Iran Sanctions
Kenneth Katzman
Specialist in Middle Eastern Affairs
August 18, 2009
Congressional Research Service
7-5700
www.crs.gov
RS20871
CRS Report for Congress
P
repared for Members and Committees of Congress

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The Iran Sanctions Act (ISA)

Summary
Iran is subject to a wide range of U.S. sanctions, restricting trade with, investment, and U.S.
foreign aid to Iran, and requiring the United States to vote against international lending to Iran.
Several laws and Executive Orders authorize sanctions against foreign companies that do
business with Iran, as part of an effort to persuade foreign firms to choose between the Iranian
market and the much larger U.S. market.
A formal U.S. effort to curb international energy investment in Iran began in 1996 with the Iran
Sanctions Act (ISA). No firms have been sanctioned under it and the precise effects of that law on
energy investment in Iran—as separate from other factors affecting international firms’ decisions
on whether to invest in Iran—has been unclear. While international pressure on Iran to curb its
nuclear program has increased the hesitation of many major foreign firms to invest in Iran’s
energy sector, hindering Iran’s efforts to expand oil production beyond 4.1 million barrels per day,
some firms continue to see opportunity in Iran. This particularly appears to be the case for
companies in Asia that appear eager to fill the void left by major European and American firms
and to line up steady supplies of Iranian oil and gas.
ISA was first passed at a time of tightening U.S. sanctions on Iran. Most notable was a 1995 ban
on U.S. trade with and investment in Iran. That ban has since been modified slightly to allow for
some bilateral trade in luxury and humanitarian-related goods. Foreign subsidiaries of U.S. firms
remain generally exempt from the trade ban since they are under the laws of the countries where
they are incorporated. Since 1995, several laws and regulations that seek to pressure Iran’s
economy, curb Iran’s support for militant groups, and curtail supplies to Iran of advanced
technology have been enacted. In the United States, there has been movement on the part of some
U.S. states to divest from firms that do business with Iran, even if such trade is legal.
In the 111th Congress, as many in Congress express concern about the reticence of U.S. allies, of
Russia, and of China, to impose very strict economic sanctions on Iran, several bills would add
sanctions on Iran. For example, H.R. 2194, H.R. 1985, H.R. 1208, and S. 908 would include as
ISA violations: selling refined gasoline to Iran; providing shipping insurance or other services to
deliver gasoline to Iran; or supplying equipment to or performing the construction of oil refineries
in Iran. H.R. 2192 and S. 908 would also expand the menu of available sanctions against
violators. H.R. 1208 would further restrict trade with Iran.
For more on Iran, see CRS Report RL32048, Iran: U.S. Concerns and Policy Responses, by
Kenneth Katzman.

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Contents
Background of the Iran Sanctions Act (ISA) ................................................................................ 1
Key Provisions...................................................................................................................... 1
“Triggers” and Available Sanctions ................................................................................. 2
Waiver and Termination Authority................................................................................... 2
Iran Freedom Support Act Amendments .......................................................................... 3
Effectiveness and Ongoing Challenges .................................................................................. 3
Energy Routes and Refinery Investment ................................................................................ 5
Refinery Construction ..................................................................................................... 6
Significant Purchase Agreements .......................................................................................... 6
Efforts in the 110th and 111th Congress to Expand ISA Application ........................................ 6
Legislation in the 111th Congress ........................................................................................... 7
Relationships to Other U.S. Sanctions ......................................................................................... 9
Ban on U.S. Trade and Investment With Iran....................................................................... 10
Treasury Department “Targeted Financial Measures” .......................................................... 11
Terrorism-Related Sanctions ............................................................................................... 13
Executive Order 13224 ................................................................................................. 14
Proliferation-Related Sanctions ........................................................................................... 14
Relations to International Sanctions..................................................................................... 15
Efforts to Promote Divestment ............................................................................................ 16
Blocked Iranian Property and Assets ................................................................................... 16

Tables
Table 1. Post-1999 Major Investments in Iran’s Energy Sector..................................................... 8
Table 2. Entities Sanctioned Under U.N. Resolutions and U.S. Laws and Executive
Orders.................................................................................................................................... 17

Contacts
Author Contact Information ...................................................................................................... 22

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Background of the Iran Sanctions Act (ISA)
The Iran Sanctions Act (ISA) is one among many U.S. sanctions in place against Iran. However,
it has attracted substantial attention because it authorizes penalties against foreign firms. The
parent countries of those firms have tended to object to sanctions such as ISA, even though these
countries might share the U.S. goal of containing Iran. American firms are restricted from trading
with or investing in Iran under U.S. measures.
Originally called the Iran-Libya Sanctions Act (ILSA), it was enacted to complement other
measures—particularly Executive Order 12959 of May 6, 1995, that banned U.S. trade with and
investment in Iran—intended to deny Iran the resources to further its nuclear program and to
support terrorist organizations such as Hizbollah, Hamas, and Palestine Islamic Jihad. Iran’s
petroleum sector generates about 20% of Iran’s GDP, but its onshore oil fields and oil industry
infrastructure are aging and need substantial investment. Its large natural gas resources (940
trillion cubic feet, exceeded only by Russia) were undeveloped when ISA was first enacted. Iran
has 136.3 billion barrels of proven oil reserves, the third largest after Saudi Arabia and Canada.
In 1995 and 1996, U.S. allies did not join the United States in enacting trade sanctions against
Iran, and the Clinton Administration and Congress believed that it might be necessary for the
United States to try to deter their investment in Iran. The opportunity to do so came in November
1995, when Iran opened its energy sector to foreign investment. To accommodate its ideology to
retain control of its national resources, Iran used a “buy-back” investment program in which
foreign firms recoup their investments from the proceeds of oil and gas discoveries but do not
receive equity. With input from the Administration, on September 8, 1995, Senator Alfonse
D’Amato introduced the “Iran Foreign Oil Sanctions Act” to sanction foreign firms’ exports to
Iran of energy technology. A revised version instead sanctioning investment in Iran’s energy
sector passed the Senate on December 18, 1995 (voice vote). On December 20, 1995, the Senate
passed a version applying the legislation to Libya as well, which was refusing to yield for trial the
two intelligence agents suspected in the December 21, 1988, bombing of Pan Am 103. The House
passed H.R. 3107, on June 19, 1996 (415-0), and then concurred on a slightly different Senate
version adopted on July 16, 1996 (unanimous consent). It was signed on August 5, 1996 (P.L.
104-172).
Key Provisions
ISA consists of a number of “triggers”—activity which, if carried out, would be considered
violations of ISA and could cause a firm or entity to be sanctioned in accordance with ISA’s
provisions. ISA provides a number of different sanctions that the President could impose that
would harm a foreign firm’s business opportunities in the United States. ISA does not, and
probably could not legally or practically, compel any foreign government to take any specific
action against one of its firms.
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“Triggers” and Available Sanctions
ISA requires the President to sanction companies (entities, persons) that make an “investment” of
more than $20 million in one year in Iran’s energy sector,1 or that sell to Iran weapons of mass
destruction (WMD) technology or “destabilizing numbers and types” of advanced conventional
weapons.2 ISA is primarily targeting foreign firms, because American firms are already prohibited
from investing in Iran under the 1995 trade and investment ban discussed earlier.
Once a firm is determined to be a violator, ISA requires the imposition of two of a menu of six
sanctions on that firm. The available sanctions the President can select from (Section 6) include:
(1) denial of Export-Import Bank loans, credits, or credit guarantees for U.S. exports to the
sanctioned entity; (2) denial of licenses for the U.S. export of military or militarily-useful
technology; (3) denial of U.S. bank loans exceeding $10 million in one year; (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); (5) prohibition on U.S. government procurement from the entity; and (6) restriction on
imports from the entity, in accordance with the International Emergency Economic Powers Act
(IEEPA, 50 U.S.C. 1701).
Waiver and Termination Authority
The President has the authority under ISA to waive the sanctions on Iran if he certifies that doing
so is important to the U.S. national interest (Section 9(c)). There was also waiver authority in the
original version of ISA if the parent country of the violating firm joined a sanctions regime
against Iran, but this waiver provision was made inapplicable by subsequent legislation. ISA
application to Iran would terminate if Iran is determined by the Administration to have ceased its
efforts to acquire WMD and is removed from the U.S. list of state sponsors of terrorism, and no
longer “poses a significant threat” to U.S. national security and U.S. allies.3 Application to Libya
terminated when the President determined on April 23, 2004, that Libya had fulfilled the
requirements of all U.N. resolutions on Pan Am 103.
Traditionally reticent to impose economic sanctions, the European Union opposed ISA as an
extraterritorial application of U.S. law. In April 1997, the United States and the EU agreed to
avoid a trade confrontation in the World Trade Organization (WTO) over it and a separate Cuba
sanctions law, (P.L. 104-114). The agreement contributed to a May 18, 1998, decision by the
Clinton Administration to waive ISA sanctions (“national interest”—Section 9(c) waiver) on the
first project determined to be in violation—a $2 billion4 contract (September 1997) for Total SA

1 The definition of “investment” in ISA (Section 14 (9)) includes not only equity and royalty arrangements (including
additions to existing investment, as added by P.L. 107-24) but any contract that includes “responsibility for the
development of petroleum resources” of Iran, interpreted to include pipelines to or through Iran. The definition
excludes sales of technology, goods, or services for such projects, and excludes financing of such purchases. For Libya,
the threshold was $40 million, and sanctionable activity included export to Libya of technology banned by Pan Am
103-related Security Council Resolutions 748 (March 31, 1992) and 883 (November 11, 1993). For Iran, the threshhold
dropped to $20 million, from $40 million, one year after enactment, when U.S. allies did not join a multilateral
sanctions regime against Iran.
2 This latter “trigger” was added by P.L. 109-293.
3 This latter termination requirement added by P.L. 109-293
4 Dollar figures for investments in Iran represent public estimates of the amounts investing firms are expected to spend
over the life of a project, which might in some cases be several decades.
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of France and its partners, Gazprom of Russia and Petronas of Malaysia to develop phases 2 and
3 of the 25-phase South Pars gas field. The EU pledged to increase cooperation with the United
States on non-proliferation and counter-terrorism, and the Administration indicated future
investments by EU firms in Iran would not be sanctioned.
ISA was to sunset on August 5, 2001, in a climate of lessening tensions with Iran and Libya.
During 1999 and 2000, the Clinton Administration had eased the trade ban on Iran somewhat to
try to engage the relatively moderate Iranian President Mohammad Khatemi. In 1999, Libya
yielded for trial the Pan Am 103 suspects. However, some maintained that both countries would
view its expiration as a concession, and renewal legislation was enacted (P.L. 107-24, August 3,
2001). This law required an Administration report on ISA’s effectiveness within 24 to 30 months
of enactment; that report was submitted to Congress in January 2004 and did not recommend that
ISA be repealed.
Iran Freedom Support Act Amendments
In addition to the amendments to ISA referred to above, P.L. 109-293, the “Iran Freedom and
Support Act” (H.R. 6198) amended ISA by: (1) calling for, but not requiring, a 180-day time limit
for a violation determination; (2) recommending against U.S. nuclear agreements with countries
that supply nuclear technology to Iran; (3) expanding provisions of the USA Patriot Act (P.L. 107-
56) to curb money-laundering for use to further WMD programs; (4) extending ISA until
December 31, 2011; and (5) formally dropping Libya and changing the name to the Iran
Sanctions Act.
Earlier versions of the Iran Freedom and Support Act in the 109th Congress (H.R. 282, S. 333)
were viewed as too restrictive of Administration prerogatives. Among the provisions of these bills
not ultimately adopted included: setting a 90-day time limit for the Administration to determine
whether an investment is a violation (there is no time limit in the original law); cutting U.S.
foreign assistance to countries whose companies violate ISA; and, applying the U.S. trade ban on
Iran to foreign subsidiaries of U.S. companies.
Effectiveness and Ongoing Challenges
The Bush Administration maintained that, even without actually imposing ISA sanctions, the
threat of sanctions—coupled with Iran’s reputedly difficult negotiating behavior, and
compounded by Iran’s growing isolation because of its nuclear program—slowed Iran’s energy
development. The Obama Administration has not altered any U.S. sanctions on Iran—and it
renewed for another year the U.S. trade and investment ban on Iran (Executive Order 12959) in
March 2009. However, the Obama Administration’s overall policy approach contrasts with the
Bush Administration approach by actively attempting to engage Iran in negotiations on the
nuclear issue, rather than focusing only on increasing sanctions on Iran. That approach has been
altered slightly in the context of the Iranian dispute over its June 12, 2009 elections; the
Administration approach now envisions an early return to formulating “crippling” new U.N.
sanctions if Iran does not return to multilateral nuclear talks by September 24, 2009.
As shown in the table below, several foreign investment agreements have been agreed with Iran
since the 1998 Total consortium waiver, but others have been long stalled. Some investors, such
as major European firms Repsol, Royal Dutch Shell, and Total, have announced pullouts,
declined further investment, or resold their investments to other companies. On July 12, 2008,
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Total and Petronas, the original South Pars investors, pulled out of a deal to develop a liquified
natural gas (LNG) export capability at Phase 11 of South Pars, saying that investing in Iran at a
time of growing international pressure over its nuclear program is “too risky.” Also in 2008,
Japan significantly reduced its participation in the development of Iran’s large Azadegan field.
Some of the void has been filled, at least partly, by Asian firms such as those of China and
Malaysia. However, some of those agreements are being implemented only slowly and these
companies are perceived not as technically capable as those that have withdrawn from Iran.
These trends have constrained Iran’s energy sector significantly; Iran’s deputy Oil Minister said
in November 2008 that Iran needs about $145 billion in new investment over the next ten years in
order to build a thriving energy sector. As a result of sanctions and the overall climate of
international isolation of Iran, its oil production has not grown—it remains at about 4.1 million
barrels per day (mbd)—although it has not fallen either.
Some observers maintain that, over and above the threat of ISA sanctions and the international
pressure on Iran, it is Iran’s negotiating behavior that has slowed international investment in
Iran’s energy sector. Some international executives that have negotiated with Iran say Iran insists
on deals that leave little profit, and that Iran frequently seeks to renegotiate provisions of a
contract after it is ratified.
Some analyses, including by the National Academy of Sciences, say that, partly because of
growing domestic consumption, Iranian oil exports are declining to the point where Iran might
have negligible exports of oil by 2015.5 Others maintain that Iran’s gas sector can more than
compensate for declining oil exports, although it needs gas to re-inject into its oil fields and
remains a relatively minor gas exporter. It exports about 3.6 trillion cubic feet of gas, primarily to
Turkey. A GAO study of December 2007, (GAO-08-58), contains a chart of post-2003
investments in Iran’s energy sector, totaling over $20 billion in investment, although the chart
includes petrochemical and refinery projects, as well as projects that do not exceed the $20
million in one year threshold for ISA sanctionability.
Since the Total/Petronas/Gazprom project in 1998, no projects have been determined as violations
of ISA. Some of the projects listed in the GAO report and in the table below may be under review
by the State Department (Bureau of Economic Affairs), but no publication of such deals has been
placed in the Federal Register (requirement of Section 5e of ISA), and no determinations of
violation have been announced. State Department reports to Congress on ISA, required every six
months, have routinely stated that U.S. diplomats raise U.S. policy concerns about Iran with
investing companies and their parent countries. However, these reports do not specifically state
which foreign companies are being investigated for ISA violations. Undersecretary of State for
Political Affairs William Burns testified on July 9, 2008 (House Foreign Affairs Committee) that
the Statoil project (listed in the table) is under review for ISA sanctions; he did not mention any
of the other projects, and no other specific projects have been named since. Nor has there been a
formal State Department determination on Statoil since that statement.
Some Members of Congress believe that ISA would have been even more effective if successive
Administrations had imposed sanctions, and have expressed frustration that the Executive branch
has not imposed ISA sanctions. Section 7043 of P.L. 111-8, the FY09 omnibus appropriation,

5 Stern, Roger. “The Iranian Petroleum Crisis and United States National Security,” Proceedings of the National
Academy of Sciences of the United States of America. December 26, 2006.
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requires, within 180 days, an Administration report on U.S. sanctions, including which companies
are believed to be violators, and what the Administration is doing to enforce sanctions on Iran.
The provision appears to apply primarily to ISA.
Energy Routes and Refinery Investment
ISA’s definition of “investment” has been interpreted by successive Administrations to include
construction of energy routes to or through Iran—because such routes help Iran develop its
petroleum resources. The Clinton and Bush Administrations used the threat of ISA sanctions to
deter oil routes involving Iran and thereby successfully promoted an alternate route from
Azerbaijan (Baku) to Turkey (Ceyhan). The route became operational in 2005. No sanctions were
imposed on a 1997 project viewed as necessary to U.S. ally Turkey—an Iran-Turkey natural gas
pipeline in which each constructed the pipeline on its side of their border. The State Department
did not impose ISA sanctions on the grounds that Turkey would be importing gas originating in
Turkmenistan, not Iran. However, direct Iranian gas exports to Turkey began in 2001, and, as
shown in the table, in July 2007, a preliminary agreement was reached to build a second Iran-
Turkey pipeline, through which Iranian gas would also flow to Europe. That agreement was not
finalized during Iranian President Mahmoud Ahmadinejad’s visit to Turkey in August 2008
because of Turkish commercial concerns but the deal remains under active discussion. On
February 23, 2009, Iranian newspapers said Iran had formed a joint venture with a Turkish firm to
export 35 billion cubic meters of gas per year to Europe; 50% of the venture would be owned by
the National Iranian Gas Export Company (NIGEC).
Another pending deal is the construction of a gas pipeline from Iran to India, through Pakistan
(IPI pipeline). The three governments have stated they are committed to the $7 billion project,
which would take about three years to complete, but India did not sign a deal “finalization” that
was signed by Iran and Pakistan on November 11, 2007. India had re-entered discussions on the
project following Iranian President Mahmoud Ahmadinejad’s visit to India in April 2008, which
also resulted in Indian firms’ winning preliminary Iranian approval to take equity stakes in the
Azadegan oil field project and South Pars gas field Phase 12. India did not attend further talks on
the project in September 2008, raising continued concerns on security of the pipeline, the location
at which the gas would be officially transferred to India, pricing of the gas, tariffs, and the source
in Iran of the gas to be sold. Perhaps to address some of those concerns, but also perhaps to move
forward whether or not India joins the project, in January 2009 Iran and Pakistan amended the
proposed pricing formula for the exported gas to reflect new energy market conditions. During
the Bush Administration, Secretary of State Rice, on several occasions “expressed U.S. concern”
about the pipeline deal or have called it “unacceptable,” but no U.S. official has stated outright
that it would be sanctioned.
Iran might also be exploring other export routes for its gas. A potential project involving Iran is
the Nabucco pipeline project, which would transport Iranian gas to western Europe. Iran, Turkey,
and Austria reportedly are negotiating on that project. The Bush Administration did not support
Iran’s participation in the project and the Obama Administration apparently takes the same view,
even though the project might make Europe less dependent on Russian gas supplies. Iran’s
Energy Minister Gholam-Hossein Nozari said on April 2, 2009, that Iran is considering
negotiating a gas export route—the “Persian Pipeline”—that would send gas to Europe via Iraq,
Syria, and the Mediterranean Sea.
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Refinery Construction
Construction of oil refineries or petrochemical plants in Iran—included in the referenced GAO
report—might also constitute sanctionable projects because they might, according to ISA’s
definition of investment: “include responsibility for the development of petroleum resources
located in Iran...”would benefit Iran’s energy sector. Iran has plans to build or expand, possibly
with foreign investment, at least eight refineries in an effort to ease gasoline imports that supply
about 25% - 30% of Iran’s needs. According to some experts, Iran’s institution of gasoline
rationing in Iran in June 2007 reduced this dependency on gasoline imports from the 40%
previously.
It is not clear whether or not Iranian investments in energy projects in other countries, such as
Iranian investment to help build five oil refineries in Asia (China, Indonesia, Malaysia, and
Singapore) and in Syria, reported in June 2007, would constitute sanctionable investment under
ISA.
Significant Purchase Agreements
Other major energy deals with Iran are considered a blow to European solidarity, but would not
appear to constitute violations of ISA. In March 2008, Switzerland’s EGL utility agreed to buy
194 trillion cubic feet per year of Iranian gas for 25 years, through a Trans-Adriatic Pipeline
(TAP) to be built by 2010, a deal valued at least $15 billion. The United States criticized the deal
as sending the “wrong message” to Iran. However, as testified by Under Secretary of State Burns
on July 9, 2008, the deal appears to involve only purchase of Iranian gas, not exploration, and
likely does not violate ISA. In August 2008, Germany’s Steiner-Prematechnik-Gastec Co. agreed
to apply its method of turning gas into liquid fuel at three Iranian plants. In early October 2008,
Iran agreed to export 1 billion cu.ft./day of gas to Oman, via a pipeline to be built that would end
at Oman’s LNG export terminal facilities.
Sales of gasoline to Iran, which imports about 30% of its gasoline, are not currently sanctionable
under ISA under widely accepted definitions of ISA violations.
Efforts in the 110th and 111th Congress to Expand ISA Application
In the 110th Congress, several bills contained numerous provisions that would have further
amended ISA, but they were not adopted. H.R. 1400, which passed the House on September 25,
2007 (397-16), would have removed the Administration’s ability to waive ISA sanctions under
Section 9(c), national interest grounds, but it would not have imposed on the Administration a
time limit to determine whether a project is sanctionable.
That bill and several others—including S. 970, S. 3227, S. 3445, H.R. 957 (passed the House on
July 31, 2007), and H.R. 7112 (which passed the House on September 26, 2008)— would have:
(1) expanded the definition of sanctionable entities to official credit guarantee agencies, such as
France’s COFACE and Germany’s Hermes, and to financial institutions and insurers generally;
and (2) made investment to develop a liquified natural gas (LNG) sector in Iran a sanctionable
violation. Iran has no LNG export terminals, in part because the technology for such terminals is
patented by U.S. firms and unavailable for sale to Iran.
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Among related bills in the 110th Congress, H.R. 2880 would have made sales to Iran of refined
petroleum resources a violation of ISA, although some believe that a sanction such as this would
only be effective if it applied to all countries under a U.N. Security Council resolution rather than
a unilateral U.S. sanction. H.R. 2347, (passed the House on July 31, 2007), would protect from
lawsuits fund managers that divest from firms that make ISA-sanctionable investments. (A
version of this bill, H.R. 1327, has been introduced in the 111th Congress.)
In early 2009, there were some indications that congressional sentiment had some effect on
foreign firms, even without enactment of significant ISA amendment in the 110th Congress. In
January 2009, Reliance Industries Ltd of India said it would cease new sales of refined gasoline
to Iran after completing existing contracts that expired December 31, 2008. The Reliance decision
came after several Members of Congress urged the Exim Bank of the United States to suspend
assistance to Reliance, on the grounds that it was assisting Iran’s economy with the gas sales. The
Exim Bank, in August 2008, had extended a total of $900 million in financing guarantees to
Reliance to help it expand. However, some observers say Reliance continues to make such sales,
as does Vitol of Switzerland, which had similarly announced it would close out existing gas sales
to Iran, in this case by the end of 2007.
Legislation in the 111th Congress
A number of ideas to expand ISA’s application, similar to those that surfaced in the 110th
Congress, have been introduced in the 111th Congress. One measure was passed in the Senate; an
amendment to S.Con.Res. 13, the FY2010 budget resolution, expressed the Sense of Congress
that the U.S. government not purchase any goods or services from any international firm that
obtains at least $1 million in revenue from the sale of goods or services to Iran’s energy sector.
The provision defined these goods or services as including: development of Iran’s oil and gas
fields; selling refined petroleum products to Iran, the enhancement or maintenance of Iran’s oil
refineries, and the provision of shipping or shipping insurance services to Iran. This provision
was intended to prevent the U.S. government from procuring any products or services from any
firm that conducts the sanctionable activity as defined in the provision. Filling the Strategic
Petroleum Reserve with products from such firms would presumably end, if that provision had
been adopted by both chambers and the recommendation followed by the Administration.
In the aftermath of Iran’s crackdown on post-June 12, 2009, presidential election protests, the
House Appropriations Committee marked up a version of a FY2010 foreign aid appropriation
(H.R. 3081) that would deny Eximbank credits to any firm that sells gasoline to Iran, provides
equipment to Iran that it can use to expand its oil refinery capabilities, or performs gasoline
production projects in Iran.
In April 2009, several bills were introduced—H.R. 2194, S. 908, H.R. 1208, and H.R. 1985—that
would make sanctionable efforts by foreign firms to supply refined gasoline to Iran or to supply
equipment to Iran that could be used by Iran to expand or construction oil refineries. Such activity
is not now sanctionable under ISA. S. 908 and H.R. 2194 would, in addition, expand the menu of
sanctions available for the President to impose, in order to enact penalties against violating firms.
The new available sanctions would include: (1) prohibiting transactions in foreign exchange by
the sanctioned firm; (2) prohibiting any financial transactions on behalf of the sanctioned firm; or
(3) prohibiting any acquisitions or ownership of U.S. property by the sanctioned entity. H.R. 1208
contained numerous other provisions that were in several of the bills mentioned above in the 110th
Congress, including eliminating the exemption in the trade ban that allows importation of Iranian
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luxury goods, and applying the trade ban to subsidiaries of U.S. firms (if those subsidiaries were
used by the parent specifically to conduct trade with Iran).
Some Members who have introduced these bills have said that such legislation might appear to
conflict with President Obama’s diplomatic outreach to Iran, although others believe such bills
might strengthen that approach by demonstrating to Iran that there are substantial downsides to
rebuffing the U.S. overtures. Upon introducing H.R. 2194, Rep. Howard Berman, Chairman of
the House Foreign Affairs Committee, said: “I fully support the Administration’s strategy of
direct diplomatic engagement with Iran, and I have no intention of moving this bill through the
legislative process in the near future....However, should engagement with Iran not yield the
desired results in a reasonable period of time, we will have no choice but to press forward with
additional sanctions—such as those contained in this bill—that could truly cripple the Iranian
economy.” Observers say that the Chairman might try to advance the legislation if Iran does not
meet the “deadline” of September 24, 2009 to return to multilateral nuclear negotiations.
Table 1. Post-1999 Major Investments in Iran’s Energy Sector
($20 million + investments in oil and gas fields only; refineries, petrochemical plants, not included.)
Date Field
Company(ies)
Value
Output/Goal
Feb.
1999
Doroud (oil)
Totalfina Elf (France)/ENI
(Italy)
$1 billion
205,000 bpd
Apr.
1999
Balal (oil)
Totalfina Elf/ Bow Valley
(Canada)/ENI
$300 million
40,000 bpd
Nov.
1999
Soroush and Nowruz (oil)
Royal Dutch Shell
$800 million
190,000 bpd
Apr.
2000
Anaran (oil)
Norsk Hydro
(Norway)/Lukoil (Russia)
$100 million
100,000 (by 2010)
July
2000
Phase 4 and 5, South Pars (gas)
ENI
$1.9 billion
2 billion cu.ft./day
(cfd)
Mar.
2001
Caspian Sea oil exploration
GVA Consultants (Sweden)
$225 million
?
June
2001
Darkhovin (oil)
ENI
$1 billion
160,000 bpd
May
2002
Masjid-e-Soleyman (oil)
Sheer Energy (Canada)
$80 million
25,000 bpd
Sep.
2002
Phase 9 + 10, South Pars (gas)
LG (South Korea)
$1.6 billion
2 billion cfd
Oct.
Phase 6, 7, 8, South Pars (gas)
2002
Statoil (Norway)
$2.65 billion
3 billion cfd
(est. to begin producing late 08)
Inpex (Japan) 10% stake;
$200 million
Jan.
China National Oil Co. agreed (Inpex
2004
Azadegan (oil)
260,000 bpd
to develop “north Azadegan”
stake); China
in Jan. 2009
$1.76 billion
Aug.
2004
Tusan Block
Petrobras (Brazil)
$34 million
?
Oct.
Yadavaran (oil). Finalized
2004
December 9, 2007
Sinopec (China)
$2 billion
185,000 bpd (by
2011)
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Date Field
Company(ies)
Value
Output/Goal
June
2006
Gamsar block (oil)
Sinopec (China)
$20 million
?
Sept.
2006
Khorramabad block (oil)
Norsk Hydro (Norway)
$49 million
?
Golshan and Ferdows onshore
Dec.
and offshore gas fields and LNG
2007
plant; modified but reaffirmed
SKS Ventures (Malaysia)
$16 billion
3.4 billion cfd
December 2008
$29.5 billion investment
Totals

Oil: 1.085 million bpd Gas: 10.4 billion cfd
Pending Deals/Preliminary Agreements
Kharg and Bahregansar fields (gas)
IRASCO (Italy)
$1.6 billion
?
Salkh and Southern Gashku fields (gas).
Includes LNG plant (Nov. 2006)
LNG Ltd. (Australia)
?
?
North Pars Gas Field (offshore gas). Includes
China National Offshore Oil
gas purchases (Dec. 2006)
Co.
$16 billion
3.6 billion cfd
Phase 13, 14 - South Pars (gas); (Feb. 2007).
Royal Dutch Shell, Repsol
Deal cancel ed in May 2008
(Spain)
$4.3 billion
?
Phase 22, 23, 24 - South Pars (gas), incl.
transport Iranian gas to Europe and building
Turkish Petroleum Company
three power plants in Iran. Initialed July 2007; (TPAO)
$12. billion
2 billion cfd
not finalized to date.
Iran’s Kish gas field (April 2008)
Oman
$7 billion
1 billion cfd
China-led consortium;
Phase 12 South Pars (gas). Incl. LNG terminal project originally subscribed
20 million tonnes
construction (March 2009)
$3.2 billion
in May 2007 by OMV
of LNG annual y by
(Austria)
2012
Source. CRS, GAO cited later, and a wide variety of press announcements and sources. CRS has no way to
confirm the precise status of any of the announced investments, and some investments may have been resold to
other firms or terms altered since agreement.
Relationships to Other U.S. Sanctions
ISA is one of many mechanisms the United States and its European partners are using to try to
pressure Iran. The following sections discuss other U.S. sanctions and measures to pressure Iran’s
economy. United Nations sanctions, which have gradually increased since 2006, are discussed in
detail in CRS Report RL32048, Iran: U.S. Concerns and Policy Responses, by Kenneth Katzman.
The U.N. sanctions are discussed in that report in conjunction with analysis of multilateral efforts
to curb Iran’s nuclear program; which also is discussed in that CRS report. Iranian entities and
persons sanctioned by the United Nations are included in the table at the end of this paper.
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Ban on U.S. Trade and Investment With Iran
On May 6, 1995, President Clinton issued Executive Order 12959 banning U.S. trade and
investment in Iran.6 This followed an earlier March 1995 executive order barring U.S. investment
in Iran’s energy sector. The trade ban was intended to blunt criticism that U.S. trade with Iran
made U.S. appeals for multilateral containment of Iran less credible. Each March since 1995 (and
most recently on March 11, 2009), the U.S. Administration has renewed a declaration of a state of
emergency that triggered the investment ban. Some modifications to the trade ban since 1999
account for the trade between the United States and Iran. As noted, in the 111th Congress, H.R.
1208 would reimpose many of the trade restrictions.
The following conditions and modifications, as administered by the Office of Foreign Assets
Control (OFAC) of the Treasury Department, apply:
• Some goods related to the safe operation of civilian aircraft may be licensed for
export to Iran, and as recently as September 2006, the George W. Bush
Administration, in the interests of safe operations of civilian aircraft, permitted a
sale by General Electric of Airbus engine spare parts to be installed on several
Iran Air passenger aircraft (by European airline contractors).
• U.S. firms may not negotiate with Iran or to trade Iranian oil overseas. The trade
ban permits U.S. companies to apply for licenses to conduct “swaps” of Caspian
Sea oil with Iran. However, a Mobil Corporation application to do so was denied
in April 1999.
• Since April 1999, commercial sales of food and medical products to Iran have
been allowed, on a case-by-case basis and subject to OFAC licensing. According
to OFAC in April 2007, licenses for exports of medicines to treat HIV and
leukemia are routinely expedited for sale to Iran, and license applications are
viewed favorably for business school exchanges, earthquake safety seminars,
plant and animal conservation, and medical training in Iran. Private letters of
credit can be used to finance approved transactions, but no U.S. government
credit guarantees are available, and U.S. exporters are not permitted to deal
directly with Iranian banks. The FY2001 agriculture appropriations law (P.L.
106-387) contained a provision banning the use of official credit guarantees 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 such credit
guarantees. Neither the Clinton Administration nor the George W. Bush
Administration provided the credit guarantees.
• In April 2000, the trade ban was further eased to allow U.S. importation of
Iranian nuts, dried fruits, carpets, and caviar. The United States was the largest
market for Iranian carpets before the 1979 revolution, but U.S. anti-dumping
tariffs imposed on Iranian products in 1986 dampened of many Iranian products.
The tariff on Iranian carpets is now about 3%-6%, and the duty on Iranian caviar
is about 15%. In December 2004, U.S. sanctions were further modified to allow
Americans to freely engage in ordinary publishing activities with entities in Iran

6 An August 1997 amendment to the trade ban (Executive Order 13059) prevented U.S. companies from knowingly
exporting goods to a third country for incorporation into products destined for Iran.
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(and Cuba and Sudan). As of mid-2007, the product most imported from Iran by
U.S. importers is pomegranate juice concentrate. In the 110th Congress, H.R.
1400, S. 970, S. 3445, and H.R. 7112 would have re-imposed the full import ban.
Application to Foreign Subsidiaries of U.S. Firms
The U.S. trade ban does not bar subsidiaries of U.S. firms from dealing with Iran, as long as the
subsidiary has no operational relationship to the parent company. Among major subsidiaries that
have traded with Iran are the following:
• Halliburton. On January 11, 2005, Iran said it had contracted with U.S. company
Halliburton, and an Iranian company, Oriental Kish, to drill for gas in Phases 9
and 10 of South Pars. Halliburton reportedly provided $30 million to $35 million
worth of services per year through Oriental Kish, leaving unclear whether
Halliburton would be considered in violation of the U.S. trade and investment
ban or the Iran Sanctions Act (ISA)7—because the deals involved a subsidiary of
Halliburton (Cayman Islands-registered Halliburton Products and Service, Ltd,
based in Dubai). On April 10, 2007, Halliburton announced that its subsidiaries
had, as promised in January 2005, no longer operating in Iran.
• General Electric (GE). The firm announced in February 2005 that it would seek
no new business in Iran, and it reportedly wound down pre-existing contracts by
July 2008. GE was selling Iran equipment and services for hydroelectric, oil and
gas services, and medical diagnostic projects through Italian, Canadian, and
French subsidiaries.
• Foreign subsidiaries of several other U.S. energy equipment firms are apparently
still in the Iranian market. These include Foster Wheeler, Natco Group, Overseas
Shipholding Group, 8 UOP (a Honeywell subsidiary), Itron, Fluor, Flowserve,
Parker Drilling, Vantage Energy Services, Weatherford, and a few others.
• An Irish subsidiary of the Coca Cola company provides syrup for the U.S.-brand
soft drink to an Iranian distributor, Khoshgovar. Local versions of both Coke and
of Pepsi (with Iranian-made syrups) are also marketed in Iran by distributors who
licensed the recipes for those soft drinks before the Islamic revolution and before
the trade ban was imposed on Iran.
In the 110th Congress, S. 970, S. 3227, S. 3445, and three House-passed bills (H.R. 1400, H.R.
7112, and H.R. 957)—would have applied sanctions to the parent companies of U.S. subsidiaries
if those subsidiaries are directed or formed to trade with Iran. In the 111th Congress, H.R. 1208
contains a similar provision.
Treasury Department “Targeted Financial Measures”
U.S. officials, whose leverage has been enhanced by five U.N. Security Council Resolutions
passed since 2006 that sanction Iran, have persuaded many European and other banks not to

7 “Iran Says Halliburton Won Drilling Contract.” Washington Times, January 11, 2005.
8 Prada, Paulo, and Betsy McKay. Trading Outcry Intensifies. Wall Street Journal, March 27, 2007; Brush, Michael.
Are You Investing in Terrorism? MSN Money, July 9, 2007.
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finance exports to Iran or to process dollar transactions with Iranian banks; and they have
persuaded European governments to reduce export credits guarantees to Iran. The actions have,
according to the International Monetary Fund, partly dried up financing for energy industry and
other projects in Iran, and have caused potential investors in the energy sector to withdraw from
or hesitate on finalizing pending projects.
These are the results of “targeted financial measures” undertaken by the Treasury Department,
particularly the office of Undersecretary of the Treasury Stuart Levey (who has remained in the
Obama Administration). Levey and other officials have been able to convince individual foreign
banks that dealing with Iran entails financial risk and furthers terrorism and proliferation.
Treasury Secretary Timothy Geithner has described Levey as having “led the design of a
remarkably successful program”9 with regard to targeting Iran’s proliferation networks.
Treasury and State Departments officials, in April 17, 2008, testimony before the House Foreign
Affairs Committee, said they had persuaded at least 40 banks not to provide financing for exports
to Iran or to process dollar transactions for Iranian banks. Among those that have pulled out of
Iran are UBS and Credit Suisse (Switzerland), HSBC (Britain), Germany’s Commerzbank A.G
and Deutsche Bank AG. U.S. pressure has reportedly convinced Kuwaiti banks to stop
transactions with Iranian accounts,10 and some banks in Asia (primarily South Korea and Japan)
and the rest of the Middle East have done the same. The International Monetary Fund and other
sources report that these measures are making it more difficult to fund energy industry and other
projects in Iran and for importers/exporters to conduct trade in expensive items.
Some of these results have come about through U.S. pressure. In 2004, the Treasury Department
fined UBS $100 million for the unauthorized movement of U.S. dollars to Iran and other
sanctioned countries, and in December 2005, the Treasury Department fined Dutch bank ABN
Amro $80 million for failing to fully report the processing of financial transactions involving
Iran’s Bank Melli (and another bank partially owned by Libya).
In action intended to cut Iran off from the U.S. banking system, on September 6, 2006, the
Treasury Department barred U.S. banks from handling any indirect transactions (“U-turn
transactions, meaning transactions with non-Iranian foreign banks that are handling transactions
on behalf of an Iranian bank) with Iran’s Bank Saderat (see above), which the Administration
accuses of providing funds to Hezbollah.11 Bank Sepah is subject to asset freezes and transactions
limitations as a result of Resolution 1737 and 1747. The Treasury Department extended that U-
Turn restriction to all Iranian banks on November 6, 2008.
Thus far, the Treasury Department has not designated any bank as a “money laundering entity”
for Iran-related transactions (under Section 311 of the USA Patriot Act), although some say that
step has been threatened at times. Nor has Treasury imposed any specific sanctions against Bank
Markazi (Central Bank) which, according to a February 25, 2008, Wall Street Journal story, is
helping other Iranian banks circumvent the U.S. and U.N. banking pressure. However, the
European countries reportedly oppose such a sanction as an extreme step with potential
humanitarian consequences, for example by preventing Iran from keeping its currency stable. S.

9 Hearing of the Financial Services and General Government Subcommittee of the House Appropriations Committee,
Federal News Service, May 21, 2009.
10 Mufson, Steven and Robin Wright. “Iran Adapts to Economic Pressure.” Washington Post, October 29, 2007.
11 Kessler, Glenn. “U.S. Moves to Isolate Iranian Banks.” Washington Post, September 9, 2006.
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3445, a Senate bill in the 110th Congress, and a counterpart passed by the House on September
26, 2008, H.R. 7112, call for this sanction. The FY2010 National Defense Authorization Act
(H.R. 2647), as passed by the Senate, expresses the Sense of the Senate that the Administration
sanction Iran’s Central Bank if Iran does not negotiate in good faith to curb its nuclear program.
In enforcing U.S. sanctions, on December 17, 2008, the U.S. Attorney for the Southern District of
New York filed a civil action seeking to seize the assets of the Assa Company, a U.K-chartered
entity. Assa allegedly was maintaining the interests of Bank Melli in an office building in New
York City. An Iranian foundation, the Alavi Foundation, allegedly is an investor in the building.
Terrorism-Related Sanctions
Several U.S. sanctions are in effect as a result of Iran’s presence on the U.S. “terrorism list.” The
list was established by Section 6(j) of the Export Administration Act of 1979, sanctioning
countries determined to have provided repeated support for acts of international terrorism. Iran
was added to the list in January 1984, following the October 1983 bombing of the U.S. Marine
barracks in Lebanon (believed perpetrated by Hezbollah). Sanctions imposed as a consequence
include: a ban on U.S. foreign aid to Iran; restrictions on U.S. exports to Iran of dual use items;
and requires the United States to vote against international loans to Iran.
• The terrorism list designation restricts sales of U.S. dual use items (Export
Administration Act, as continued by executive order), and, under other laws, bans
direct U.S. financial assistance (Foreign Assistance Act, FAA) and arms sales
(Arms Export Control Act), and requires the United States to vote to oppose
multilateral lending to the designated countries (Anti-Terrorism and Effective
Death Penalty Act of 1996, P.L. 104-132). Waivers are provided under these
laws, but successive foreign aid appropriations laws since the late 1980s ban
direct assistance to Iran (loans, credits, insurance, Eximbank credits) without
providing for a waiver.
• Section 307 of the FAA (added in 1985) names Iran as unable to benefit from
U.S. contributions to international organizations, and require proportionate cuts if
these institutions work in Iran. No waiver is provided for.
• The Anti-Terrorism and Effective Death Penalty Act also requires the President to
withhold U.S. foreign assistance to any country that provides to a terrorism list
country foreign assistance or arms. Waivers are provided.
U.S. sanctions laws do not bar disaster aid and the United States donated $125,000, through relief
agencies, to help victims of two earthquakes in Iran (February and May 1997), and another
$350,000 worth of aid to the victims of a June 22, 2002 earthquake. (The World Bank provided
some earthquake related lending as well.) The United States provided $5.7 million in assistance
(out of total governmental pledges of about $32 million, of which $17 million have been
remitted) to the victims of the December 2003 earthquake in Bam, Iran, which killed as many as
40,000 people and destroyed 90% of Bam’s buildings. The United States military flew in 68,000
kilograms of supplies to Bam.
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Executive Order 13224
The separate, but related, Executive Order 13324 (September 23, 2001) authorizes the President
to freeze the assets of and bar U.S. transactions with entities determined to be supporting
international terrorism. Iranian entities named and sanctioned under this order are in the tables at
the end of CRS Report RL32048, Iran: U.S. Concerns and Policy Responses, by Kenneth
Katzman. Those tables also include the names of Iranian entities sanctioned by the United
Nations.
Proliferation-Related Sanctions
Iran is prevented from receiving advanced technology from the United States under relevant and
Iran-specific anti-proliferation laws12 and by Executive Order 13382 (June 28, 2005).
The Iran-Iraq Arms Nonproliferation Act (P.L. 102-484) requires denial of license applications for
exports to Iran of dual use items, and imposes sanctions on foreign countries that transfer to Iran
“destabilizing numbers and types of conventional weapons,” as well as WMD technology.
The Iran Nonproliferation Act (P.L. 106-178, now called the Iran-Syria-North Korea Non-
Proliferation Act) authorizes sanctions on foreign entities that assist Iran’s WMD programs. It
bans U.S. extraordinary payments to the Russian Aviation and Space Agency in connection with
the international space station unless the President can certify that the agency or entities under its
control had not transferred any WMD or missile technology to Iran within the year prior.13 (A
Continuing Resolution for FY2009, which funded the U.S. government through March 2009,
waived this law to allow NASA to continue to use Russian vehicles to access the International
Space Station.)
Executive Order 13382 allows the President to block the assets of proliferators of 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 Emergencies
Act (50 U.S.C. 1601 et seq.), and Section 301 of Title 3, United States Code.
The George W. Bush Administration decided to impose sanctions for violations, and it sanctioned
numerous entities as discussed below. The Obama Administration sanctioned several entities on
February 2, 2009, suggesting it is continuing that policy. Iranian entities designated under these
laws and orders are listed in the tables at the end of CRS Report RL32048, Iran: U.S. Concerns
and Policy Responses, by Kenneth Katzman, which includes lists of other entities sanctioned by
the United Nations and other U.S. laws and Executive orders.
Despite these efforts, Iran has used loopholes and other devices, such as front companies, to elude
U.S. and international sanctions. Some of these efforts focus on countries perceived as having lax

12 Such laws include the Atomic Energy Act of 1954 and the Energy Policy Act of 2005 (P.L. 109-58).
13 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
transportation on its Soyuz spacecraft. Legislation in the 109th Congress (S. 1713, P.L. 109-112) amended the provision
in order to facilitate continued U.S. access and extended INA sanctions provisions to Syria.
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enforcement of export control laws, such as UAE and Malaysia. In some cases, Iran has been
able, according to some reports, to obtain sophisticated technology even from U.S. firms.14
In addition, successive foreign aid appropriations punish the Russian Federation for assisting Iran
by withholding 60% of any U.S. assistance to the Russian Federation unless it terminates
technical assistance to Iran’s nuclear and ballistic missiles programs.
Relations to International Sanctions
The U.S. sanctions discussed in this paper are more extensive than those imposed, to date, by the
United Nations Security Council. However, some of the U.N. sanctions are similar to some
unilateral U.S. sanctions and sanctions that have been imposed separately by U.S. allies. As part
of a multilateral process of attempting to convince Iran to choose the path of negotiations or face
further penalty, during 2006-2008, three U.N. Security Council resolutions – 1737, 1747, and
1803 – imposed sanctions primarily on Iran’s weapons of mass destruction (WMD) infrastructure.
While pressing for sanctions, the multilateral group negotiation with Iran (“P5+1:” the Security
Council permanent members, plus Germany) at the same time offered Iran incentives to suspend
uranium enrichment; the last meeting between Iran and the P5+1 to discuss these issues was in
July 2008. The negotiations made little progress, and then entered a hiatus for the U.S.
presidential election, the establishment of the Obama Administration, and then the Iranian
presidential election. The main provisions of the current U.N. sanctions are below:
Summary of Provisions of U.N. Resolutions on Iran Nuclear Program
(1737, 1747, and 1803)
Require Iran to suspend uranium enrichment
Prohibit transfer to Iran of nuclear, missile, and dual use items to Iran, except for use in light water reactors
Prohibit Iran from exporting arms or WMD-useful technology
Freeze the assets of 40 named Iranian persons and entities, including Bank Sepah, and several Iranian front companies
Require that countries exercise restraint with respect to travel of 35 named Iranians and ban the travel of 5 others
Cal on states not to export arms to Iran or support new business with Iran
Call for vigilance with respect to the foreign activities of all Iranian banks, particularly Bank Melli and Bank Saderat
Calls on countries to inspect cargoes carried by Iran Air Cargo and Islamic Republic of Iran Shipping Lines if there are
indications they carry cargo banned for carriage to Iran.





14 Warrick, Joby. “Iran Using Fronts to Get Bomb Parts From U.S.” Washington Post, January 11, 2009; Institute for
Science and International Security. “Iranian Entities’ Illicit Military Procurement Networks.” David Albright, Paul
Brannan, and Andrea Scheel. January 12, 2009.
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Efforts to Promote Divestment
A growing trend not only in Congress but in several states is to require or call for or require
divestment of shares of firms that have invested in Iran’s energy sector (at the same levels
considered sanctionable under the Iran Sanctions Act).15
Legislation in the 110th Congress, H.R. 1400, did not require divestment, but requires a
presidential report on firms that have invested in Iran’s energy sector. Another bill, H.R. 1357,
required government pension funds to divest of shares in firms that have made ISA-sanctionable
investments in Iran’s energy sector and bar government and private pension funds from future
investments in such firms. Two other bills, H.R. 2347 (passed by the House on July 31, 2007) and
S. 1430, would protect mutual fund and other investment companies from shareholder action for
any losses that would occur from divesting in firms that have investing in Iran’s energy sector.
In the 111th Congress, H.R. 1327 (Iran Sanctions Enabling Act), a bill similar to H.R. 2347 of the
110th Congress, was reported by the Financial Services Committee on April 28, 2009. A similar
bill. S. 1065, has been introduced in the Senate.
Blocked Iranian Property and Assets
Iranian leaders continue to assert that the United States is holding Iranian assets, and that this is
an impediment to improved relations. A U.S.-Iran Claims Tribunal at the Hague continues to
arbitrate cases resulting from the 1980 break in relations and freezing of some of Iran’s assets.
Major cases yet to be decided center on hundreds of Foreign Military Sales (FMS) cases between
the United States and the Shah’s regime, which Iran claims it paid for but were unfulfilled. About
$400 million in proceeds from the resale of that equipment was placed in a DOD FMS account,
and about $22 million in Iranian diplomatic property remains blocked, although U.S. funds have
been disbursed—credited against the DOD FMS account—to pay judgments against Iran for past
acts of terrorism against Americans. Other disputes include the mistaken U.S. shoot-down on July
3, 1988, of an Iranian Airbus passenger jet (Iran Air flight 655), for which the United States, in
accordance with an ICJ judgment, paid Iran $61.8 million in compensation ($300,000 per wage
earning victim, $150,000 per non-wage earner) for the 248 Iranians killed. The United States has
not compensated Iran for the airplane itself. As it has in past similar cases, the Bush
Administration opposed a terrorism lawsuit against Iran by victims of the U.S. Embassy Tehran
seizure on the grounds of diplomatic obligation.16


15 For information on the steps taken by individual states, see National Conference of State Legislatures. State
Divestment Legislation.
16 See CRS Report RL31258, Suits Against Terrorist States by Victims of Terrorism, by Jennifer K. Elsea.
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Table 2. Entities Sanctioned Under U.N. Resolutions and
U.S. Laws and Executive Orders
(Persons listed are identified by the positions they held when designated;
some have since changed.)
Entities Named for Sanctions Under Resolution 1737
Atomic Energy Organization of Iran (AEIO) Mesbah Energy
Gen Hosein Salimi (Commander, IRGC Air Force)
Company (Arak supplier)
Dawood Agha Jani (Natanz official)
Kalaye Electric (Natanz supplier))
Ali Hajinia Leilabadi (director of Mesbah Energy)
Pars Trash Company (centrifuge program) Farayand Technique
(centrifuge program)
Lt. Gen. Mohammad Mehdi Nejad Nouri
(Malak Ashtar University of Defence Technology
Defense Industries Organization (DIO)
rector)
7th of Tir (DIO subordinate)
Bahmanyar Morteza Bahmanyar
(AIO official)
Shahid Hemmat Industrial Group (SHIG)—missile program
Reza Gholi Esmaeli (AIO official)
Shahid Bagheri Industrial Group (SBIG) - missile program
Ahmad Vahid Dastjerdi
Fajr Industrial Group (missile program)
(head of Aerospace Industries Org., AIO)
Mohammad Qanadi, AEIO Vice President
Maj. Gen. Yahya Rahim Safavi (Commander in
Behman Asgarpour (Arak manager)
Chief, IRGC)
Ehsan Monajemi (Natanz construction manager)
Jafar Mohammadi (Adviser to AEIO)

Entities/Persons Added by Resolution 1747
Ammunition and Metal urgy Industries Group
Fereidoun Abbasi-Davani
(controls 7th of Tir)
(senior defense scientist)
Parchin Chemical Industries (branch of DIO)
Mohasen Fakrizadeh-Mahabai
(defense scientist)
Karaj Nuclear Research Center
Seyed Jaber Safdari
Novin Energy Company
(Natanz manager)
Cruise Missile Industry Group
Mohsen Hojati
Sanam Industrial Group (subordinate to AIO)
(head of Fajr Industrial Group)
Ya Mahdi Industries Group
Ahmad Derakshandeh
(head of Bank Sepah)
Kavoshyar Company (subsidiary of AEIO)
Brig. Gen. Mohammad Reza Zahedi (IRGC ground
Sho’a Aviation (produces IRGC light aircraft for asymmetric
forces commander)
warfare)
Amir Rahimi
Bank Sepah
(head of Esfahan nuclear facilities)
(funds AIO and subordinate entities)
Mehrdada Akhlaghi Ketabachi (head of SBIG)
Esfahan Nuclear Fuel Research and Production Center and
Esfahan Nuclear Technology Center
Naser Maleki (head of SHIG)
Qods Aeronautics Industries
Brig. Gen. Morteza Reza’i
(produces UAV’s, para-gliders for IRGC asymmetric
(Deputy commander-in-chief, IRGC)
warfare)
Vice Admiral Ali Akbar Ahmadiyan
Pars Aviation Services Company
(chief of IRGC Joint Staff)
(maintains IRGC Air Force equipment)
Brig. Gen. Mohammad Hejazi
Gen. Mohammad Baqr Zolqadr
(Basij commander)
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(IRGC officer serving as deputy Interior Minister
Brig. Gen. Qasem Soleimani (Qods Force commander)

Entities Added by Resolution 1803
Thirteen Iranians named in Annex 1 to Resolution 1803; al
Ettehad Technical Group
reputedly involved in various aspects of nuclear program
(AIO front co.)
Electro Sanam Co.
Industrial Factories of Precision
Abzar Boresh Kaveh Co.
Joza Industrial Co.
(centrifuge production)
Pshgam (Pioneer) Energy Industries
Barzaganin Tejaral Tavanmad Saccal
Tamas Co.
Jabber Ibn Hayan
(involved in uranium enrichment)
Khorasan Metal urgy Industries

Niru Battery Manufacturing Co.
(Makes batteries for Iranian military and missile systems)
Safety Equipment Procurement
(AIO front, involved in missiles)

Entities Designated Under U.S. Executive Order 13382
(many designations coincident with designations under U.N. resolutions)
Entity Date
Named
Shahid Hemmat Industrial Group (Iran)
June 2005, Sept. 07
Shahid Bakeri Industrial Group (Iran)
June 2005, Feb. 2009
Atomic Energy Organization of Iran
June 2005
Novin Energy Company (Iran)
January 2006
Mesbah Energy Company (Iran)
January 2006
Four Chinese entities: Beijing Alite Technologies, LIMMT
June 2006
Economic and Trading Company, China Great Wall Industry
Corp, and China National Precision Machinery
Import/Export Corp.
Sanam Industrial Group (Iran)
July 2006
Ya Mahdi Industries Group (Iran)
July 2006
Bank Sepah (Iran)
January 2007
Defense Industries Organization (Iran)
March 2007
Pars Trash (Iran, nuclear program)
June 2007
Farayand Technique (Iran, nuclear program)
June 2007
Fajr Industries Group (Iran, missile program)
June 2007
Mizan Machine Manufacturing Group (Iran, missile prog.)
June 2007
Aerospace Industries Organization (AIO) (Iran)
Sept. 2007
Korea Mining and Development Corp. (N. Korea)
Sept. 2007
Islamic Revolutionary Guard Corps (IRGC)
October 21, 07
Ministry of Defense and Armed Forces Logistics
October 21
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Bank Melli (Iran’s largest bank, widely used by Guard); Bank
October 21
Melli Iran Zao (Moscow); Melli Bank PC (U.K.)
Bank Kargoshaee
October 21
Arian Bank (joint venture between Melli and Bank Saderat).
October 21
Based in Afghanistan
Bank Mellat (provides banking services to Iran’s nuclear
October 21
sector); Mellat Bank SB CJSC (Armenia). Reportedly has
$1.4 billion in assets in UAE
Persia International Bank PLC (U.K.)
October 21
Khatam ol Anbiya Gharargah Sazendegi Nooh
October 21
(Revolutionary Guard construction, contracting arm, with
$7 billion in oil, gas deals
Oriental Oil Kish (Iranian oil exploration firm)
October 21
Ghorb Karbala; Ghorb Nooh (synonymous with Khatam ol
October 21
Anbiya)
Sepasad Engineering Company (Guard construction affiliate)
October 21
Omran Sahel (Guard construction affiliate)
October 21
Sahel Consultant Engineering (Guard construction affiliate)
October 21
Hara Company
October 21
Gharargahe Sazandegi Ghaem
October 21
Bahmanyar Morteza Bahmanyar (AIO, Iran missile official,
October 21
see above under Resolution 1737)
Ahmad Vahid Dastjerdi (AIO head, Iran missile program)
October 21
Reza Gholi Esmaeli (AIO, see under Resolution 1737)
October 21
Morteza Reza’i (deputy commander, IRGC) See also
October 21
Resolution 1747
Mohammad Hejazi (Basij commander). Also, Resolution
October 21,
1747
Ali Akbar Ahmadian (Chief of IRGC Joint Staff). Resolution
October 21,
1747
Hosein Salimi (IRGC Air Force commander). Resolution
October 21,
1737
Qasem Soleimani (Qods Force commander). Resolution
October 21
1747
Future Bank (Bahrain-based but al egedly control ed by Bank
March 12, 2008
Melli)
Yahya Rahim Safavi (former IRGC Commander in Chief
July 8, 2008
Mohsen Fakrizadeh-Mahabadi (senior Defense Ministry
July 8, 2008
scientist)
Dawood Agha-Jani (head of Natanz enrichment site)
July 8, 2008
Mohsen Hojati (head of Fajr Industries, involved in missile
July 8, 2008
program)
Mehrdada Akhlaghi Ketabachi (heads Shahid Bakeri Industrial July 8, 2008
Group)
Naser Maliki (heads Shahid Hemmat Industrial Group)
July 8, 2008
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Tamas Company (involved in uranium enrichment)
July 8, 2008
Shahid Sattari Industries (makes equipment for Shahid
July 8, 2008
Bakeri)
7th of Tir (involved in developing centrifuge technology)
July 8, 2008
Ammunition and Metal urgy Industries Group (partner of 7th July 8, 2008
of Tir)
Parchin Chemical Industries (deals in chemicals used in
July 8, 2008
ballistic missile programs)
Karaj Nuclear Research Center
August 12, 08
Esfahan Nuclear Fuel Research and Production Center
August 12, 08
(NFRPC)
Jabber Ibn Hayyan (reports to Atomic Energy Org. of Iran,
August 12, 08
AEIO)
Safety Equipment Procurement Company
August 12, 08
Joza Industrial Company (front company for Shahid Hemmat August 12, 08
Industrial Group, SHIG)
Islamic Republic of Iran Shipping Lines (IRISL) and 18
September 10, 2008
affiliates, including Val Fajr 8; Kazar; Irinvestship; Shipping
Computer Services; Iran o Misr Shipping; Iran o Hind; IRISL
Marine Services; Iriatal Shipping; South Shipping; IRISL
Multimodal; Oasis; IRISL Europe; IRISL Benelux; IRISL China;
Asia Marine Network; CISCO Shipping; and IRISL Malta
Firms affiliated to the Ministry of Defense, including
September 17, 2008
Armament Industries Group; Farasakht Industries; Iran
Aircraft Manufacturing Industrial Co.; Iran Communications
Industries; Iran Electronics Industries; and Shiraz Electronics
Industries
Export Development Bank of Iran. Provides financial services October 22, 2008
to Iran’s Ministry of Defense and Armed Forces Logistics
Assa Corporation (alleged front for Bank Melli involved in
December 17, 2008
managing property in New York City on behalf of Iran)
11 Entities Tied to Bank Melli: Bank Melli Iran Investment
March 3, 2009
(BMIIC); Bank Melli Printing and Publishing; Melli Investment
Holding; Mehr Cayman Ltd.; Cement Investment and
Development; Mazandaran Cement Co.; Shomal Cement;
Mazandaran Textile; Melli Agrochemical; First Persian Equity
Fund; BMIIC Intel. General Trading
Entities Sanctioned Under Executive Order 13224 (Terrorism Entities)
Qods Force
October 21, 2007
Bank Saderat (al egedly used to funnel Iranian money to
October 21, 2007
Hezbollah, Hamas, PIJ, and other Iranian supported terrorist
groups)
Al Qaeda Operatives in Iran: Saad bin Laden; Mustafa Hamid; Jan. 16, 2009
Muhammad Rab’a al-Bahtiyti; Alis Saleh Husain
Entities Sanctioned Under the Iran Non-Proliferation Act and other U.S. Proliferation Laws
Norinco (China). For al eged missile technology sale to Iran. May 2003
Taiwan Foreign Trade General Corporation (Taiwan)
July 4, 2003
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The Iran Sanctions Act (ISA)

Tula Instrument Design Bureau (Russia). For alleged sales of
Sept. 17, 2003
laser-guided artillery shells to Iran.
13 entities sanctioned including companies from Russia,
April 7, 2004
China, Belarus, Macedonia, North Korea, UAE, and Taiwan.
14 entities from China, North Korea, Belarus, India (two
September 29, 2004
nuclear scientists, Dr. Surendar and Dr. Y.S.R. Prasad),
Russia, Spain, and Ukraine.
14 entities, mostly from China, for al eged supplying of Iran’s December 2004 and January 2005
missile program. Many, such as North Korea’s Changgwang
Sinyong and China’s Norinco and Great Wall Industry Corp,
have been sanctioned several times previously. Newly
sanctioned entities included North Korea’s Paeksan
Associated Corporation, and Taiwan’s Ecoma Enterprise Co.
9 entities, including those from China (Norinco yet again),
December 26, 2005
India (two chemical companies), and Austria. Sanctions
against Dr. Surendar of India (see September 29, 2004) were
ended, presumably because of information exonerating him.
7 entities. Two Indian chemical companies (Balaji Amines
August 4, 2006
and Prachi Poly Products); two Russian firms
(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 and Biotechnology).
9 entities. Rosobornesksport, Tula Design, and Komna
January 2007
Design Office of Machine Building, and Alexei Safonov
(Russia); Zibo Chemical, China National Aerotechnology,
and China National Electrical (China). Korean Mining and
Industrial Development (North Korea) for WMD or
advanced weapons sales to Iran (and Syria).
14 entities, including Lebanese Hezbollah. Some were
April 23, 2007
penalized for transactions with Syria. Among the new
entities sanctioned for assisting Iran were Shanghai Non-
Ferrous Metals Pudong Development Trade Company
(China); Iran’s Defense Industries Organization; Sokkia
Company (Singapore); Challenger Corporation (Malaysia);
Target Airfreight (Malaysia); Aerospace Logistics Services
(Mexico); and Arif Durrani (Pakistani national).
13 entities: China Xinshidai Co.; China Shipbuilding and
October 23, 2008
Offshore International Corp.; Huazhong CNC (China);
IRGC; Korea Mining Development Corp. (North Korea);
Korea Taesong Trading Co. (NK); Yolin/Yullin Tech, Inc.
(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 Industries Co. (CAVIM);
Entities Designated as Threats to Iraqi Stability under Executive Order 13438
Ahmad Forouzandeh. Commander of the Qods Force
January 9, 2008
Ramazan Headquarters, accused of fomenting sectarian
violence in Iraq and of organizing training in Iran for Iraqi
Shiite militia fighters
Abu Mustafa al-Sheibani. Iran based leader of network that
January 9, 2008
funnels Iranian arms to Shiite militias in Iraq.
Isma’il al-Lami (Abu Dura). Shiite militia leader, breakaway
January 9, 2008
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The Iran Sanctions Act (ISA)

from Sadr Mahdi Army, alleged to have committed mass
kidnapings and planned assassination attempts against Iraqi
Sunni politicians
Mishan al-Jabburi. Financier of Sunni insurgents, owner of
January 9, 2008
pro-insurgent Al-Zawra television, now banned
Al Zawra Television Station
January 9, 2008
Khata’ib Hezbollah (pro-Iranian Mahdi splinter group)
July 2, 2009
Abu Mahdi al-Muhandis
July 2, 2009



Author Contact Information

Kenneth Katzman

Specialist in Middle Eastern Affairs
kkatzman@crs.loc.gov, 7-7612




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