (Dubai, UAE) (all four named as (Dubai, UAE) (all four named as
front companies for NIOC, front companies for NIOC, Naftiran Intertrade Company, Ltd (NICO), or (NICO), or NICO Sarl) )
58 vessels of National Iranian Tanker Company (NITC)
Banks: Ansar Bank; Banks: Ansar Bank; Future Bank B.S.C; ; Post Bank of Iran; ; Dey Bank; ; Eghtesad Novin Bank; ;
Hekmat Iranian Bank; ; Iran Zamin Bank; Islamic Regional Cooperation Bank; Joint Iran-Venezuela ; Joint Iran-Venezuela
Bank; Bank; Karafarin Bank; ; Mehr Iran Credit Union Bank; ; Parsian Bank; ; Pasargad Bank; ; Saman Bank; ;
Sarmayeh Bank; ; Tat Bank; Tosee Taavon Bank; ; Tourism Bank; Bank-e Shahr; Credit Institution for
Development
Entities and persons helping Iran evade oil shipping sanctions: Entities and persons helping Iran evade oil shipping sanctions: Dimitris Cambis; ; Impire Shipping March 14, 2013 March 14, 2013
Co.; Libra Shipping SA; .; Libra Shipping SA; Monsoon Shipping Ltd.; .; Koning Marine Ltd.; .; Blue Tanker Shipping SA; ;
Jupiter Seaways Shipping; ; Hercules International Ship; ; Hermis Shipping SA; ; Garbin Navigation Ltd.; .;
Grace Bay Shipping Inc; ; Sima General Trading Co. FZE; ; Polinex General Trading LLC; ; Asia Energy
General Trading; ; Synergy General Trading FZE. .
Sambouk Shipping FZC, which is tied to Dr. Dimitris Cambis and his network of front , which is tied to Dr. Dimitris Cambis and his network of front
May 9, 2013 May 9, 2013
companies. companies.
Eight petrochemicals companies: Eight petrochemicals companies: Bandar Imam; Bou Ali Sina; Mobin; Nouri; Pars; Shahid
May 31, 2013 May 31, 2013
Tondgooyan; Shazand; and and Tabriz.
Six individuals including Six individuals including Seyed Nasser Mohammad Seyyedi, director of Sima General Trading , director of Sima General Trading
September 6, 2013 September 6, 2013
who is also associated with NIOC and NICO. The other 5 persons sanctioned manage firms who is also associated with NIOC and NICO. The other 5 persons sanctioned manage firms
associated with NIOC and NICO. associated with NIOC and NICO.
Four businesses used by Seyyedi to assist NIOC and NICO front companies: Four businesses used by Seyyedi to assist NIOC and NICO front companies: AA Energy
FZCO; ; Petro Royal FZE; and ; and KASB International LLC (all in UAE); and Swiss Management Services
Sarl. .
Execution of Imam’s Order (EIKO) and entities under its umbrella, designated for hiding assets and entities under its umbrella, designated for hiding assets
January 4, 2013 January 4, 2013
on behalf of the government of Iran’s leadership: on behalf of the government of Iran’s leadership: Tosee e Eqtesad Ayandehsazan Company
(TEACO); (TEACO); Tadbir Economic Development Company (Tadbir Group); (Tadbir Group); Tadbir Investment
Company; ; Modaber; ; Tadbir Construction Development Company; ; Tadbir Energy Development
Group; ; Amin Investment Bank; ; Pardis Investment Company; ; Mellat Insurance Company; ; Rey
Investment Company; ; Reyco GmbH; ; MCS International GmbH (Mannesman Cylinder Systems); (Mannesman Cylinder Systems);
MCS Engineering (Efficient Provider Services GmbH); (Efficient Provider Services GmbH); Golden Resources Trading Company L.L.C.
(GRTC); (GRTC); Cylinder System Ltd. (Cylinder System DDO); . (Cylinder System DDO); One Vision Investments 5 (Pty) Ltd.; .; One
Class Properties (Pty) Ltd.; Iran and Shargh Company; Iran and Shargh Leasing Company; Tadbir
Brokerage Company; Rafsanjan Cement Company; Rafsanjan Cement Company; Rishmak Productive and Exports Company; ;
Omid Rey Civil and Construction Company; ; Behsaz Kashane Tehran Construction Company; y; Royal
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Entity
Date Named
Arya Company; ; Hormuz Oil Refining Company; ; Ghaed Bassir Petrochemical Products Company; ;
Persia Oil and Gas Industry Development Company; ; Pars Oil Company; ; Commercial Pars Oil
Company; ; Marjan Petrochemical Company; ; Ghadir Investment Company; ; Sadaf Petrochemical
Assaluyeh Company; ; Polynar Company; ; Pars MCS; Arman Pajouh Sabzevaran Mining Company; ; Arman Pajouh Sabzevaran Mining Company;
Oil industry Investment Company; ; Rey Niru Engineering Company. .
Five Iranian banks: Five Iranian banks: Khavarmianeh Bank, Ghavamin Bank, , Gharzolhasaneh Bank, Kish
August 29, 2014 August 29, 2014
International Bank, and , and Kafolatbank (Tajikistan). (Tajikistan).
Numerous Iranian aircraft and vessels, in keeping with the reimposition of U.S. sanctions. Numerous Iranian aircraft and vessels, in keeping with the reimposition of U.S. sanctions.
November 5, 2018 November 5, 2018
Five unnamed Iranian ship captains for delivering gasoline to Venezuela Five unnamed Iranian ship captains for delivering gasoline to Venezuela
June 24, 2020 June 24, 2020

Table D-12. Entities Sanctioned Under Executive Order 13622 for Oil and
Petrochemical Purchases from Iran (July 30, 2012)
Entity
Date Named
Jam Petrochemical Company (for purchasing petrochemical products from Iran); (for purchasing petrochemical products from Iran); Niksima Food
May 31, 2013 May 31, 2013
and Beverage JLT (for receiving payments on behalf of Jam Petrochemical). (for receiving payments on behalf of Jam Petrochemical).
Asia Bank (for delivering from Moscow to Tehran of $13 (for delivering from Moscow to Tehran of $13 ~~mil ion~~million in U.S. bank notes paid to in U.S. bank notes paid to
August 29, 2014 August 29, 2014
representatives of the Iranian government). representatives of the Iranian government).
Five individuals and one company for helping Iran acquire U.S. banknotes: Five individuals and one company for helping Iran acquire U.S. banknotes: Hossein Zeidi,
December 30, 2014 December 30, 2014
Seyed Kamal Yasini, , Azizullah Qulandary, , Asadollah Seifi, , Teymour Ameri, and , and Belfast General
Trading. .
Anahita Nasirbeik—Asia Bank official (see above).—Asia Bank official (see above).

Table D-13. Entities Sanctioned under the Iran Freedom and Counter-Proliferation
Act (IFCA, P.L. 112-239)
Entity
Date Named
Goldentex FZE (UAE)
August 29, 2014 August 29, 2014
Zhuhai Zhenrong (China) for purchasing oil from Iran Zhuhai Zhenrong (China) for purchasing oil from Iran
July 22, 2019 July 22, 2019
Global Industrial and Engineering Supply Ltd. (China and Hong Kong) For transferring Global Industrial and Engineering Supply Ltd. (China and Hong Kong) For transferring
June 25, 2020 June 25, 2020
graphite to IRISL graphite to IRISL
China and Hong Kong Entities Supporting Islamic Republic of Iran Shipping
October 19, 2020 October 19, 2020
Lines (IRISL): Reach Holdings (Shanghai); Reach Shipping Lines; Delight Shipping Co., Ltd.; : Reach Holdings (Shanghai); Reach Shipping Lines; Delight Shipping Co., Ltd.;
Gracious Shipping Co. Ltd.; Noble Shipping Co. Ltd.: Supreme Shipping Co. Ltd; and officials Gracious Shipping Co. Ltd.; Noble Shipping Co. Ltd.: Supreme Shipping Co. Ltd; and officials
of these firms of these firms

Kaifeng Pingmei New Carbon Materials Technology Co.; IRISL subsidiary Hafez Darya Arya January 5, 2021 Shipping Co; and Majid Sajdeh for transferring graphite to Iran Congressional Research Service 85 Iran Sanctions Table D-14. Entities Designated as Human Rights Abusers under Executive Order
13628 (October 9, 2012, pursuant to ITRSHRA)
Entity
Date Named
Ali Fazli, deputy commander of the Basij; Reza Taghipour, Minister of Communications and Ali Fazli, deputy commander of the Basij; Reza Taghipour, Minister of Communications and
November 8, 2012 November 8, 2012
Information Technology; LEF Commander Moghaddam (see above); Center to Investigate Information Technology; LEF Commander Moghaddam (see above); Center to Investigate
Organized Crime (established by the IRGC to protect the government from cyberattacks; Organized Crime (established by the IRGC to protect the government from cyberattacks;
Press Supervisory Board, established in 1986 to issue licenses to publications and oversee Press Supervisory Board, established in 1986 to issue licenses to publications and oversee
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~~Iran Sanctions~~

~~Entity~~
~~Date Named~~
news agencies; Ministry of Culture and Islamic Guidance; Rasool Jalili, active in assisting the news agencies; Ministry of Culture and Islamic Guidance; Rasool Jalili, active in assisting the
government’s internet censorship activities; Anm Afzar Goster-e-Sharif, (censorship government’s internet censorship activities; Anm Afzar Goster-e-Sharif, (censorship
equipment); PekyAsa, another company owned by Jalili, to develop telecom software. equipment); PekyAsa, another company owned by Jalili, to develop telecom software.
Islamic Republic of Iran Broadcasting (IRIB) and Islamic Republic of Iran Broadcasting (IRIB) and ~~Ezzatol ah~~Ezzatollah Zarghami (director and head of Zarghami (director and head of
February 6, 2013 February 6, 2013
IRIB); Iranian Cyber Police (hacks email accounts of political activists); Iranian IRIB); Iranian Cyber Police (hacks email accounts of political activists); Iranian
Communications Regulatory Authority (filters Internet content); Iran Electronics Industries Communications Regulatory Authority (filters Internet content); Iran Electronics Industries
(producer of electronic systems and products including those for jamming, eavesdropping(producer of electronic systems and products including those for jamming, eavesdropping
Committee to Determine Instances of Criminal Content for engaging in censorship Committee to Determine Instances of Criminal Content for engaging in censorship
May 30, 2013 May 30, 2013
activities on/after June 12, 2009; Ofogh Saberin Engineering Development Company for activities on/after June 12, 2009; Ofogh Saberin Engineering Development Company for
providing services to the IRGC and Ministry of Communications to override Western providing services to the IRGC and Ministry of Communications to override Western
satellite communications. satellite communications.
Morteza Tamaddon for blocking cellphones of opposition leaders Mir Hosein Musavi and Morteza Tamaddon for blocking cellphones of opposition leaders Mir Hosein Musavi and
May 23, 2014 May 23, 2014
Mehdi Karrubi when Tamaddon was governor-general of Tehran Province in 2009. Mehdi Karrubi when Tamaddon was governor-general of Tehran Province in 2009.
Douran Software Technologies, for acting on behalf of the Committee to Determine Douran Software Technologies, for acting on behalf of the Committee to Determine
December 30, 2014 December 30, 2014
Instances of Criminal Content (see above). Instances of Criminal Content (see above).
Two entities that blocked social media sites and websites: Supreme Council for Cyberspace, January 12, 2018 Two entities that blocked social media sites and websites: Supreme Council for Cyberspace, January 12, 2018
and National Cyberspace Center and National Cyberspace Center
IRIB Director General Abdulali Ali-Asgari (see above); Abolhassan Firouzabadi (Secretary of IRIB Director General Abdulali Ali-Asgari (see above); Abolhassan Firouzabadi (Secretary of
May 30, 3018 May 30, 3018
the Supreme Council of Cyberspace); and Abdolsamad Khoramabadi (Secretary of the the Supreme Council of Cyberspace); and Abdolsamad Khoramabadi (Secretary of the
Committee to Determine Instances of Criminal Conduct (oversees Internet censorship) Committee to Determine Instances of Criminal Conduct (oversees Internet censorship)

Table D-15. Entities Designated under E.O. I3645 on Auto production, Rial Trading,
Precious Stones, and Support to NITC (June 3, 2013)
Entity
Date Named
Five entities/persons supporting NITC: Five entities/persons supporting NITC: Mid Oil Asia (Singapore); (Singapore); Singa Tankers (Singapore); (Singapore);
December 12, 2012 December 12, 2012
Siqiriya Maritime (Philippines); (Philippines); Ferland Company Limited (previously designated under other (previously designated under other
E.O.); E.O.); Vitaly Sokolenko (general manager of Ferland). (general manager of Ferland).
Three entities/persons for deceptive Iran oil dealings: Three entities/persons for deceptive Iran oil dealings: Saeed Al Aqili (co-owner of Al Aqili (co-owner of Al Aqili
April 29, 2014 April 29, 2014
Group LLC); Group LLC); Al Aqili Group LLC; ; Anwar Kamal Nizami (Dubai-based Pakistani facilitator, (Dubai-based Pakistani facilitator,
manages bank relations for affilates of Al Aqili and Al Aqili Group. Also works for manages bank relations for affilates of Al Aqili and Al Aqili Group. Also works for Sima
General Trading, sanctioned under E.O. 13599). , sanctioned under E.O. 13599).
Faylaca Petroleum (for obscuring the origin of Iranian sales of gas condensates); (for obscuring the origin of Iranian sales of gas condensates); Lissome
August 29, 2014 August 29, 2014
Marine Services LLC and six of its vessels (for supporting NITC with ship-to-ship transfers); and six of its vessels (for supporting NITC with ship-to-ship transfers);
Abdelhak Kaddouri (manages Iranian front companies on behalf of NICO); (manages Iranian front companies on behalf of NICO); Mussafer Polat (for (for
obscuring origin of Iran’s gas condensate sales); obscuring origin of Iran’s gas condensate sales); Seyedeh Hanje Seyed Nasser Seyyedi
(managing director of Faylaca).(managing director of Faylaca).

Congressional Research Service 86 Iran Sanctions Table D-16. Entities Designated under Executive Order 13581 on Transnational
Criminal Organizations (July 24, 2011)
Entity
Date Named
Four individuals/entities: Ajily Software Procurement Group, Andisheh Vesal Middle East Four individuals/entities: Ajily Software Procurement Group, Andisheh Vesal Middle East
July 18, 2017 July 18, 2017
Company, Mohammed Saeed Ajily, and Mohammed Reza Rezkhah. For stealing engineering Company, Mohammed Saeed Ajily, and Mohammed Reza Rezkhah. For stealing engineering
software programs from U.S. and other Western firms and selling them to Iranian military software programs from U.S. and other Western firms and selling them to Iranian military
and government entities. and government entities.
~~Congressional Research Service~~
87

~~Iran Sanctions~~

Table D-17. Entities Designated under Executive Order 13694 on Malicious ~~Cyber~~
Cyber Activities (April 1, 2015)
Entity
Date Named
Eight individuals/entities: ITSec Team, for 2011-12 distributed denial of services attacks on Eight individuals/entities: ITSec Team, for 2011-12 distributed denial of services attacks on
September 14, September 14,
U.S. banks, acting on behalf of the IRGC; and Ahmad Fathi, Amin Shokohi, and Hamid U.S. banks, acting on behalf of the IRGC; and Ahmad Fathi, Amin Shokohi, and Hamid
2017 2017
Firoozi (for working for or with ITSec). Four persons working for or with Mersad Co, an Firoozi (for working for or with ITSec). Four persons working for or with Mersad Co, an
IRGC-affiliate firm indicted in 2016 for computer disruption/botnet/malware activities in IRGC-affiliate firm indicted in 2016 for computer disruption/botnet/malware activities in
2012-13 targeting 24 U.S. financial sector companies: Sadegh Ahmazadegand; Sina Keissar; 2012-13 targeting 24 U.S. financial sector companies: Sadegh Ahmazadegand; Sina Keissar;
Omid Ghaffarinia; and Nader Saedi. Omid Ghaffarinia; and Nader Saedi.
Ten individuals and one entity, for theft of data from U.S. and third-country universities: Ten individuals and one entity, for theft of data from U.S. and third-country universities:
March 23, 2018 March 23, 2018
Mabna Institute, Gholamreza Rafatnejad, Ehsan Mohammadi, Seyed Ali Mirkarimi, Mostafa Mabna Institute, Gholamreza Rafatnejad, Ehsan Mohammadi, Seyed Ali Mirkarimi, Mostafa
Sadeghi, Sadeghi, ~~Saj ad~~Sajjad Tamasebi, Tamasebi, ~~Abdol ah~~Abdollah Karima, Abuzr Gohair Moqadam. Roozbeh Sabahi, Karima, Abuzr Gohair Moqadam. Roozbeh Sabahi,
Mohammed Reza Sabai, Behzad Mesri. Mohammed Reza Sabai, Behzad Mesri.
Ali Khorashadizadeh and Mohammad Ghorbaniyan. For helping exchange bitcoin digital Ali Khorashadizadeh and Mohammad Ghorbaniyan. For helping exchange bitcoin digital
November 28, November 28,
currency into Iranian rials on behalf of Iranian cyber actors involved with a “SamSam” currency into Iranian rials on behalf of Iranian cyber actors involved with a “SamSam”
2018 2018
ransomware scheme. ransomware scheme.

Table D-18. Entities Designated under E.O.13846 Reimposing Sanctions
(August 6, 2018)
Entity
Date Named
Ayandeh Bank (for materially assisting IRIB). Ayandeh Bank (for materially assisting IRIB).
November 5, 2018 November 5, 2018
Subsidiaries of China’s COSCO Shipping Corp. Ltd and persons for involvement September 25, September 25,
in oil shipments from Iran: China Concord Petroleum Ltd.; COSCO Shipping Tanker : China Concord Petroleum Ltd.; COSCO Shipping Tanker
2019 2019
(Dalian) Ltd.; COSCO Shipping Tanker (Dalian) Seaman and Ship Management Co. Ltd.; (Dalian) Ltd.; COSCO Shipping Tanker (Dalian) Seaman and Ship Management Co. Ltd.;
Kunlun Holding Co Ltd.; Kunlun Shipping Co. Ltd; Pegasus 88 Ltd.; Yi Li; Yu Hua Mao; Kunlun Holding Co Ltd.; Kunlun Shipping Co. Ltd; Pegasus 88 Ltd.; Yi Li; Yu Hua Mao;
Luqian Shen; Bin Xu; Yazhou Xu. Luqian Shen; Bin Xu; Yazhou Xu.
Under Section 7 of the E.O. (Human Rights related provision sanctioning persons who limit Under Section 7 of the E.O. (Human Rights related provision sanctioning persons who limit
December 19, 2019 December 19, 2019
freedom of expression in Iran): Abolghassem Salavati, Mohammad Moghisseh (judges freedom of expression in Iran): Abolghassem Salavati, Mohammad Moghisseh (judges
presiding over branches of the regime’s Revolutionary Court) presiding over branches of the regime’s Revolutionary Court)
Several petrochemical companies for brokering sales of Iranian oil and other
January 23, 2020 January 23, 2020
petroleum products to China and UAE: Sanctioned by Treasury: Triliance : Sanctioned by Treasury: Triliance
Petrochemical Co. Ltd (Hong Kong); Sage Energy HK Limited (Hong Kong); Peakview Petrochemical Co. Ltd (Hong Kong); Sage Energy HK Limited (Hong Kong); Peakview
Industry Co. Ltd (Shanghai); and Beneathco DMCC (Dubai). Sanctioned by State Dept.: Industry Co. Ltd (Shanghai); and Beneathco DMCC (Dubai). Sanctioned by State Dept.:
Shandong Qiwangda Petrochemical Co. Ltd (China); Jiaxing Industry Hong Kong Ltd.; Ali Shandong Qiwangda Petrochemical Co. Ltd (China); Jiaxing Industry Hong Kong Ltd.; Ali
Bayandarian; and Zhiqing Wang Bayandarian; and Zhiqing Wang
Entities involved in petrochemical transactions with Iran SPI International SPI International
March 18, 2020 March 18, 2020
Proprietary Ltd. and Main Street 1095 (South Africa). McFly Plastic HK Ltd.; Saturn Oasis Proprietary Ltd. and Main Street 1095 (South Africa). McFly Plastic HK Ltd.; Saturn Oasis
Co.; and Sea Charming Shipping Co. Ltd (Hong Kong). Dalian Golden Sun Import and Co.; and Sea Charming Shipping Co. Ltd (Hong Kong). Dalian Golden Sun Import and
Export Co. and Tianyin International Co. Ltd (Dalian, China). Aoxing Ship Management Ltd. Export Co. and Tianyin International Co. Ltd (Dalian, China). Aoxing Ship Management Ltd.
(Shanghai). Armed Forces Social Security Investment Company (Iran). Mohammad Hassan (Shanghai). Armed Forces Social Security Investment Company (Iran). Mohammad Hassan
Congressional Research Service 87 Iran Sanctions Entity Date Named Toulai (managing director of Armed Forces Social Security Investment Company); Hossein Toulai (managing director of Armed Forces Social Security Investment Company); Hossein
Tavakkoli; and Rea Ebadzadeh Semnani. Tavakkoli; and Rea Ebadzadeh Semnani.
UAE Companies facilitating Iran petrochemical and oil sales Petro Grand FZE; Petro Grand FZE;
March 19, 2020 March 19, 2020
Alphabet International DMCC; Swissol Trade DMCC; Alam Althrwa General Trading LLC; Alphabet International DMCC; Swissol Trade DMCC; Alam Althrwa General Trading LLC;
and Alwaneo LLC Co. and Alwaneo LLC Co.
For facilitating Iran petrochemical transactions: Triliance Petrochemical Co. Ltd : Triliance Petrochemical Co. Ltd
January 23, 2020 January 23, 2020
(Hong Kong); Sage Energy HK Limited (Hong Kong); Peakview Industry Co. Limited (Hong Kong); Sage Energy HK Limited (Hong Kong); Peakview Industry Co. Limited
(Shanghai); and Beneathco DMCC (UAE) (Shanghai); and Beneathco DMCC (UAE)
~~Congressional Research Service~~
88

~~Iran Sanctions~~

~~Entity~~
~~Date Named~~
For Enabling the Shipment and Sale of Iranian Petrochemicals: By Treasury:
September 3, 2020 September 3, 2020
Zagros Petrochemical Co. (Iran); Petrotech FZE (UAE); Jingho Technology Co. Ltd (Hong Zagros Petrochemical Co. (Iran); Petrotech FZE (UAE); Jingho Technology Co. Ltd (Hong
Kong) Dynapex Energy Ltd (Hong Kong); Trio Energy DMCC (UAE); Dinrin Ltd (Hong Kong) Dynapex Energy Ltd (Hong Kong); Trio Energy DMCC (UAE); Dinrin Ltd (Hong
Kong)Kong)
By State: Abadan Refining Co,; Zhihang Ship Management (China); New Fars International Abadan Refining Co,; Zhihang Ship Management (China); New Fars International
Logistics LLC (China); Sino Energy Shipping Ltd (China); Chemtrans Petrochemicals Trading Logistics LLC (China); Sino Energy Shipping Ltd (China); Chemtrans Petrochemicals Trading
LLC (UAE); and several Chines and Iranian employees of these firms LLC (UAE); and several Chines and Iranian employees of these firms
Entities Facilitating Iran’s export of Petrochemicals: Donghai International Ship December 16, 2020 Management Ltd (China); Petrochem South East Limited (China); Alpha Tech Trading FZE (UAE); Petroliance Trading FZE (UAE); Vietnam Gas and Chemicals Transportation Corporation (designated by State). Vietnam gas managing director Vo Ngoc Phung also designated by State.
Table D-19. Executive Order 13871 on Metals and Minerals (May 8, 2019)
Entity
Date Named
Pamchel Trading Beijing Ltd; Power Anchor Ltd (Seychelles); Hongyuan Marine Co.; Pamchel Trading Beijing Ltd; Power Anchor Ltd (Seychelles); Hongyuan Marine Co.;
January 10. 2020 January 10. 2020
Mobarakeh Steel Company (Iran, previously designated under E.O 13224); Saba Steel; Mobarakeh Steel Company (Iran, previously designated under E.O 13224); Saba Steel;
Hormozgan Steel Co.; Esfahan Steel Co.; Oxin Steel Co.; Khorasan Steel Co.; South Kaveh Hormozgan Steel Co.; Esfahan Steel Co.; Oxin Steel Co.; Khorasan Steel Co.; South Kaveh
Steel Co.; Iran Alloy Steel Co; Golgohar Mining and Industrial Co,; Chadormalu Mining and Steel Co.; Iran Alloy Steel Co; Golgohar Mining and Industrial Co,; Chadormalu Mining and
Industrial Co.; Arfa Iron and Steel Co.; Khouzestan Steel Co.; Iranian Ghadir Iron and Steel Industrial Co.; Arfa Iron and Steel Co.; Khouzestan Steel Co.; Iranian Ghadir Iron and Steel
Co.; Reputable Trading Source LLC (Oman); Iran Aluminum Co.; Al Mahdi Aluminum Co.; Co.; Reputable Trading Source LLC (Oman); Iran Aluminum Co.; Al Mahdi Aluminum Co.;
National Iranian Copper Industries; and Khalagh Tadbir Pars Co. National Iranian Copper Industries; and Khalagh Tadbir Pars Co.
Affiliates of Iran’s Mobarakeh Steel Company: Iran—Metil Steel; South Aluminum : Iran—Metil Steel; South Aluminum
June 25, 2020 June 25, 2020
Company; Sirjan Jahan Steel Complex; and Iran Central Iron Ore Company. Others: Tara Company; Sirjan Jahan Steel Complex; and Iran Central Iron Ore Company. Others: Tara
Steel GmbH (Germany); UAESteel GmbH (Germany); UAE - –Pacific Steel FZE; Better Future General Trading Co LLC; Pacific Steel FZE; Better Future General Trading Co LLC;
and and Tuka Metal Trading DMCC. Suppliers of Graphite Electrodes and Iranian producers. Kaifeng Pingmei New Carbon Materials Technology Co., Ltd. (China); Pasargad Steel Complex; Gilan Steel Complex Co.; Middle East Mines and Mineral Industries Development Holding Co.; Sirjan Iranian Steel; Zarand Iranian Steel Co,; GMI P:ojects Hamburg GmbH (Germany); World Mining Industry Co.; Khazar Steel Co.; Vian Steel Complex; South Rouhina Steel Complex; Yazd Industrial Steel Rolling Mill; West Alborz Steel Complex; Efarayen Industrial Complex; Bonab Steel Industry Complex~~Tuka Metal Trading DMCC~~. .

Table D-20. Entities Designated as Gross Human Rights Violators under Section
7031(c) of Foreign Aid Appropriations
Entity
Date Named
Two Iranian prisons: Great Tehran Penitentiary; Qarchak Prison Two Iranian prisons: Great Tehran Penitentiary; Qarchak Prison
December 5, 2019 December 5, 2019
Congressional Research Service 88 Iran Sanctions Entity Date Named Hassan Shahvarpour, IRGC commander of Vali Asr unit Hassan Shahvarpour, IRGC commander of Vali Asr unit
January 18, 2020 January 18, 2020
Abdolreza Rahmani Fazli (Interior Minister), and Ali Fallahian (Intelligence head during Abdolreza Rahmani Fazli (Interior Minister), and Ali Fallahian (Intelligence head during
May 20, 2020 May 20, 2020
1989-1997) 1989-1997)
IRGC Brig. Gen. Heidar IRGC Brig. Gen. Heidar ~~Abasszadeh~~Abbaszadeh, IRGC Colonel Reza Papi – for involvement in the , IRGC Colonel Reza Papi – for involvement in the ~~kil ing~~ November 18, November 18,
killing of protesters in the town of Mahshar in November 2019 of protesters in the town of Mahshar in November 2019
2020 2020

Table D-21. Entities Designated under E.O. 13876 on the Supreme Leader and his
Office (June 24, 2019)
Entity
Date Named
Foreign Minister Mohammad Javad Zarif Foreign Minister Mohammad Javad Zarif
July 31, 2019 July 31, 2019
~~Congressional Research Service~~
89

~~Iran Sanctions~~

~~Entity~~
~~Date Named~~
Ten High-Ranking Officials/Personalities and One Major Entity: Ebrahim Raisi (head of the Ten High-Ranking Officials/Personalities and One Major Entity: Ebrahim Raisi (head of the
November 4, 2019 November 4, 2019
judiciary); Mojtaba Khamene’i (second son of the Supreme Leader, and liaison with the judiciary); Mojtaba Khamene’i (second son of the Supreme Leader, and liaison with the
IRGC-QF and Basij); Mohammad Mohammadi Golpayegani (chief of staff to the Supreme IRGC-QF and Basij); Mohammad Mohammadi Golpayegani (chief of staff to the Supreme
Leader); Vahid Haghanian (top aide to the Supreme Leader); Ali Akbar Velayati (former Leader); Vahid Haghanian (top aide to the Supreme Leader); Ali Akbar Velayati (former
Foreign Minister and top foreign policy adviser to the Supreme Leader); Gholam-Ali Foreign Minister and top foreign policy adviser to the Supreme Leader); Gholam-Ali
Hadad-Adel (former Majles Speaker, adviser to the Supreme Leader); Mohammad Bagheri Hadad-Adel (former Majles Speaker, adviser to the Supreme Leader); Mohammad Bagheri
(head of the Armed Forces General Staff); Iran Armed Forces General Staff; Hossein (head of the Armed Forces General Staff); Iran Armed Forces General Staff; Hossein
Dehghan (military aide to the Supreme Leader, former Defense Minister, and former Dehghan (military aide to the Supreme Leader, former Defense Minister, and former
commander of the IRGC-QF contingent in Lebanon); Gholam Ali Rashid (head of Khatem commander of the IRGC-QF contingent in Lebanon); Gholam Ali Rashid (head of Khatem
ol-Anbiya Central Headquarters, a major military headquarters). ol-Anbiya Central Headquarters, a major military headquarters).
Ali Shamkhani—Secretary General of Iran Supreme National Security Council; Ali Shamkhani—Secretary General of Iran Supreme National Security Council;
January 10, 2020 January 10, 2020
Gholamreza Soleimani—commander of the Basij; Mohsen Reza’i—Expediency Council Gholamreza Soleimani—commander of the Basij; Mohsen Reza’i—Expediency Council
member and IRGC commander-in-chief 1981-1997; Mohammad Reza Naqdi—former member and IRGC commander-in-chief 1981-1997; Mohammad Reza Naqdi—former
Basij commander; Mohammad Reza Ashtiani—deputy chief of staff of the Armed Forces; Basij commander; Mohammad Reza Ashtiani—deputy chief of staff of the Armed Forces;
IRGC Brig. Gen. Ali IRGC Brig. Gen. Ali ~~Abdol ahi~~Abdollahi—coordination deputy for the Armed Forces General Staff; —coordination deputy for the Armed Forces General Staff;
Ali Asghar Hejazi—chief of Supreme Leader security; Mohsen Qomi—advisor to the Ali Asghar Hejazi—chief of Supreme Leader security; Mohsen Qomi—advisor to the
Supreme Leader on international communications Supreme Leader on international communications
Members of Council of Guardians and Elections Supervision Committee (for (for
February 20, 2020 February 20, 2020
manipulating Iran’s parliamentary elections): Ahmad Jannati (head of the Council of manipulating Iran’s parliamentary elections): Ahmad Jannati (head of the Council of
Guardians); Mohammad Yazdi; Siamak Rahpeyk; Abbas Ali Kadkhodaie (Council speaker); Guardians); Mohammad Yazdi; Siamak Rahpeyk; Abbas Ali Kadkhodaie (Council speaker);
and Mohammad Hasan Sadeghi Moghadam and Mohammad Hasan Sadeghi Moghadam
Bonyad Mostazafan economic conglomerate and affiliates: Bonyad Mostazafan; its Bonyad Mostazafan; its
November 18, 2020 November 18, 2020
president (and IRGC conduit) Parviz Fattah; several Bonyad board members; Bonyad president (and IRGC conduit) Parviz Fattah; several Bonyad board members; Bonyad
affiliate companies – Sina Energy Development Co (SEDCO), SEDCO subordinates in the affiliate companies – Sina Energy Development Co (SEDCO), SEDCO subordinates in the
energy energy ~~dril ing~~drilling and financial sector, Behran Oil, Kaveh Pars Mining Industries Development and financial sector, Behran Oil, Kaveh Pars Mining Industries Development
Co and steel, aluminum, and financial subordinates (including Turkey-based Turira Co), Co and steel, aluminum, and financial subordinates (including Turkey-based Turira Co),
Bank Sina and affiliates, Omran va Maskan Iran Company and Paya Saman Pars Co, Persian Bank Sina and affiliates, Omran va Maskan Iran Company and Paya Saman Pars Co, Persian
Tourism and Recreational Centers Co. and subordinates (ex Bonyad Shipping Agencies Tourism and Recreational Centers Co. and subordinates (ex Bonyad Shipping Agencies
Co), Sina Paya Sanat Development Co and subordinates. Other subsidiaries: Iran Co), Sina Paya Sanat Development Co and subordinates. Other subsidiaries: Iran
Electronic Development Co, Rah Negar Middle East Pars Co and Peyvand Tejarat Atieh Electronic Development Co, Rah Negar Middle East Pars Co and Peyvand Tejarat Atieh
Iranian Co; Iranian Co;

Congressional Research Service 89 Iran Sanctions Table D-22. Executive Order 13818 Implementing the Global Magnitsky Act
(December 20, 2017)
Entity
Date Named
Iran-backed Iraqi militia figures: Qais al-Khazali (head of Asa’ib Ahl Al Haq Iran-backed Iraqi militia figures: Qais al-Khazali (head of Asa’ib Ahl Al Haq
December 6, 2019 December 6, 2019
militia); Laith al-Khazali; Husayn Falih al-Lami militia); Laith al-Khazali; Husayn Falih al-Lami Falih al-Fayyadh. Iraq head of the Popular Mobilization Committee, for serious January 8, 2021 human rights abuses to suppress protests, reportedly with IRGC-QF support.

Table D-23. Executive Order 13902 on the Construction, Textiles, and other Sectors
(January 10. 2020)
Entity
Date Named
Iranian Banks not Iranian Banks not ~~Sanctioned~~sanctioned under other under other ~~Orders~~orders: Amin Investment Bank; : Amin Investment Bank;
October 8, 2020 October 8, 2020
Bank Keshavarzi Iran; Bank Maskan; Bank Refah Kargaran; Banke-e Shahr; Bank Keshavarzi Iran; Bank Maskan; Bank Refah Kargaran; Banke-e Shahr;
Eghtesad Novin Bank; Gharzolhasaneh Resalat Bank; Hekmat Iranian Bank; Eghtesad Novin Bank; Gharzolhasaneh Resalat Bank; Hekmat Iranian Bank;
Iran Zamin Bank; Islamic Regional Cooperation Bank; Karafarin Bank; Iran Zamin Bank; Islamic Regional Cooperation Bank; Karafarin Bank;
Khavarmianeh Bank; Mehr Iran Credit Union Bank; Pasargad Bank; Saman Khavarmianeh Bank; Mehr Iran Credit Union Bank; Pasargad Bank; Saman
Bank; Sarmayeh Bank; Tosee Taavon Bank; Tourism BankBank; Sarmayeh Bank; Tosee Taavon Bank; Tourism Bank
~~Congressional Research Service~~
90

~~Iran Sanctions~~

Table D-24. Executive Order 13949 on Conventional Arms to Iran (September 21,
2020)
Entity
Date Named
Iran Ministry of Defense and Armed Forces Logistics (MODAFL); Defense Iran Ministry of Defense and Armed Forces Logistics (MODAFL); Defense
September 21, 2020 September 21, 2020
Industries Organization; Nicholas Maduro Industries Organization; Nicholas Maduro Marine Industries Organization, Aerospace Industries Organization, and Iran January 15, 2021 Aviation Industries Organization (all Iran-based) for activities to transfer arms and materiel to regional armed groups

Table D-25. Entities Sanctions Under CAATSA
Entity
Date Named
Pursuant to CAATSA Section 106 on human rights abuses, for gross violations Pursuant to CAATSA Section 106 on human rights abuses, for gross violations
September 24, 2020 September 24, 2020
of human rights: Various Iranian judges and prison entities of human rights: Various Iranian judges and prison entities - —Judge Seyyed Judge Seyyed
Mahmoud Sadati; Judge Mohammad Soltani; Branch 1 of the Revolutionary Mahmoud Sadati; Judge Mohammad Soltani; Branch 1 of the Revolutionary
Court of Shiraz; Adelabad, Orumiyeh, and Vakilabad Prisons Court of Shiraz; Adelabad, Orumiyeh, and Vakilabad Prisons

Author Information

Kenneth Katzman Kenneth Katzman

Specialist in Middle Eastern Affairs Specialist in Middle Eastern Affairs

Congressional Research Service 90 Iran Sanctions

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