Iran Sanctions
Kenneth Katzman
Specialist in Middle Eastern Affairs
June 22, 2011
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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Iran Sanctions

Summary
There is broad international support for imposing progressively strict economic sanctions on Iran
to try to compel it to verifiably confine its nuclear program to purely peaceful uses. However,
there is not a consensus on how effective the sanctions are on core Western goals. In January
2011, Secretary of State Clinton claimed that sanctions have accomplished a core objective of
slowing Iran’s nuclear program. But, nuclear talks in December 2010 and in January 2011 made
virtually no progress, suggesting that Iran’s leaders do not feel sufficiently pressured by sanctions
to offer major concessions to obtain a nuclear deal.
Because so many major economic powers have imposed sanctions on Iran, the sanctions are, by
all accounts, harming key sectors of Iran’s economy by reinforcing the effects of Iran’s economic
mismanagement. Among other indicators, there have been a stream of announcements by major
international firms since early 2010 that they are exiting the Iranian market. Iran’s oil production
has fallen slightly to about 3.9 million barrels per day, from over 4.1 million barrels per day
several years ago, although Iran now has small natural gas exports that it did not have before Iran
opened its fields to foreign investment in 1996. In addition, Iran’s overall ability to limit the
effects of sanctions has been aided by relatively high oil prices in mid-2011.
The United States and its allies appear to agree that sanctions should continue to target Iran’s
energy sector and should try to isolate Iran from the international financial system. The energy
sector provides about 80% of government revenues. Iran’s large trading community depends on
financing to buy goods from the West and sell them inside Iran. Using the authorities of U.N.
Security Council Resolution 1929, adopted June 9, 2010, measures adopted since mid-2010 by
the United Nations Security Council, the European Union, and several other countries target those
sectors. These national measures complement the numerous U.S. laws and regulations that have
long sought to try to pressure Iran, particularly the Iran Sanctions Act (ISA)—a 1996 U.S. law
that mandated U.S. penalties against foreign companies that invest in Iran’s energy sector. In the
111th Congress, the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
(CISADA, P.L. 111-195) expanded ISA to sanction Iran’s ability to obtain or make gasoline, for
which Iran depends heavily on imports. Sales to Iran of gasoline have fallen dramatically since.
CISADA also contained a broad range of other measures further restricting the already limited
amount of U.S. trade with Iran. It also contained provisions to promote the cause of the domestic
opposition in Iran by sanctioning Iranian officials who are human rights abusers and facilitating
the democracy movement’s access to information technology—a trend that is increasingly taking
hold in the Obama Administration and in partner countries. The increasing emphasis on human
rights-related laws and sanctions reflect a growing belief that there are few new economic
sanctions that can be successfully agreed on or imposed. In the 112th Congress, legislation has
been introduced to enhance both the economic sanctions and human rights-related provisions of
CISADA and other laws. For a broader analysis of policy on Iran, see CRS Report RL32048,
Iran: U.S. Concerns and Policy Responses, by Kenneth Katzman.

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Contents
Overview .................................................................................................................................... 6
Sanctions Targeting Iran’s Energy Sector: The Iran Sanctions Act (ISA) and CISADA
Amendments............................................................................................................................ 6
Legislative History and Provisions ........................................................................................ 6
Key ”Triggers”................................................................................................................ 7
Requirement and Time Frame to Investigate Violations ................................................... 9
Available Sanctions Under ISA ..................................................................................... 10
Waivers, Exemptions, and Termination Authority .......................................................... 11
ISA Sunset .................................................................................................................... 12
Interpretations and Implementation ..................................................................................... 12
ISA Sanctions Determinations: September 2010 to the Present ...................................... 13
Non-Application to Crude Oil or Natural Gas Purchases from Iran or to Sales of
Most Energy Equipment or Services........................................................................... 15
Application to Energy Pipelines .................................................................................... 17
Application to Iranian Firms or the Revolutionary Guard .............................................. 18
Application to Liquefied Natural Gas ............................................................................ 19
Ban on U.S. Trade and Investment With Iran............................................................................. 33
Application to Foreign Subsidiaries of U.S. Firms ............................................................... 35
Subsidiaries Exiting Iran ............................................................................................... 36
Banking and Finance: Treasury Department Financial Measures and CISADA .......................... 37
Banking Provisions of CISADA.......................................................................................... 38
Terrorism List Designation-Related Sanctions ........................................................................... 39
Executive Order 13224 ....................................................................................................... 40
Proliferation-Related U.S. Sanctions ......................................................................................... 40
Iran-Iraq Arms Nonproliferation Act ................................................................................... 40
Iran-Syria-North Korea Nonproliferation Act ...................................................................... 40
Executive Order 13382 ....................................................................................................... 41
Foreign Aid Restrictions for Suppliers of Iran...................................................................... 41
U.S. Efforts to Promote Divestment .......................................................................................... 41
U.S. Sanctions Intended to Support Democratic Change in Iran................................................. 42
Expanding Internet and Communications Freedoms ............................................................ 42
Measures to Sanction Human Rights Abuses and Promote the Opposition ........................... 43
Blocked Iranian Property and Assets ......................................................................................... 43
U.N. Sanctions .......................................................................................................................... 44
International Implementation and Compliance........................................................................... 46
European Union and Other Western States..................................................................... 46
Japan and South Korea .................................................................................................. 46
India/Asian Clearing Union........................................................................................... 46
China, Russia, and Others ............................................................................................. 47
Contrast With Previous Periods ..................................................................................... 48
World Bank Loans ........................................................................................................ 48
Effects of Sanctions on Iran....................................................................................................... 52
Effect on Nuclear Negotiations............................................................................................ 53
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Counter-Proliferation Effects............................................................................................... 53
General Political Effects...................................................................................................... 53
Economic Effects ................................................................................................................ 54
Foreign Companies Exiting the Iran Market .................................................................. 55
Foreign Firms Remaining in the Iran Market ................................................................. 55
Subsidy Phase-Out Issue ............................................................................................... 56
Effect on the Energy Sector ................................................................................................. 56
Concerns About “Backfill”............................................................................................ 57
Effect on Gasoline Availability and Importation ............................................................ 57
Recent or Pending Legislation to Impose Additional Sanctions.................................................. 60

Tables
Table 1. Major Energy Buyers From Iran (2009) ....................................................................... 16
Table 2. Comparison of Major Versions of H.R. 2194/P.L. 111-195............................................ 19
Table 3. Post-1999 Major Investments/Major Development Projects in
Iran’s Energy Sector............................................................................................................... 29
Table 4. Summary of Provisions of U.N. Resolutions on Iran Nuclear Program (1737,
1747, 1803, and 1929)............................................................................................................ 45
Table 5. Points of Comparison Between U.S., U.N., and EU Sanctions Against Iran .................. 49
Table 6. Entities Sanctioned Under U.N. Resolutions and
U.S. Laws and Executive Orders ............................................................................................ 62

Contacts
Author Contact Information ...................................................................................................... 70

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Overview
The Obama Administration’s policy approach toward Iran has contrasted with the Bush
Administration’s by attempting to couple the imposition of sanctions to a consistent, direct U.S.
effort to negotiate with Iran on the nuclear issue. That approach was not initially altered because
of the Iranian dispute over its June 12, 2009, elections. However, with negotiations yielding no
firm Iranian agreement to compromise, since early 2010 the Administration and Congress have
focused on achieving adoption of and implementing additional U.S., U.N., and allied country
sanctions whose cumulative effect, it is believed, could compel Iran to accept a nuclear bargain.
U.N. sanctions on Iran (the latest of which are imposed by Resolution 1929, adopted June 9,
2010) are a relatively recent (post-2006) development. U.S. sanctions, on the other hand, have
been a major feature of U.S. Iran policy since Iran’s 1979 Islamic revolution. Many of the U.S.
sanctions overlap each other as well as the several U.N. sanctions now in place. Some U.S.
sanctions, particularly the 1996 Iran Sanctions Act (ISA), caused differences of opinion between
the United States and its European allies because it mandates U.S. imposition of sanctions on
foreign firms. Successive Administrations have sought to ensure that U.S. sanctions do not
hamper cooperation with key international partners whose support is needed to adopt stricter
international sanctions.
Sanctions Targeting Iran’s Energy Sector: The Iran
Sanctions Act (ISA) and CISADA Amendments
The Iran Sanctions Act (ISA) is one among many U.S. sanctions in place against Iran. Since its
first enactment, it has attracted substantial attention because it is an “extra-territorial sanction”—
it authorizes U.S. penalties against foreign firms, many of which are incorporated in countries
that are U.S. allies. (U.S. firms are barred by executive orders, discussed below, from dealing
with Iran.) When it was first enacted in 1996, Congress and the Clinton Administration saw ISA
as a potential mechanism to compel U.S. allies to join the United States in enacting trade
sanctions against Iran. American firms are separately restricted from trading with or investing in
Iran under separate U.S. executive measures, as discussed below. As noted, a law enacted in the
111th Congress (CISADA, P.L. 111-195) amended ISA to try to curtail additional types of activity,
such as selling gasoline and gasoline production-related equipment and services to Iran, and to
restrict international banking relationships with Iran (among many provisions).
Legislative History and Provisions
Originally called the Iran and Libya Sanctions Act (ILSA), ISA was enacted to try 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 (which is about $870 billion), and 80% of its government revenue. Iran’s oil sector is
as old as the petroleum industry itself (early 20th century), and Iran’s onshore oil fields and oil
industry infrastructure are far past peak production and in need of substantial investment. Its large
natural gas resources (940 trillion cubic feet, exceeded only by Russia) were virtually
undeveloped when ISA was first enacted. Iran has 136.3 billion barrels of proven oil reserves, the
third-largest after Saudi Arabia and Canada.
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The opportunity for the United States to try to harm Iran’s energy sector came in November 1995,
when Iran opened the sector to foreign investment. To accommodate its insistence on retaining
control of its national resources, Iran used a “buy-back” investment program in which foreign
firms gradually recoup their investments as oil and gas is discovered and then produced. 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 provisions to Libya, 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 Senate version adopted on July 16, 1996 (unanimous
consent). The Iran and Libya Sanctions Act was signed on August 5, 1996 (P.L. 104-172).
Key ”Triggers”
ISA consists of a number of “triggers”—transactions with Iran that would be considered
violations of ISA and could cause a firm or entity to be sanctioned under ISA’s provisions. When
triggered, 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 practically, compel any foreign government to act against one of its firms.
Original Triggers
ISA primarily targets foreign firms, because American firms are already prohibited from investing
in Iran under the 1995 trade and investment ban discussed earlier. The pre-2010 version of ISA
requires the President to sanction companies (entities, persons) that make an “investment”1 of
more than $20 million2 in one year in Iran’s energy sector,3 or that sell to Iran weapons of mass
destruction (WMD) technology or “destabilizing numbers and types” of advanced conventional
weapons.4

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. As amended by CISADA (P.L. 111-195), these definitions include
pipelines to or through Iran, as well as contracts to lead the construction, upgrading, or expansions of energy projects.
CISADA also changes the definition of investment to eliminate the exemption from sanctions for sales of energy-
related equipment to Iran, if such sales are structured as investments or ongoing profit-earning ventures.
2 Under Section 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. However, P.L. 111-195 explicit
sets the threshold investment level at $20 million. 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).
3 The definition of energy sector had included oil and natural gas, but now, as a consequence of the enactment of P.L.
111-195, also includes liquefied natural gas (LNG), oil or LNG tankers, and products to make or transport pipelines
that transport oil or LNG.
4 This latter “trigger” was added by P.L. 109-293.
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Trigger Added by CISADA: Selling Gasoline and Refinery Equipment
ISA, as initially constituted, did not address Iran’s gasoline dependency because selling Iran
equipment with which it can build or expand its refineries using its own construction capabilities
did not constitute “investment” under the original definition of ISA. Sales to Iran of gasoline were
not sanctionable either. However, taking responsibility for constructing oil refineries or
petrochemical plants in Iran did constitute sanctionable projects under the original version of ISA
because ISA’s definition of investment includes “responsibility for the development of petroleum
resources located in Iran.” Table 3 provides some information on openly announced contracts to
upgrade or refurbish Iranian oil refineries.) Nor did ISA clearly apply to Iranian investments in oil
refineries in several 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
have constituted “investment” under ISA.
Many in the 111th Congress took exception to the limited of the original version of ISA, arguing
that Iran was dependent on gasoline imports to meet about 40% of its gasoline needs. There have
been a relatively limited group of major gasoline suppliers to Iran, and many in Congress
believed that trying to stop such sells could put economic pressure on Iran’s leaders. The ideas
that became the core of CISADA were introduced as legislation in the 110th and 111th Congresses.
In the 110th Congress, H.R. 2880 would have made sales to Iran of refined petroleum resources a
violation of ISA.
To address this perceived weakness of the original version of ISA, CISADA (P.L. 111-195) added
new triggers: selling to Iran (over specified threshold amounts) refined petroleum (gasoline,
aviation fuel, and other fuels included in the definitions); and selling equipment or services for
Iran to expand its own ability to produce refined petroleum. (Fuel oil, a petroleum by-product
which is reportedly being sold to Iran by exporters in the Kurdish region of Iraq, is not included
in the definition of refined petroleum.)
Pre-CISADA Efforts to Sanction Gasoline Sales to Iran
In the 111th Congress, a few initiatives were adopted prior to CSIDA. Using U.S. funds to fill the
Strategic Petroleum Reserve with products from firms that sell over $1 million worth of gasoline
to Iran is prevented by the FY2010 Energy and Water Appropriation (H.R. 3183, P.L. 111-85,
signed October 28, 2009). A provision of the FY2010 consolidated appropriation (P.L. 111-117)
would deny Ex-Im Bank 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.
These initiatives did deter some gasoline sales to Iran. The Reliance Industries Ltd. of India
decision to cease new sales of refined gasoline to Iran (as of December 31, 2008), mentioned
above, came after several Members of Congress urged the Ex-Im 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 Ex-Im Bank, in August 2008, had extended a total of $900 million in financing
guarantees to Reliance to help it expand.
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CISADA Legislative History
CISADA had its origins in several bills introduced in April 2009 (H.R. 2194, S. 908, H.R. 1208,
and H.R. 1985) that would amend ISA to 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
construct oil refineries. H.R. 2194 and S. 908 were both titled the Iran Refined Petroleum
Sanctions Act of 2009 (IRPSA). H.R. 2194 passed the House on December 15, 2009, by a vote of
412-12, with four others voting “present” and six others not voting.
A bill in the Senate, the “Dodd-Shelby Comprehensive Iran Sanctions, Accountability, and
Divestment Act,” (S. 2799), was reported to the full Senate by the Senate Banking Committee on
November 19, 2009, and passed the Senate, by voice vote, on January 28, 2010. It was adopted
by the Senate under unanimous consent as a substitute amendment to H.R. 2194 on March 11,
2010, setting up conference action on the two versions of H.R. 2194. The Senate bill contained
very similar provisions of the Iran Refined Petroleum Sanctions Act, but, as discussed in Table 2
below, added provisions affecting U.S.-Iran trade and other issues.
A public meeting of the House-Senate conference, chaired by Representative Berman and Senator
Dodd, was held on April 28, 2010. Obama Administration officials were said to be concerned by
some provisions of H.R. 2194 because of the legislation’s potential to weaken allied unity on Iran.
The Administration sought successfully to persuade Members to delay passage of until a new
U.N. sanctions resolution was adopted—for fear that some P5+1 countries might refuse to
support the U.N. resolution if there is a chance their firms would be sanctioned by a new U.S.
law. The U.N. Resolution was adopted on June 9, 2010. A conference report on H.R. 2194 was
agreed on June 22, 2010, and was submitted on June 23, 2010. On June 24, 2010, the Senate
passed it 99-0, and the House passed it 408-8, with one voting “present.” President Obama
welcomed the passage and signed it into law on July 1, 2010.
As widely predicted, and as shown in Table 2 below, the final version contained many of the
extensive provisions of the Senate version, and some of the efforts to compel sanctions
represented in the House version. Administration concerns about angering U.S. partner countries
were addressed in the provisions for waivers, delayed mandatory investigations of violations, and
for the “special rule” exempting from sanctions companies that promise to end their business in
Iran. As was widely predicted, the conference report contains provisions to sanction Iranian
human rights abusers, including denial of visas for their travel to the United States and freezing of
their assets.
Those who supported CISADA said it would strengthen President Obama’s ability to obtain an
agreement with Iran that might impose limitations on its nuclear program. It was argued that
Iran’s dependence on gasoline imports could, at the very least, cause Iran’s government to have to
spend more for such imports. Others, however, believed the Iranian government would have
numerous ways to circumvent its effects, including rationing, reducing gasoline subsidies in an
effort to reduce gasoline consumption; or offering premium prices to obscure gasoline suppliers.
The effect on Iran’s supplies are discussed later in this report.
Requirement and Time Frame to Investigate Violations
In the original version of ISA, there was no time frame for the Administration to determine that a
firm has violated ISA’s provisions. Some might argue that the amendments of P.L. 111-195 still
do not set a binding determination deadline, although the parameters are narrowed significantly.
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Earlier, P.L. 109-293, the “Iran Freedom Support Act” (signed September 30, 2006) amended ISA
by calling for, but not requiring, a 180-day time limit for a violation determination (there is no
time limit in the original law).5
In restricting the Administration’s ability to choose not to act on information about potential
violations, CISADA (P.L. 111-195), Section 102(g)(5), made mandatory that the Administration
begin an investigation of potential ISA violations when there is “credible information” about a
potential violation. The same section of CISADA made mandatory the 180 day time limit for a
determination of violation (with the exception that the mandatory investigations and time limit go
into effect one year after enactment, with respect to gasoline related sales to Iran). However, there
is still lack of precision and potential differences of opinion over what constitutes “credible
information” that an investment or sanctionable sale has been undertaken.
Earlier versions of legislation (H.R. 282, S. 333) that ultimately became P.L. 109-293 contained
ISA amendment proposals that were viewed by the Bush Administration as too inflexible and
restrictive, and potentially harmful to U.S. relations with its allies. These provisions included
setting a mandatory 90-day time limit for the Administration to determine whether an investment
is a violation; cutting U.S. foreign assistance to countries whose companies violate ISA; and
applying the U.S.-Iran trade ban to foreign subsidiaries of U.S. firms.
Available Sanctions Under ISA
Once a firm is determined to be a violator, the original version of ISA required the imposition of
two of a menu of six sanctions on that firm. CISADA added three new possible sanctions and
requires the imposition of at least three out of the nine against violators. The nine available
sanctions against the sanctioned entity that 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 to
the entity;
3. denial of U.S. bank loans exceeding $10 million in one year to the entity;
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;
6. restriction on imports from the violating entity, in accordance with the
International Emergency Economic Powers Act (IEEPA, 50 U.S.C. 1701);
7. prohibitions in transactions in foreign exchange by the entity;
8. prohibition on any credit or payments between the entity and any U.S. financial
institution;

5 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-
laundering for use to further WMD programs.
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9. prohibition of the sanctioned entity from acquiring, holding, or trading any U.S.-
based property.
New Mandatory ISA Sanction Imposed by CISADA: Prohibition on Contracts
With the U.S. Government
CISADA (Section 102(b)) added a provision to further incent foreign companies to comply with
ISA. It requires companies, as a condition of obtaining a U.S. government contract, to certify to
the relevant U.S. government agency, that the firm—and any companies it owns or controls—are
not violating ISA, as amended. A contract may be terminated—and further penalties imposed—if
it is determined that the company’s certification of compliance was false. CISADA requires a
revision of the Federal Acquisition Regulation (within 90 days of CISADA enactment on July 1,
2010) to reflect this requirement. This requirement has been imposed in regulations, as per an
interim rule issued on September 29, 2010. H.R. 6296, introduced September 29, 2010, in the
111th Congress, would have authorized state and local governments to similarly ban such
contracts.
Waivers, Exemptions, and Termination Authority
The President has had the authority under ISA to waive sanctions if he certifies that doing so is
important to the U.S. national interest (Section 9(c)). CISADA (Section 102(c)), changed the 9(c)
ISA waiver standard to “necessary” to the national interest. Under the original version of ISA,
there was also waiver authority (Section 4(c)) if the parent country of the violating firm joined a
sanctions regime against Iran, but this waiver provision was changed by P.L. 109-293 to allow for
a waiver determination based on U.S. vital national security interests. The Section 4(c) waiver
was altered by CISADA to provide for a six month (extendable) waiver if doing so is vital to the
national interest and if the parent country of the violating entity is “closely cooperating” with
U.S. efforts against Iran’s WMD and advanced conventional weapons program. The criteria of
“closely cooperating” are defined in the conference report, with primary focus on implementing
all U.N. sanctions against Iran. However, it is not clear why an Administration would use a
Section 4 waiver rather than a Section 9 waiver, although it could be argued that using a Section 4
waiver would support U.S. diplomacy with the parent country of the offending entity.
ISA (Section5(f)) also contains several exceptions such 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 source supplier of a particular defense article or
service. The President also is not required to prevent procurement or importation of essential
spare parts or component parts.
In the 110th Congress, several bills contained 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.
“Special Rule” Exempting Firms That End Their Business With Iran
CISADA (Section 102(g)(5) also amended ISA to provide a means—a so-called “special rule”—
for firms to avoid any possibility of U.S. sanctions by pledging to verifiably end their business
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with Iran and to forgo any sanctionable business with Iran in the future. Under the special rule,
the Administration is not required to make a determination of sanctionability against a firm that
makes such pledges. The special rule was invoked on September 30, 2010, and again on
November 17, 2010.
Termination Requirements
In its entirety, ISA application to Iran would terminate if Iran is determined by the Administration
to have ceased its efforts to acquire WMD; 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.6 The
amendments to ISA made by P.L. 111-195 would terminate if the first two criteria are met.
ISA Sunset
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. However, some
maintained that Iran 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. ISA was scheduled to sunset on
December 31, 2011 (as provided by P.L. 109-293). The sunset is now December 31, 2016, as
provided for in CISADA).
Interpretations and Implementation
Traditionally reticent to impose economic sanctions, the European Union opposed ISA, when it
was first enacted, as an extraterritorial application of U.S. law and filed a formal complaint before
the World Trade Organization (WTO). In April 1997, the United States and the EU agreed to
avoid a trade confrontation over ISA and a separate Cuba sanctions law (P.L. 104-114). The
agreement involved the dropping of the WTO complaint and the May 18, 1998, decision by the
Clinton Administration to waive ISA sanctions (“national interest”—Section 9c—waiver) on the
first project determined to be in violation. That project was a $2 billion7 contract, signed in
September 1997, for Total SA 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, for its part,
pledged to increase cooperation with the United States on non-proliferation and counter-
terrorism. Then-Secretary of State Albright, in a statement, indicated that similar future such
projects by EU firms in Iran would not be sanctioned, provided overall EU cooperation against
Iranian terrorism and proliferation continued.8 (The EU sanctions against Iran, announced July

6 This latter termination requirement added by P.L. 109-293. This law also removed Libya from the act, although
application to Libya effectively terminated when the President determined on April 23, 2004, that Libya had fulfilled
the requirements of all U.N. resolutions on Pan Am 103.
7 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.
8 Text of announcement of waiver decision by then Secretary of State Madeleine Albright, containing expectation of
similar waivers in the future. http://www.parstimes.com/law/albright_southpars.html.
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27, 2010, might render this understanding moot because the EU sanctions ban EU investment in
and supplies of equipment and services to Iran’s energy sector.)
ISA Sanctions Determinations: September 2010 to the Present
Since the Total/Petronas/Gazprom project in 1998, no projects were determined as violations of
ISA until a State Department announcement of September 30, 2010.9 Prior to the passage of
CISADA, several Members of Congress questioned why no penalties had been imposed for
violations of ISA. 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 have not specifically stated which
foreign companies, if any, were being investigated for ISA violations. No publication of such
deals has been placed in the Federal Register, as required by Section 5e of ISA. In an effort to
address the congressional criticism, Under Secretary of State for Political Affairs William Burns
testified on July 9, 2008 (House Foreign Affairs Committee), that the Statoil project (listed in
Table 3) was under review for ISA sanctions. Statoil is incorporated in Norway, which is not an
EU member and it would therefore not fall under the 1998 U.S.-EU agreement discussed above.
Possibly in response to the pending CISADA legislation, and to an October 2009 letter signed by
50 Members of Congress referencing the CRS table below, Assistant Secretary of State for Near
Eastern Affairs Jeffrey Feltman testified before the House Foreign Affairs Committee on October
28, 2009, that the Obama Administration would review investments in Iran for violations of ISA.
Feltman testified that the preliminary review would be completed within 45 days (by December
11, 2009) to determine which projects, if any, require further investigation. He testified that some
announced projects were for political purposes and did not result in actual investment.
On February 25, 2010, Secretary of State Clinton testified before the House Foreign Affairs
Committee that the State Department’s preliminary review was completed in early February and
that some of the cases reviewed “deserve[] more consideration” and were undergoing additional
scrutiny. The preliminary review, according to the testimony, was conducted, in part, through
State Department officials’ contacts with their counterpart officials abroad and corporation
officials. The additional investigations of problematic investments would involve the intelligence
community, according to Secretary Clinton. State Department officials told CRS in November
2009 that any projects that the State Department plan was to complete the additional investigation
and determine violations within 180 days of the completion of the preliminary review. (The 180-
day time frame was, according to the Department officials, consistent with the Iran Freedom
Support Act amendments to ISA discussed above, even though the 180 day time frame was not a
mandatory deadline before CISADA was adopted.) A final determination of sanctionability would
therefore, according to the Administration, be issued in early August 2010 (180 days from “early
February). On June 22, 2010, Assistant Secretary of State William Burns testified before the
Senate Foreign Relations Committee that there were “less than 10” cases of possible ISA
violations.

9 Much of this section is derived from a meeting between the CRS author and officials of the State Department’s
Economics Bureau, which is tasked with the referenced review of investment projects. November 24, 2009.
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September 30, 2010 Sanctions Determinations
Several determinations of sanctionability were made on September 30, 2010. That day, a Swiss-
based Iranian-owned oil trading company—Naftiran Intertrade Company (NICO)—became the
first firm to be sanctioned under ISA. The three penalties selected were: a ban on Ex-Im Bank
credits; a denial of dual use export licensing to the firm; and a denial of bank loans exceeding $10
million. The mandatory ban on receiving U.S. government contracts applies as well.
That same day, following a months-long Administration review discussed later, four major energy
sector investing companies were deemed eligible to avoid sanctions, under the ISA “special rule,”
by pledging to end their business in Iran. They are:
• Total of France,
• Statoil of Norway,
• ENI of Italy, and
• Royal Dutch Shell of Britain and the Netherlands.
• Inpex of Japan was exempted from sanctions under the special rule on November
17, 2010, according to a State Department announcement. The firm announced
on October 15, 2010, that it is shedding its stake in the Azadegan development
project shown in the table.
There remained some difference of opinion on the Administration invocation of the special rule,
as evident at a hearing of the House Foreign Affairs Committee on December 1, 2010. At the
hearing, Under Secretary Burns stated that companies exempted under the special rule had
pledged to end their existing investments in Iran “in the very near future.” Some Members of
Congress questioned the imprecision of that time frame and others question the process for
determining whether a firm is adhering to its pledge to pursue no future business in Iran’s energy
sector. Observers provided reasons for why the energy firms insisted they needed time to wind
down their investments in Iran—under the buy-back program used for investments in Iran, the
energy firms are paid back their investment over time, making it highly costly for them to
suddenly end operations in Iran.
March 29, 2011, Sanctions Determination Against Belarusneft
As shown in Table 3 below, several additional foreign investment agreements have been agreed
with Iran not covered in the September 2010 determination. Some of these firms remained under
Administration scrutiny, and the Administration stated that determinations will be made within
180 days (by April 1, 2011). On March 29, 2011, with that deadline approaching, the State
Department announced that one additional firm would be sanctioned under ISA—Belarusneft, a
subsidiary of the Belarus government owned Belneftekhim—for a $500 million contract with
Naftiran (the company sanctioned in September 2010) to develop the Jofeir oil field discussed in
Table 3. Other subsidiaries of Belneftekhim were sanctioned in 2007 under Executive Order
13405 related to U.S. policy on Belarus. The three ISA sanctions imposed on March 29, 2011,
were denial of Exim Bank financing, denial of U.S. export licenses, and denial of U.S. loans
above $10 million.
The Administration announcement did not indicate that some of the other investments in Table 3
or other investments, for which no ISA determinations have been made to date, are still under
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investigation. In public statements, some Members of Congress have expressed concern that
Chinese firms have not been sanctioned, indicating that the Administration might be emphasizing
some policy goals with respect to China at the expense of implementing sanctions against Iran.
May 24, 2011 Sanctions Imposed on Gasoline Sellers
On May 24, 2011, the Administration issued its first sanctions determinations under the CISADA-
amended “trigger” that requires sanctions against sellers of gasoline and related equipment and
services. The reasons for the sanctions, including size of gasoline shipments to Iran or
characterization of sanctionable dealings with Iran, as well as the ISA-related sanctions selected,
can be found at http://www.state.gov/r/pa/prs/ps/2011/05/164132.htm. The seven firms sanctioned
are
• Petrochemical Commercial Company International (PCCI) of Bailiwick of Jersey
and Iran
• Royal Oyster Group (UAE)
• Tanker Pacific (Singapore)
• Ofer Brothers Group (Israel)
• Speedy Ship (UAE/Iran)
• Associated Shipbroking (Monaco)
• Petroleos de Venezuela (PDVSA) of Venezuela
Many of the firms sanctioned on May 24, 2011 were subjected to the financial-related sanctions
provided in ISA. With respect to PDVSA, the Administration made clear in its announcement that
U.S.-based subsidiaries were not included in the determination and that U.S. purchases of
Venezuelan oil would not be affected. The day prior to the sanctions announcement, President
Obama issued an Executive order clarifying that it is the responsibility of the Treasury
Department to implement those ISA sanctions that involve the financial sector, including bans on
loans, credits, and foreign exchange for, or imports from the sanctioned entity, as well as
blockage of property of the sanctioned entity (if these sanctions are selected by the Secretary of
State, who makes the decision which penalties to impose on sanctioned entities).
Non-Application to Crude Oil or Natural Gas Purchases from Iran or to Sales
of Most Energy Equipment or Services
Purchases of oil or natural gas from Iran are generally considered not to constitute violations of
ISA, because ISA sanctions investment in Iran’s energy sector and sales to Iran of gasoline or
gasoline-related services or equipment. Some of the deals listed in the chart later in this report
involve combinations of investment and purchase. 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 over $15 billion. The United States criticized
the deal as sending the “wrong message” to Iran. In August 2008, Germany’s Steiner-
Prematechnik-Gastec Co. agreed to apply its method of turning gas into liquid fuel at three
Iranian plants.
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Nor does ISA sanction sales to Iran of equipment that Iran could use to explore or extract its own
oil or gas resources, unless such sales are structured to provide ongoing profits or royalties (and
therefore meet the definition of investments as provided in ISA).10 For example, selling Iran an oil
or gas drill rig or motors or other gear that Iran will use to drill for oil or gas would not appear to
be sanctionable, unless the sale is structured to provide the seller ongoing profits or royalties. In
addition, as noted, CISADA made sanctionable sales of equipment to Iran to enhance or expand
its oil refineries, or equipment with which Iran could import gasoline (such as tankers), and of
equipment that Iran could use to construct an energy pipeline.
Official credit guarantee agencies are not considered sanctionable entities under ISA. In the 110th
Congress, several bills—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
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.
Some versions of CISADA would have made these entities sanctionable but these provisions
were not included in the final law, probably out of concern for alienating U.S. allies in Europe.
Table 1. Major Energy Buyers From Iran (2009)
amounts in millions of U.S. dollars
(includes mineral fuels, crude oil, natural gas, distillates, and the like)
China 10,529
France
1,340
Germany 400.79
Greece 309.99
Hong Kong
372.59
India 9,541
Indonesia 182.95
Italy 2,363
Japan 9,192
Malaysia 964.33
Netherlands 2,765
Portugal 214.52
Singapore 1,998
South Africa
21,973
South Korea
5,420
Spain 2,624
Sri Lanka
843.51
Taiwan 1,788
Thailand 127.49
Turkey 3,047
United Kingdom
174.46
Source: Adapted by CRS, Susan Chesser, from the World Trade Atlas.

10 Prior to CISADA, the definition of investment in ISA specifically exempted sales of equipment or services under that
definition. CISADA omitted that exclusion.
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Application to Energy Pipelines
As noted earlier, ISA’s definition of sanctionable “investment”—which specifies investment in
Iran’s petroleum resources, defined as petroleum and natural gas—has been interpreted by
successive administrations to include construction of energy pipelines to or through Iran. That
interpretation was reinforced by the amendments to ISA in P.L. 111-195, which include in the
definition of petroleum resources “products used to construct or maintain pipelines used to
transport oil or liquefied natural gas.” 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.
Only a few significant pipelines involving Iran have been constructed in recent years—a line built
in 1997 to carry natural gas from Iran to Turkey. Each country constructed the pipeline on its side
of their border. At the time the project was under construction, State Department testimony stated
that Turkey would be importing gas originating in Turkmenistan, not Iran, under a swap
arrangement. That was one reason given for why the State Department did not determine that the
project was sanctionable under ISA. However, many believe the decision not to sanction the
pipeline was because the line was viewed as crucial to Turkey, a key U.S. ally. That explanation
was reinforced when direct Iranian gas exports to Turkey through the line began in 2001, and no
determination of sanctionability has been made. In May 2009, Iran and Armenia inaugurated a
natural gas pipeline between the two, built by Gazprom of Russia. No determination of
sanctionability has been announced.
As shown in Table 3, 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 reportedly remains under 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).
Iran and Kuwait have held talks on the construction of a 350-mile pipeline that would bring
Iranian gas to Kuwait. The two sides have apparently reached agreement on volumes (8.5 million
cubic meters of gas would go to Kuwait each day) but not on price.11 There are also discussions
reported between Iran and Iraq on constructing pipelines to facilitate oil and gas swaps between
the two, but no firm movement on these projects is evident.
Iran-India Pipeline
Another pending pipeline project would carry Iranian gas, by pipeline, to Pakistan. India had been
a part of the $7 billion project, which would take about three years to complete, but India was
reported in June 2010 to be largely out of the project. India did not sign a memorandum between
Iran and Pakistan finalizing the deal on June 12, 2010. India reportedly has been concerned about
the 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.

11 http://www.kuwaittimes.net/read_news.php?newsid=NDQ0OTY1NTU4; http://english.farsnews.com/newstext.php?
nn=8901181055.
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During the Bush Administration, Secretary of State Rice on several occasions “expressed U.S.
concern” about the pipeline deal or called it “unacceptable.” Possibly contributing to India’s
hesitancy to move forward, the late Ambassador Richard Holbrooke, the Administration Special
Representative on Pakistan and Afghanistan, during 2010 trips to Pakistan, raised the possibility
that the project could be sanctioned if it is undertaken, citing enactment of CISADA. Other steps
taken by India in late 2010 to prevent some banking transactions with Iran, discussed later, could
suggest that India is now cautious about any expansion of energy or other commercial relations
with Iran. Previously, the threat of imposition of U.S. sanctions had not dissuaded Indian firms
from taking some equity stakes in various Iranian energy projects, as shown in Table 3 below.
India may envision an alternative to the pipeline project, as a means of tapping into Iran’s vast gas
resources. During high-level economic talks in early July 2010, Iranian and Indian officials
reportedly raised the issue of constructing an underwater natural gas pipeline, which would avoid
going through Pakistani territory. However, such a route would presumably be much more
expensive to construct than would be an overland route.
European Gas Pipeline Routes
Iran also is attempting to position itself as a gas exporter to Europe. The Obama Administration,
like its predecessors, takes the view that Iran be excluded from gas pipeline projects to Europe,
even though the projects might make Europe less dependent on Russian gas supplies. One
potential project involving Iran is the Nabucco pipeline project, which would transport Iranian
gas to western Europe. Iran, Turkey, and Austria reportedly have negotiated on that project.
Another is the Trans-Adriatic Pipeline (TAP) although, as discussed below, partners in that
project have announced that Iranian gas would not be involved. 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.
Application to Iranian Firms or the Revolutionary Guard
Although ISA is widely understood to apply to firms around the world that reach an investment
agreement with Iran, the provisions could also be applied to Iranian firms and entities subordinate
to the National Iranian Oil Company (NIOC), which is supervised by the Oil Ministry. The firm
that was sanctioned, Naftiran Interrade Company (NICO), is one such entity; it is a subsidiary of
NIOC. However, such entities, including Naftiran, do not do business in the United States and
would not likely be harmed by any of the penalties that could be imposed under ISA. Some of the
other major components of NIOC are:
• The Iranian Offshore Oil Company;
• The National Iranian Gas Export Co.;
• National Iranian Tanker Company; and
• Petroleum Engineering and Development Co.
Actual construction and work is largely done through a series of contractors. Some of them, such
as Khatam ol-Anbia and Oriental Kish, have been identified by the U.S. government as controlled
by Iran’s Revolutionary Guard and have been sanctioned under various executive orders,
discussed below. The relationship of other Iranian contractors to the Guard, if any, is unclear.
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Some of the Iranian contractor firms include Pasargad Oil Co, Zagros Petrochem. Co, Sazeh
Consultants, Qeshm Energy, Sadid Industrial Group, and others.
Application to Liquefied Natural Gas
The original version of ISA did not apply to the development of liquefied natural gas. 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. However, CISADA, specifically includes LNG in the definition
of petroleum resources and therefore makes investment in LNG (or supply of LNG tankers or
pipelines) sanctionable.
Table 2. Comparison of Major Versions of H.R. 2194/P.L. 111-195
Final Law and
House Version
Senate Version
Implementation Status
General Goals and Overview:
Broader goals than House:
General y closer to the Senate
Seeks to expand the authorities of
sanctions sales of gasoline to Iran
version, but adds new provisions
the Iran Sanctions Act (ISA, P.L. 104-
similar to House version of H.R.
(not in either version) sanctioning
172) to deter sales by foreign
2194, but also would affect several
Iranians determined to be involved in
companies of gasoline to Iran.
other U.S. sanctions against Iran
human rights abuses and prohibiting
already in place, including revoking
transactions with foreign banks that
some exemptions to the U.S. ban on
conduct business with Revolutionary
imports from Iran.
Guard and U.N.-sanctioned Iranian
entities.
Statement of U.S. Policy on
Section 108 urges the President to
Section 104 (see below) contains
Sanctioning Iran’s Central Bank
use existing U.S. authorities to
sense of Congress urging U.S.
(Bank Markazi):
impose U.S. sanctions against the
sanctions against Iranian Central
Iranian Central Bank or other Iranian Bank and would prohibit U.S. bank
Section2(c) and 3(a) state that it
banks engaged in proliferation or
dealings with any financial institution
shall be U.S. policy to fully enforce
support of terrorist groups.
that helps the Central Bank facilitate
ISA to encourage foreign
circumvention of U.N. resolutions
governments:
Such authorities could include
on Iran.
Section 311 of the USA Patriot Act
- to cease investing in Iran’s energy
(31 U.S.C. 5318A), which authorizes
sector.
designation of foreign banks as “of
- to sanction Iran’s Central Bank and
primary money laundering concern”
other financial institutions that do
and thereby cut off their relations
business with the Iranian Central
with U.S. banks.
Bank (or any Iranian bank involved in
proliferation or support of terrorist
activities).
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Final Law and
House Version
Senate Version
Implementation Status
Extension of ISA to Sales of
Section 102(a) contains similar
Section 102(a) contains provisions
Gasoline:
provisions regarding both gasoline
amending ISA to include sales of
sales and sales of equipment and
gasoline and refining services and
Section 3(a) would amend ISA to
services for Iran to expand its own
equipment as sanctionable (similar to
make sanctionable:
refinery capacity. However, sets the
both versions). Sets dollar value
-the sale to Iran of equipment or
aggregate one-year sale value at $1
“trigger” at $1 million transaction, or
services (of over $200,000 in value,
million—double the level of the
$5 million aggregate value
or $500,000 combined sales in one
House bill.
(equipment or gasoline sales) in a
year) that would enable Iran to
one-year period.

maintain or expand its domestic
Specifies that what is sanctionable
production of refined petroleum.
includes helping Iran develop its
-or, the sale to Iran of refined
liquefied natural gas (LNG) sector.
petroleum products or ships,
Products whose sales is sanctionable
vehicles, or insurance or reinsurance
include LNG tankers and products
to provide such gasoline to Iran
to build pipelines used to transport
(same dollar values as sale of
oil or LNG. Includes aviation fuel in
equipment).
definition of refined petroleum.
Formally reduces investment
threshold to $20 million to trigger
sanctionability.
Expansion of ISA Sanctions:
Similar to House bill (Section
Section 102(b) amends ISA to add
102(a)).
add three sanctions to the existing
Section 3(b) would mandate certain
menu of six sanctions in ISA and
sanctions (not currently authorized
requires the President to impose 3
by ISA) on sel ers of the equipment,
out of the 9 specified sanctions on
gasoline, or services described in
entities determined to be violators.
Section 3(a) to include:
(As it previously existed, ISA
- prohibition of any transactions in
required the imposition of two out
foreign exchange with sanctioned
of six sanctions of the menu.)
entity;
- prohibition of credit or payments
to the sanctioned entity;
- and, prohibition on any
transactions involving U.S.-based
property of the sanctioned entity.
(These sanctions would be imposed
in addition to the required two out
of six sanctions currently specified in
ISA.)
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Final Law and
House Version
Senate Version
Implementation Status
U.S. Government Enforcement
Section 103(b)(4) contains a similar
Section 102(b) amends ISA by adding
Mechanism:
provision, but mandates that the
a provision similar to the House
head of a U.S. agency may not
version: requiring, within 90 days of
Section 3(b) also requires the heads
contract with a person who meets
enactment (by October 1, 2010) new
of U.S. Government agencies to
criteria of sanctionability in the act.
Federal Acquisition Regulations that
ensure that their agencies contract
Would not require the
mandate that firms to certify that
with firms that certify to the U.S.
bidding/contracting firm to certify its
they are not in violating of ISA as a
agency that they are not selling any
own compliance, thereby placing the
condition of receiving a U.S.
of the equipment, products, or
burden of verifying such compliance
government contract, and providing
services to Iran (gasoline and related on the U.S. executive agency.
for penalties for any falsification.
equipment and services) specified in
Section 3(a).

The Civilian Agency Acquisition
Council issued the needed
The section contains certain
regulations (interim ruling) on
penalties, such as prohibition on
September 29, 2010. Paperwork that
future bids for U.S. government
firms must sign making that
contracts, to be imposed on any firm
certification now included as part of
that makes a false certification about
their contract signature package.
such activity.
Additional Sanctions Against
No equivalent, although, as noted
Section 102(a)(2) amends ISA by
Suppliers of Nuclear, Missile, or
below, the Senate bill does contain
adding a prohibition on licensing of
Advanced Conventional
several proliferation-related
nuclear materials, facilities, or
Weapons Technology to Iran:
provisions.
technology to any country which is
the parent country of an entity
Section 3(c) provides an additional
determined to be sanctioned under
ISA sanction to be imposed on any
ISA for providing WMD technology
country whose entity(ies) violate ISA
to Iran.
by providing nuclear weapons-
related technology or missile
Waiver is provided on vital national
technology to Iran.
security interest grounds.
The sanction to be imposed on such
country is a ban on any nuclear
cooperation agreement with the
United States under the Atomic
Energy Act of 1954, and a
prohibition on U.S. sales to that
country of nuclear technology in
accordance with such an agreement.
The sanction can be waived if the
President certifies to Congress that
the country in question is taking
effective actions against its violating
entities.
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Final Law and
House Version
Senate Version
Implementation Status
Alterations to Waiver and
No similar provisions
Implementation and waiver
Implementation Provisions:
provisions closer to House version.
Section 102(g) amends ISA to make
Section 3(d)(1) imposes a
mandatory the beginning of an
requirement (rather than an non-
investigation of potentially
binding exhortation in the existing
sanctionable activity, and makes
law) that the Administration
mandatory a decision on
“immediately” initiate an
sanctionability within 180 days of the
investigation of any potentially
beginning of such an investigation.
sanctionable activity under ISA.
(Previously, 180 day period was non-
Section 3(d)(2) would require the
binding.)
President to certify that a waiver of
Mandatory investigation (which goes
penalties on violating entities
into effect July 1, 2011) of gasoline
described above is “vital to the
sales to Iran can be delayed for 180
national security interest of the
days subject to a report—by June 1,
United States.” rather than, as
2011—certifying that there has been
currently stipulated in ISA, is
a substantial reduction in gasoline
“important to the national interest
sales to Iran as a result of CISADA.
of the United States.”
Section 102(c) sets 9(c) waiver
standard as “necessary to the
national interest”
Section 102(g) also alters existing
4(c) ISA waiver to delay sanctions on
firms of countries that are “closely
cooperating” with U.S. efforts against
Iran’s WMD programs. (This is not
an automatic “carve out” for
cooperating countries.)
Section 102(g)(3) adds to ISA a
“special rule” that no investigation of
a potential violation need be started
if a firm has ended or pledged to end
its violating activity in/with Iran.
“Special rule” invoked twice, as
discussed above.
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Final Law and
House Version
Senate Version
Implementation Status
Required Reports:





Section 3(e) would amend ISA’s
Section 107 contains a provision
Various reporting requirements
current Administration reporting
similar to the new reporting
throughout (separate from those
requirements to also include an
requirement of the House bill with
required to trigger or justify the
assessment of Iran’s support for
regard to firms that sold gasoline and various sanctions or waivers). These
militant movements and to acquire
related equipment and services to
reporting requirements are:
weapons of mass destruction
Iran, and invested in Iran’s energy
technology.
sector.
- Amendment of section 10 of ISA to
include a report, within 90 days of
A new reporting requirement would
The Senate bill does not require
enactment, and annual thereafter, on
be created (every six months) on
reporting on the IRGC that is
trade between Iran and the countries
firms providing Iran gasoline and
stipulated in the House bill, or the
of the Group of 20 Finance Ministers
related equipment and services
report on Iran-G-20 trade.
and Central Bank Governors. (From
specified above, as well as the names
House version)
and dates of such activity, and any
However, the Senate bill (Section
contracts such entities have with
109) expresses the sense of
- Section 110 of the law (not an
U.S. Government agencies.
Congress that the United States
amendment to ISA) requires a report
“continue to target” the IRGC for
within 90 days, and every 180 days
The required report is to include
supporting terrorism, its role in
hence, on investments made in Iran’s
information on persons the
proliferation, and its oppressive
energy sector since January 1, 2006.
President determines is affiliated
activities against the people of Iran.
The report must include significant
with Iran’s Islamic Revolutionary
joint ventures outside Iran in which
Guard Corp (IRGC), as well as
Iranian entities are involved.
persons providing material support
to the IRGC or conducting financial
- The Section 110 report is to
transactions with the IRGC or its
include an estimate of the value of
affiliates.
ethanol imported by Iran during the
reporting period.
Also required is an Administration
report, within one year of
- Section 111 (not an ISA
enactment, on trade between Iran
amendment) requires a report within
and countries in the G-20.
90 days on the activities of export
credit agencies of foreign countries
in guaranteeing financing for trade
with Iran).

Expansion of ISA Definitions:





Section 3(f) would expand the
Similar provision contained in
Does not include export credit
definitions of investing entities, or
Section 102(d).
agencies as a sanctionable entity
persons, contained in ISA, to include:
under ISA (as amended). (However,
a report is required on export credit
- export credit agencies. (Such a
agency activity, as discussed above.)
provision is widely considered
controversial because export credit
Does include LNG as petroleum
agencies are arms of their
resources.
governments, and therefore
sanctioning such agencies is

considered a sanction against a
government.)
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Final Law and
House Version
Senate Version
Implementation Status
Termination Provisions:





Section 3(g) would terminate the
Title IV would terminate the act’s
Same as Senate version, which means
bill’s sanctions against persons who
provisions 30 days after the
that the amendments to ISA in this
are sanctioned, under the act, for
President certifies that Iran has:
law terminate if the President
sales of WMD-related technology, if
certifies that Iran has ceased WMD
the President certifies that Iran has
- ceased support for international
development, and has qualified for
ceased activities to acquire a nuclear
terrorism and qualifies for removal
removal from the U.S. terrorism list.
device and has ceased enrichment of
from the U.S. “terrorism list”
uranium and other nuclear activities.
However, the pre-existing version of
- and, has ceased the pursuit and
ISA would continue to apply until the
development of WMD and ballistic
President also certifies that Iran
missile technology.
poses no significant threat to U.S.
national security, interests, or allies.
ISA Sunset:





Section 3(h) would extend al
No similar provision.
Sunset provision same as House
provisions of ISA until December 31,
version ISA to sunset December 31,
2016. It is currently scheduled to
2016.
“sunset” on December 31, 2011, as
amended by the Iran Freedom
Support Act (P.L. 109-293).
Additional Provisions That Are Not Amendments to ISA
Modification to U.S. Ban on


Trade With and Investment in


Iran:



Section 103(b)(1) would ban al
Same as Senate version. However,
No provision
imports of Iranian origin from the
contains a new section that the
United States, with the exception of
existing U.S. ban (by Executive
informational material. Currently,
order) on most exports to Iran not
modifications to the U.S. trade ban
include the exportation of services
with Iran (Executive Order 12959 of
for Internet communications.
May 6, 1995) that became effective in
2000 permit imports of Iranian
Provision also states that the ban on
luxury goods, such as carpets, caviar,
most exports should not include
nuts, and dried fruits.
goods or services needed to help
non-governmental organizations
- Section 103(b)(2)) general y
support democracy in Iran.
reiterates/codifies current provisions
of U.S. trade ban related to U.S.
Both provisions designed to support
exports to Iran. Provision would
opposition protesters linked to Iran’s
prohibit exports to Iran of all goods
“Green movement.”
except food and medical devices,
Implementation: In July 2010,
informational material, articles used
Treasury Office of Foreign Assets
for humanitarian assistance to Iran,
Control issued a statement that,
or goods needed to ensure safe
effective September 29, 2010, the
operation of civilian aircraft.
general license for imports of Iranian
luxury goods will be eliminated (no
such imports allowed). This went
into effect that day.
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Final Law and
House Version
Senate Version
Implementation Status
Freezing of Assets/Travel
Section 103(b)(3) mandates the
Similar to Senate version
Restriction on Revolutionary
President to freeze the assets of
Guard and Related Entities and
Iranian diplomats, IRGC, or other
Persons:
Iranian official personnel deemed a
threat to U.S. national security under
No provision
the International Emergency
Economic Powers Act (50 U.S.C.
1701 et seq.). Provision would
require freezing of assets of families
and associates of persons so
designated. Section 109 calls for a
ban on travel of IRGC and affiliated
persons.
Application of U.S. Trade Ban
Section 104 would apply the
No provision
to Subsidiaries:
provisions of the U.S. trade ban with
Iran (Executive Order 12959) to

No provision
subsidiaries of U.S. firms if the
subsidiary is established or
maintained for the purpose of
avoiding the U.S. ban on trade with
Iran . The definition of subsidiary,
under the provision, is any entity
that is more than 50% owned or is
directed by a U.S. person or firm.
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Final Law and
House Version
Senate Version
Implementation Status
Mandatory Sanctions on
No provision
Section 104(c) requires the Treasury
Financial Institutions that Help
Department to develop regulations
Iran’s Sanctioned Entities:
(within 90 days of enactment) to
prohibit and specify penalties for any
No provision
U.S. financial transactions with any
foreign financial institution that
- facilitates efforts by the
Revolutionary Guard to acquire
WMD or fund terrorism
- facilitate the activities of any person
sanctioned under U.N. resolutions
on Iran.
- facilitates the efforts by Iran’s
Central Bank to support the Guard’s
WMD acquisition efforts or support
any U.N.- sanctioned entity
Section 104(d) requires penalties to
be specified in regulations within 90
days.
Section 104(e) requires regulations
(no date specified) to make this
requirement retroactive to existing
accounts, pending an audit by the
U.S. banks involved.
Implementation: Treasury
Department regulations
implementing Section 104(c) and (d)
provisions issued August 16, 2010.
Regulations to implement 104(e)
were proposed by Treasury
Department’s Financial Crimes
Enforcement Network (FINCEN) on
April 27, 2011.
Sanctions on Iranian Human
No provision
Section 105 requires, within 90 days,
Rights Abusers:
a report listing Iranian officials (or
affiliates) determined responsible for
No provision
or complicit in serious human rights
abuses since the June 12, 2009,
Iranian election. Those listed are
ineligible for a U.S. visa, their U.S,
property is to be blocked, and
transactions with those listed are
prohibited.
On September 29, 2010, President
Obama issued Executive Order
13553 providing for these sanctions.
See human rights section of this
paper for Iranians sanctioned.
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Final Law and
House Version
Senate Version
Implementation Status
Sanctioning Certain
Section 105 prohibits U.S. executive
Section 106 of the conference report
Information Technology Sales
agencies from contracting with firms
is similar to Senate version.
to Iran:
that export sensitive technology to
Iran. “Sensitive technology” is
The contracting restriction is to be
No provision
defined as hardware, software,
imposed “pursuant to such
telecommunications equipment, or
regulations as the President may
other technology that restricts the
prescribe.”
free flow of information in Iran or
The contracting regulations issued
which monitor or restrict “speech”
September 29, 2010, “partial y”
of the people of Iran.
implement this requirement, with
further regulations to be issued.
Treasury Department
Section 106(b) authorizes $64.611
Section 109 authorizes $102 million
Authorization to prevent
million for FY2010 (and “such sums
for FY2011 and “sums as may be
misuse of the U.S. financial
as may be necessary” for FY2011 and necessary” for FY2012 and 2013 to
system by Iran or other
2012) for the Treasury Department’s the Treasury Department Office of
countries:
Office of Terrorism and Financial
Terrorism and Financial Intelligence.
Intelligence. The funds are
Another $100 million is authorized
No provision
authorized to ensure that countries
for FY2011 for the Financial Crimes
such as Iran are not misusing the
Enforcement Network, and $113
international financial system for
million for FY2011 for the Bureau of
illicit purposes. Iran is not mentioned Industry and Security for the
specifically. $104.26 million is
Department of Commerce
authorized by the section for FY2010
for the Department’s Financial
Crimes Enforcement Network.
Hezbollah:
Section 110 contains a sense of
Section 113 similar to Senate
Congress that the President impose
version.
No specific provision, although, as
the ful range of sanctions under the
noted above, the House bill does
International Emergency Economic
expand ISA reporting requirements
Powers Act (50 U.S.C. 1701) on
to include Iran’s activities to support
Hezbol ah, and that the President
terrorist movements. Lebanese
renew international efforts to disarm
Hezbollah is named as a Foreign
Hezbollah in Lebanon (as called for
Terrorist Organization (FTO) by the by U.N. Security Council Resolutions
U.S. State Department.
1559 and 1701).
Divestment:
Title II of the Senate bill (Section
Similar to Senate version
203) prevents criminal, civil, or
No provisions
administrative action against any
investment firm or officer or adviser
based on its decision to divest from
securities that
- have investments or operations in
Sudan described in the Sudan
Accountability and Divestment Act
of 2007
- or, engage in investments in Iran
that would be considered
sanctionable by the Senate bill.
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Final Law and
House Version
Senate Version
Implementation Status
Prevention of Transshipment,
Section 302 requires a report by the
Similar to Senate version, but does
Reexportation, or Diversion of
Director of National Intelligence that not provide for prior negotiations
Sensitive Items to Iran:
identifies all countries considered a
before designating a country as a
concern to al ow transshipment or
“Destination of Possible Diversion
No provision
diversion of WMD-related
Concern.”
technology to Iran (technically:
“items subject to the provision of
List of countries that are believed to
the Export Administration
be allowing diversion of specified
Regulations”).
goods or technology to Iran to be
named in a report provided within
Section 303 requires the Secretary of 180 days of enactment.
Commerce to designate a country as
a “Destination of Possible Diversion

Concern” if such country is
considered to have inadequate
export controls or is unwilling to
prevent the diversion of U.S.
technology to Iran. The provision
stipulates government-to-
government discussions are to take
place to improve that country’s
export control systems.
If such efforts did not lead to
improvement, the section would
mandate designation of that country
as a “Destination of Diversion
Concern” and would set up a strict
licensing requirement for U.S.
exports of sensitive technologies to
that country.









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Table 3. Post-1999 Major Investments/Major Development Projects in
Iran’s Energy Sector
Company(ies)/Status
Date Field/Project
(If Known)
Value
Output/Goal
February Doroud (oil)
Total (France)/ENI
$1 billion
205,000 bpd
1999
(Italy)
(Energy Information Agency, Department of
Energy, August 2006.)
Total and ENI exempted from sanctions on
September 30 because of pledge to exit Iran
market
April
Balal (oil)
Total/ Bow Valley
$300 million
40,000 bpd
1999
(Canada)/ENI
(“Balal Field Development in Iran
Completed,” World Market Research Centre,
May 17, 2004.)
Nov.
Soroush and Nowruz (oil)
Royal Dutch Shell
$800 million
190,000 bpd
1999
(Netherlands)/Japex
(“News in Brief: Iran.” Middle East Economic
(Japan)
Digest, (MEED) January 24, 2003.)
Royal Dutch exempted from sanctions on
9/30 because of pledge to exit Iran market
April
Anaran bloc (oil)
Norsk Hydro and
$105 million
65,000
2000
Statoil (Norway) and
(MEED Special Report, December 16, 2005,
Gazprom and Lukoil
pp. 48-50.)
(Russia) No production
to date; Statoil and
Norsk have left project.
July
Phase 4 and 5, South Pars (gas)
ENI
$1.9 billion
2 billion
2000
cu.ft./day (cfd)
(Petroleum Economist, December 1, 2004.)
Gas onstream as of
Dec. 2004
ENI exempted 9/30 based on pledge to exit
Iran market
March
Caspian Sea oil exploration—
GVA Consultants
$225 million
NA
2001
construction of submersible drilling rig for
(Sweden)
Iranian partner
(IPR Strategic Business Information
Database, March 11, 2001.)
June
Darkhovin (oil)
ENI
$1 billion
100,000 bpd
2001
(“Darkhovin Production Doubles.” Gulf
Field in production
Daily News, May 1, 2008.) ENI told CRS in
April 2010 it would close out al Iran
operations by 2013.
ENI exempted from sanctions on 9/30, as
discussed above
May
Masjid-e-Soleyman (oil)
Sheer Energy
$80 million
25,000 bpd
2002
(Canada)/China
(“CNPC Gains Upstream Foothold.” MEED,
National Petroleum
September 3, 2004.)
Company (CNPC).
Local partner is
Naftgaran Engineering
Sept.
Phase 9 + 10, South Pars (gas)
LG Engineering and
$1.6 billion
2 billion cfd
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Company(ies)/Status
Date Field/Project
(If Known)
Value Output/Goal
2002
(“OIEC Surpasses South Korean Company in Construction Corp.
South Pars.” IPR Strategic Business
(now known as GS
Information Database, November 15, 2004.)
Engineering and
Construction Corp.,
South Korea)
On stream as of early
2009
October Phase 6, 7, 8, South Pars (gas)
Statoil (Norway)
$750 million
3 billion cfd
2002
(Source: Statoil, May 2011)

Field began producing late 2008; operational
control handed to NIOC in 2009. Statoil
exempted from sanctions on 9/30/2010
because Statoil pledged to exit Iran market.
January
Azadegan (oil)
Inpex (Japan) 10%
$200 million
260,000 bpd
2004
stake. CNPC agreed to
(Inpex stake);
(“Japan Mulls Azadegan Options.” APS
develop “north
China $1.76
Review Oil Market Trends, November 27,
Azadegan” in Jan. 2009
billion
2006.)
October 15, 2010: Inpex announced it would
exit the project by selling its stake; “special
rule” exempting it from ISA investigation
invoked November 17, 2010.
August
Tusan Block
Petrobras (Brazil)
$178 million
No
2004
production
Oil found in block in Feb. 2009, but not in

commercial quantity, according to the firm.
(“Iran-Petrobras Operations.” APS Review
Gas Market Trends, April 6, 2009; “Brazil’s
Petrobras Sees Few Prospects for Iran Oil,”
(http://www.reuters.com/article/
idUSN0317110720090703.)
October Yadavaran (oil)
Sinopec (China), deal
$2 billion
300,000 bpd
2004
finalized December 9,
(“Iran, China’s Sinopec Ink Yadavaran
2007
Oilfield Development Contract.” Payvand’s
Iran News, December 9, 2009.)
2005
Saveh bloc (oil)
PTT (Thailand)
?
?
GAO report, cited below
June
Garmsar bloc (oil)
Sinopec (China)
$20 million
?
2006
Deal finalized in June 2009
(“China’s Sinopec signs a deal to develop oil
block in Iran—report,” Forbes, 20 June
2009, http://www.forbes.com/feeds/afx/2006/
06/20/afx2829188.html.)
July
Arak Refinery expansion
Sinopec (China); JGC
$959 million
Expansion to
2006
(Japan)
produce
(GAO report; Fimco FZE Machinery
250,000 bpd
website; http://www.fimco.org/index.php?
option=com_content&task=view&id=70&
Itemid=78.)
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Company(ies)/Status
Date Field/Project
(If Known)
Value Output/Goal
Sept.
Khorramabad block (oil)
Norsk Hydro and
$49 million
?
2006
Statoil (Norway).
Seismic data gathered, but no production is
planned. (Statoil factsheet, May 2011)
Feb.
LNG Tanks at Tombak Port
Daelim (S. Korea)
$320 million
200,000 ton
2007
capacity
Contract to build three LNG tanks at
Tombak, 30 miles north of Assaluyeh Port.
(May not constitute “investment” as defined
in pre-2010 version of ISA, because that
definition did not specify LNG as “petroleum
resource” of Iran.)
“Central Bank Approves $900 Million for
Iran LNG Project.” Tehran Times, June 13,
2009.
March
Esfahan refinery upgrade
Daelim (S. Korea)

NA
2007
(“Daelim, Others to Upgrade Iran’s Esfahan
Refinery.” Chemical News and Intelligence,
March 19, 2007.)
Dec.
Golshan and Ferdows onshore and
SKS Ventures,
$16 billion
3.4 billion cfd
2007
offshore gas fields and LNG plant
Petrofield Subsidiary
(Malaysia)
contract modified but reaffirmed December
2008
(GAO report; Oil Daily, January 14, 2008.)
2007
Jofeir Field (oil)
Belarusneft (Belarus)
$500 million
40,000 bpd
(unspec.)
under contract to
GAO report cited below. Belarusneft, a
Naftiran.
subsidiary of Belneftekhim, sanctioned under
ISA on March 29, 2011. Naftiran sanctioned
No production to date
on September 29, 2010 for this and other
activities.
2008
Dayyer Bloc (Persian Gulf, offshore,
Edison (Italy)
$44 million
?
oil)
GAO report cited below
February Lavan field (offshore natural gas)
PGNiG (Poland)
$2 billion

2008
GAO report cited below
Status unclear
March
Danan Field (on-shore oil)
Petro Vietnam
? ?
2008
Exploration and
“PVEP Wins Bid to Develop Danan Field.”
Production Co.
Iran Press TV, March 11, 2008
(Vietnam)
April
Moghan 2 (onshore oil and gas, Ardebil INA (Croatia)
$40-$140
?
2008
province)
million
(dispute over
GAO report cited below
size)
?
Kermanshah petrochemical plant (new Uhde (Germany)

300,000
construction)
metric tons/yr
GAO report cited below
January
“North Azadegan”
CNPC (China)
$1.75 billion
75,000 bpd
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Company(ies)/Status
Date Field/Project
(If Known)
Value Output/Goal
2009
(Chinadaily.com. “CNPC to Develop
Azadegan Oilfield,”
http://www.chinadaily.com.cn/bizchina/2009-
01/16/content_7403699.htm.)
Oct.
South Pars Gas Field—Phases 6-8, Gas
G and S Engineering
$1.4 billion

2009
Sweetening Plant
and Construction
(South Korea)
CRS conversation with Embassy of S. Korea
in Washington, D.C, July 2010
Contract signed but then abrogated by S.
Korean firm
Nov.
South Pars: Phase 12—Part 2 and Part
Daelim (S. Korea)—
$4 billion ($2
2009
3
Part 2; Tecnimont
bn each part)
(Italy)—Part 3
(“Italy, South Korea To Develop South Pars
Phase 12.” Press TV (Iran), November 3,
2009, http://www.presstv.com/pop/Print/?id=
110308.)
February South Pars: Phase 11
CNPC (China)
$4.7 billion

2010
Drilling to Begin in March 2010
(“CNPC in Gas Deal, Beefs Up Tehran
Team—Source,” Reuters India, February 10,
2010, http://in.reuters.com.articlePrint?
articleId=INTOE61909U20100210.)
Totals: $41 billion investment
Other Pending/Preliminary Deals
North Pars Gas Field (offshore gas). Includes gas
China National
$16 billion
3.6 billion cfd
purchases (December 2006)
Offshore Oil Co.
(http://english.peopledaily.com.cn/200705/19/
print20070519_376139.html.)
Phase 13, 14—South Pars (gas); (Feb. 2007).
Royal Dutch Shell,
$4.3 billion
?
Repsol (Spain)
Deadline to finalize as May 20, 2009, apparently not met;
firms submitted revised proposals to Iran in June 2009.
(http://www.rigzone.com/news/article.asp?a_id=77040&
hmpn=1.)
State Department said on September 30, 2010, that
Royal Dutch Shell and Repsol have ended negotiations
with Iran and will not pursue this project any further
Phase 22, 23, 24—South Pars (gas), incl. transport
Turkish Petroleum
$12. billion
2 billion cfd
Iranian gas to Turkey, and on to Europe and building
Company (TPAO)
three power plants in Iran. Initialed July 2007; not
finalized to date.
Iran’s Kish gas field (April 2008) Includes pipeline
Oman (co-financing of
$7 billion
1 billion cfd
from Iran to Oman
project)
(http://www.presstv.ir/detail.aspx?id=112062&sectionid=
351020103.)
Phase 12 South Pars (gas)—part 1. Incl. LNG
Taken over by Indian
$8 billion+
20 million
terminal construction and Farzad-B natural gas bloc
firms (ONGC, Oil India
tonnes of
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Company(ies)/Status
Date Field/Project
(If Known)
Value Output/Goal
(March 2009). Financing stal ed due to sanctions; Tehran
Ltd., Hinduja, Petronet
LNG annual y
gave ONGC and Hinduja until January 31, 2011, to line
in 2007)
by 2012
up financing or the bid will be considered abandoned.
South Pars gas field (September 2009)
Petroleos de Venezuela $760 million

S.A.; 10% stake in
venture
Abadan refinery
Sinopec
up to $6

billion if new
Upgrade and expansion; building a new refinery at
refinery is
Hormuz on the Persian Gulf coast (August 2009)
built
Sources: As noted in table, as wel as CRS conversations with officials of the State Department Bureau of
Economics, and officials of embassies of the parent government of some of the listed companies (2005-2009).
Some information comes from a March 2010 GAO report, “Firms Reported in Open Sources as Having
Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors.” GAO-10-515R Iran’s Oil, Gas, and
Petrochemical Sectors. http://www.gao.gov/new.items/d10515r.pdf. The GAO report lists 41 firms with
“commercial activity in Iran’s energy sector; several of the listed agreements do not appear to constitute
“investment,” as defined in ISA.
Note: CRS has neither the mandate, the authority, nor the means to determine which of these projects, if any,
might constitute a violation of the Iran Sanctions Act. 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. In virtual y al cases, such investments and contracts represent private agreements between Iran and
its instruments and the investing firms, and firms are not necessarily required to confirm or publicly release the
terms of their arrangements with Iran. Reported $20 million+ investments in oil and gas fields, refinery upgrades,
and major project leadership are included in this table. Responsibility for a project to develop Iran’s energy
sector is part of ISA investment definition.

Ban on U.S. Trade and Investment With Iran
A ban on U.S. trade with and investment in Iran was imposed on May 6, 1995, by President
Clinton, through Executive Order 12959.12 This followed an earlier March 1995 executive order
barring U.S. investment in Iran’s energy sector. The trade and investment 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 10, 2010), the U.S.
Administration has renewed a declaration of a state of emergency that triggered the investment
ban; it is likely to be renewed again in March 2011. The operation of the trade regulations is
stipulated in Section 560 of the Code of Federal Regulations (Iranian Transactions Regulations,
ITR’s). As noted above, in accordance with CISADA, the strict ban on imports from Iran was
restored on September 29, 2010; the ban on exports to Iran was altered only slightly by CISADA.

12 The executive order was issued under the authority of: 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.; Section 505 of the International Security
and Development Cooperation Act of 1985 (22 U.S.C. 2349aa-9) and Section 301 of Title 3, United States Code. 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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Some modifications to the trade ban since 1999 account for the fact that trade between the United
States and Iran is minimal. Total U.S.-Iran trade was about $300 million in 2010 ($208 million in
exports to Iran, and $94 million in imports). Trade was about $350 million worth of goods for all
of 2009 ($281 million in exports to Iran, and $67 million in imports from Iran). That is about half
the value of the bilateral trade in 2008.
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 (Section 560.528 of Title 31, C.F.R.). 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). (A provision of H.R. 6296, a bill introduced in the 111th Congress,
sought to prevent these sales to Iran.) An Administration intent to sell Iran data to
repair certain GE engines for its legacy American-made aircraft, in order to
ensure safe operation, was notified to Congress on March 16, 2011.
• U.S. firms may not negotiate with Iran or to trade Iranian oil overseas, but U.S.
companies may apply for licenses to conduct “swaps” of Caspian Sea oil with
Iran. A Mobil Corporation application to do so was denied in April 1999.
• According to the Iranian Transactions Regulations (ITR’s), the ban does not
apply to personal communications (phone calls, e-mails), or to humanitarian
donations. U.S. non-government organizations (NGOs) require a specific license
to operate in Iran, and some NGOs say the licensing requirements are too
onerous to make work in Iran practical.
• 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.
• OFAC generally declines to discuss export licenses approved, and a press
account on December 24, 2010,13 paints a picture of broad export approvals to
Iran of such condiments as ice cream sprinkles, chewing gum, food additives, hot
sauces, body-building supplements, and other goods that appear to have uses
other than those that are purely humanitarian or nutritive. U.S. exporters widely
mentioned include Mars Co. (candy manufacturer); Kraft Foods; Wrigley’s
(gum); and McCormick and Co. (spices). Some goods were sold through a
Revolutionary Guard-owned chains of stores in Iran called Qods; as well as a
government owned Shahrvand store and a chain called Refah. OFAC officials
indicated in the press accounts that such licenses were not in contradiction with
U.S. law or policy, although there might have been less than full scrutiny of some

13 The information in this bullet is taken from: Becker, Jo. “With U.S. Leave, Companies Skirt Iran Sanctions.” New
York Times, December 24, 2010.
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Iran Sanctions

Iranian end users and that such scrutiny might be increased in future licensing
decisions.
• As far as financing of approved U.S. sales to 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. No U.S.
Administration has authorized credit guarantees, to date. In December 2004, the
trade ban was further modified to allow Americans to freely engage in ordinary
publishing activities with entities in Iran (and Cuba and Sudan).
• In April 2000, the trade ban was further eased to allow U.S. importation of
Iranian nuts, dried fruits, carpets, and caviar. Financing was permitted for U.S.
importers of these goods. 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. As discussed
above, CISADA ended approval of such imports as of October 1, 2010. Prior to
the entry into force of this CISADA provision, the number one U.S. import from
Iran was pomegranate juice concentrate. Iranian carpets were another popular
import, despite a U.S. tariff of about 3%-6%. Imports of Iranian caviar carried a
duty of about 15%.
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. Foreign subsidiaries are
generally considered foreign persons, not U.S. persons. The March 7, 2010, New York Times
article, cited above, discusses some subsidiaries of U.S. firms that have been active in Iran and
which have also received U.S. government contracts, grants, loans, or loan guarantees. Among
major foreign subsidiaries of U.S. firms that have traded with Iran are the following:
• U.S. energy equipment firms. Some subsidiaries of such firms may still be in the
Iranian market, according to their “10-K” filings with the Securities and
Exchange Commission. These include Natco Group,14 Overseas Shipholding
Group,15 UOP (United Oil Products, a Honeywell subsidiary based in Britain),16
Itron17, Fluor,18 Flowserve,19 Parker Drilling, Vantage Energy Services,20

14 Form 10-K Filed for fiscal year ended December 31, 2008.
15 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.
16 New York Times, March 7, 2010, cited previously.
17 Subsidiaries of the Registrant at December 31, 2009. http://www.sec.gov/Archives/edgar/data/780571/
000078057110000007/ex_21-1.htm.
18 “Exhibit to 10-K Filed February 25, 2009.” Officials of Fluor claim that their only dealings with Iran involve
property in Iran owned by a Fluor subsidiary, which the subsidiary has been unable to dispose of. CRS conversation
with Fluor, December 2009.
19 Form 10-K for Fiscal year ended December 31, 2009.
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Weatherford,21and a few others. UOP reportedly sells refinery equipment to Iran;
new such sales are now potentially sanctionable under ISA, as modified by
CISADA.
• 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.
• Transammonia Corp., via a Swiss-based subsidiary, is said to be conducting
business with Iran to help it export ammonia, a growth export for Iran.
Subsidiaries Exiting Iran
As international sanctions against Iran have increased in recent years, many foreign subsidiaries
have decided that the risks of continuing to do business with Iran outweigh the benefits:
• Chemical manufacturer Huntsman announced in January 2010 its subsidiaries
would halt sales to Iran.
• 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)22—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
were, 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 preexisting 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.
• Oilfield services firm Smith International said on March 1, 2010, it would stop
sales to Iran by its subsidiaries.
• On March 1, 2010, Caterpillar Corp. said it had altered its policies to prevent
foreign subsidiaries from selling equipment to independent dealers that have been
reselling the equipment to Iran.23 Ingersoll Rand, maker of air compressors and
cooling systems, followed suit.24

(...continued)
20 Form 10-K for Fiscal year ended December 31, 2007.
21 Form 10-K for Fiscal year ended December 31, 2008, claims firm directed its subsidiaries to cease new business in
Iran and Cuba, Syria, and Sudan as of September 2007.
22 “Iran Says Halliburton Won Drilling Contract.” Washington Times, January 11, 2005.
23 “Caterpillar Says Tightens ‘No-Iran’ Business Policy.” Reuters, March 1, 2010.
24 Nixon, Ron. “2 Corporations Say Business With Tehran Will Be Curbed.” New York Times, March 11, 2010.
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• In April 2010, it was reported that foreign partners of several U.S. or other
multinational accounting firms had cut their ties with Iran, including KPMG of
the Netherlands, and local affiliates of U.S. firms PricewaterhouseCoopers and
Ernst and Young.25
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 by the parent company to trade with Iran. The Senate version of
CISADA contained a similar provision, but it was taken out in conference action. A provision of
H.R. 6296, the bill introduced in the 111th Congress, would apply this sanction, and there
reportedly is consideration of introducing similar legislation in the 112th Congress.
Banking and Finance: Treasury Department
Financial Measures and CISADA
U.S. efforts to shut Iran out of the international banking system—gaining strength as other
countries have joined the effort—have been implemented by the Treasury Department (office of
then-Under Secretary of the Treasury Stuart Levey) through “targeted financial measures.” Since
2006, strengthened by leverage provided in five U.N. Security Council Resolutions, Levey and
other officials have been able to convince at least 80 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”26 with regard to
targeting Iran’s proliferation networks. Some fear that U.S. sanctions may not be as vigorously
enforced now that Levey has left office as of April 2011. His replacement is Daniel Cohen.
In earlier 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.27 Bank Sepah is subject to asset freezes and transactions
limitations as a result of Resolutions 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). 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. Several European countries reportedly still oppose such a sanction as
an extreme step with potential humanitarian consequences, for example by preventing Iran from
keeping its currency stable. S. 3445, a Senate bill in the 110th Congress, and a counterpart passed
by the House on September 26, 2008 (H.R. 7112), called for this sanction. The Senate version of

25 Baker, Peter. “U.S. and Foreign Companies Feeling Pressure to Sever Ties With Iran.” New York Times, April 24,
2010.
26 Hearing of the Financial Services and General Government Subcommittee of the House Appropriations Committee,
Federal News Service, May 21, 2009.
27 Kessler, Glenn. “U.S. Moves to Isolate Iranian Banks.” Washington Post, September 9, 2006.
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H.R. 2194 had a similar provision, which was included in conference action. Resolution 1929
references the need for vigilance in dealing with Iran’s Central Bank but does not mandate any
new sanctions against it.
The Treasury Department has also used punishments to pressure firms to cease doing business
with Iran. 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 the biggest such instance, on December 16, 2009, the Treasury Department
announced that Credit Suisse would pay a $536 million settlement to the United States for illicitly
processing Iranian transactions with U.S. banks. Credit Suisse, according to the Treasury
Department, saw business opportunity by picking up the transactions business from a competitor
who had, in accordance with U.S. regulations discussed below, ceased processing dollar
transactions for Iranian banks. Credit Suisse also pledged to cease doing business with Iran.
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 UK-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.
Banking Provisions of CISADA
Section 104 of CISADA is a section of that law that, in the aggregate, would seek to exclude
foreign banks from operating in the United States if these banks conduct transactions with Iranian
entities that are subject to international or U.S. sanctions. The premise of the provision was that
cutting off Iran’s access to the international financial system would make it more difficult for Iran
to move its money. The binding provisions of Section 104 require the Secretary of the Treasury to
prescribe several sets of regulations. Section 104 states that these regulations must forbid U.S.
banks from opening new “correspondent accounts” or “payable through accounts”—or force the
cancellation of existing such accounts—with foreign banks that process “significant transactions”
with several categories of Iranian (or other) entities. Foreign banks that do not have operations in
the United States typically establish such accounts with U.S. banks as a means of accessing the
U.S. financial system and financial industry. The entities with which transactions would trigger
the sanctions are:
• The Islamic Revolutionary Guard Corps (IRGC) or any of its agents or affiliates
that are sanctioned under U.S. executive orders. The two executive orders that
have served as the principal source of U.S. sanctions against Iranian firms and
organizations are Executive Order 13224 (September 23, 2001) and 13382 (June
28, 2005), discussed elsewhere in this paper.
• Any entity that is sanctioned by U.S. executive orders such as the two mentioned
above. To date, over 125 entities (including individuals), almost all of them Iran-
based or of Iranian origin, have been designated for Iran-related proliferation or
terrorism activities under these orders.
• Any entity designated under the various U.N. Security Council resolutions
adopted to impose sanctions on Iran.
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• Any entity that assists Iran’s Central Bank in efforts to help the IRGC acquire
weapons of mass destruction or support international terrorism.
Terrorism List Designation-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 (P.L. 96-72, as
amended), 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 through presidential authorities under the
International Emergency Economic Powers Act, IEEPA, as implemented by
executive orders), and, under other laws, bans direct U.S. financial assistance
(Section 620A of the Foreign Assistance Act, FAA, P.L. 87-195) and arms sales
(Section 40 of the Arms Export Control Act, P.L. 95-92, as amended), and
requires the United States to vote to oppose multilateral lending to the designated
countries (Section 327 of the 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, Ex-Im Bank 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 (Sections 325 and 326 of
P.L. 104-132) 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. 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. In the Bam case, there was also a temporary exemption made in
the regulations to allow for a general licensing (no need for a specific license) for donations to
Iran of humanitarian goods by American citizens and organizations. Those exemptions were
extended several times but expired in March 2004. When that expiration occurred, the policy
reverted to a requirement for specific licensing (application to OFAC) and approval process for
donations and operations in Iran of U.S.-based humanitarian NGO’s.
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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. This order, issued two weeks after the September 11 attacks, 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, was intended to primarily target Al Qaeda-related entities.
However, it has increasingly been applied to Iranian entities. Such Iran-related entities named and
sanctioned under this order are in Table 6 at the end of this report, which also contains the names
of Iranian entities sanctioned under other orders and under United Nations resolutions pertaining
to Iran’s nuclear program.
Proliferation-Related U.S. Sanctions
Iran is prevented from receiving advanced technology from the United States under relevant and
Iran-specific anti-proliferation laws28 and by Executive Order 13382 (June 28, 2005). Some of
these laws and executive measures seek to penalize foreign firms and countries that provide
equipment to Iran’s WMD programs.
Iran-Iraq Arms Nonproliferation Act
The Iran-Iraq Arms Nonproliferation Act (P.L. 102-484) imposes a number of sanctions on
foreign entities that supply Iran with WMD technology or “destabilizing numbers and types of
conventional weapons.” Sanctions imposed on violating entities include a ban, for two years, on
U.S. government procurement from that entity, and a two-year ban on licensing U.S. exports to
that entity. A sanction to ban imports to the United States from the entity is authorized.
If the violator is determined to be a foreign country, sanctions to be imposed are a one-year ban
on U.S. assistance to that country; a one-year requirement that the United States vote against
international lending to it; a one-year suspension of U.S. co-production agreements with the
country; a one-year suspension of technical exchanges with the country in military or dual use
technology; and a one-year ban on sales of U.S. arms to the country. The President is also
authorized to deny the country most-favored-nation trade status; and to impose a ban on U.S.
trade with the country.
The Iran-Iraq Arms Nonproliferation Act (Section 1603) also provides for a “presumption of
denial” for all dual use exports to Iran (which would include computer software). A waiver to
permit such exports, on a case-by-case basis, is provided for.
Iran-Syria-North Korea Nonproliferation Act
The Iran Nonproliferation Act (P.L. 106-178), now called the Iran-Syria-North Korea Non-
Proliferation Act) authorizes sanctions on foreign persons (individuals or corporations, not
countries or governments) that are determined by the Administration to have assisted Iran’s

28 Such laws include the Atomic Energy Act of 1954 and the Energy Policy Act of 2005 (P.L. 109-58).
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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.29 (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
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
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. Table
6 lists Iran-related entities sanctioned under the order.
Foreign Aid Restrictions for Suppliers of Iran
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.
U.S. 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).30 The concept of these sanctions is to
express the view of Western and other democracies that Iran is an outcast internationally.
Legislation in the 110th Congress, H.R. 1400, did not require divestment, but would have required
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. It passed
the House on October 14, 2009, by a vote of 414-6. A similar bill. S. 1065, was introduced in the
Senate. Provisions along these lines was contained in CISADA (P.L. 111-195)—in particular

29 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.
30 For information on the steps taken by individual states, see National Conference of State Legislatures. State
Divestment Legislation.
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providing a “safe harbor” for investment managers who sell shares of firms that invest in Iran’s
energy sector (as defined by ISA, as amended by CISADA).
U.S. Sanctions Intended to Support Democratic
Change in Iran
A trend since the June 2009 Iran election dispute has been to promote the prospects for the
domestic opposition in Iran. Proposals to target the Revolutionary Guard for sanctions, discussed
throughout, represent one facet of the trend toward measures that undermine the legitimacy of
Iran’s regime and support Iran’s domestic opposition. The Revolutionary Guard is involved in
Iran’s WMD programs but it is also the key instrument through which the regime has suppressed
the pro-democracy movement. Several measures to support the opposition’s ability to
communicate, to reduce the regime’s ability to monitor or censor Internet communications, and to
identify and sanction Iranian human rights abusers were included in CISADA.
Earlier legislation, the Iran Freedom Support Act (IFSA, P.L. 109-293), represented a
congressional effort to promote the prospects for opponents of the regime. That law authorized
“sums as may be necessary” to assist Iranians who are “dedicated” to “democratic values … and
the adoption of a democratic form of government in Iran”; and “advocates the adherence by Iran
to nonproliferation regimes….”
Expanding Internet and Communications Freedoms
Some Members have focused on expanding Internet freedom in Iran or preventing the Iranian
government from using the Internet to identify opponents. Subtitle D of the FY2010 Defense
Authorization Act (P.L. 111-84), called the “VOICE” (Victims of Iranian Censorship) Act
contains several provisions to increase U.S. broadcasting to Iran and to identify (in a report to be
submitted 180 days after enactment, or April 25, 2009) companies that are selling Iran technology
equipment that it can use to suppress or monitor the internet usage of Iranians. The VOICE Act
authorized funds to document Iranian human rights abuses since the June 12, 2009, presidential
election. Another provision of P.L. 111-84 (Section 1241) required an Administration report, not
later than January 31, 2010, on U.S. enforcement of sanctions against Iran, and the effect of those
sanctions on Iran.
In the 111th Congress, the “Reduce Iranian Cyber-Suppression Act,” (S. 1475 and H.R. 3284) was
incorporated into CISADA. It authorizes the President to ban U.S. government contracts with
foreign companies that sell technology that Iran could use to monitor or control Iranian usage of
the internet. Another provision of CISADA exempts from the U.S. export ban on Iran equipment
to help Iranians communicate and use the Internet. The provisions were directed, in part, against
firms, including a joint venture between Nokia (Finland) and Siemens (Germany), reportedly sold
Internet monitoring and censorship technology to Iran in 2008.31 Perhaps to avoid further
embarrassment, Siemens announced on January 27, 2010, that it would stop signing new business
deals in Iran as of mid-2010.32

31 Rhoads, Christopher. “Iran’s Web Spying Aided by Western Technology.” Wall Street Journal, June 22, 2009.
32 End, Aurelia. “Siemens Quits Iran Amid Mounting Diplomatic Tensions.” Agence France Press, January 27, 2010.
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Also in line with this trend, on March 8, 2010, OFAC amended the Iran Transactions Regulations
that implement the U.S.-Iran trade ban to provide for a general license for providing to Iranians
free mass market software in order to facilitate internet communications. The ruling appeared to
incorporate the major features of a proposal in the 111th Congress, H.R. 4301, the “Iran Digital
Empowerment Act.” The OFAC determination required a waiver of the provision of the Iran-Iraq
Arms Nonproliferation Act (Section 1606 waiver provision) discussed above.
Measures to Sanction Human Rights Abuses and
Promote the Opposition
Another part of the effort to help Iran’s opposition has been legislation to sanction regime
officials involved in suppressing the domestic opposition in Iran. Senator John McCain proposed
to offer amendments to S. 2799 (the Senate version of what became H.R. 2194) to focus on
banning travel and freezing assets of those Iranians determined to be human rights abusers. These
provisions were included in the conference report on CISADA. The provisions were similar to
those of Senator McCain’s earlier stand alone bill, S. 3022, the “Iran Human Rights Sanctions
Act.” Companion measures in the House were H.R. 4647 and H.R. 4649.
On September 29, 2010, the Administration implemented the CISADA provision when President
Obama signed an Executive Order (13553) providing for the CISADA sanctions against Iranians
determined to be responsible for or complicit in post-2009 Iran election human rights abuses.
Along with the order, an initial group of eight Iranian officials were penalized, including
Mohammad Ali Jafari, the commander-in-chief of the IRGC, and several other officials who were
in key security or judicial positions at the time of the June 2009 election and aftermath. On
February 23, 2011, the State Department added two Iranian officials to the list of those sanctioned
(Tehran Prosecutor General Abbas Dowlatabai and Basij Commander Mohammad Reza Naqdi).
On June 9, 2011, the Administration added to the designation list three entities – the
Revolutionary Guard, Basij, and Law Enforcement Forces (LEF) - and one person – LEF
commander Ismail Ahmad Moghadam. Under State Department interpretations of the Executive
Order, if an entity is designated, all members of that entity are ineligible for visas to enter the
United States.33 Similar sanctions against many of these same officials—as well as several
others—were imposed by the European Union (a total of 32 Iranians sanctioned by the EU) on
April 14, 2011.
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

33 U.S. Department of Treasury, Office of Public Affairs. Treasury Sanctions Iranian Security Forces for Human Rights
Abuses, June 9, 2011.
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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.34
U.N. Sanctions
The U.S. sanctions discussed in this report are more comprehensive than those imposed, to date,
by the United Nations Security Council or by individual foreign countries or groups of countries,
such as the European Union. However, there is increasing convergence among all these varying
sets of sanctions.
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. 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. After failed negotiations with Iran during 2009, Resolution 1929 was adopted on
June 9, 2010, by a vote of 12-2 (Turkey and Brazil), with one abstention (Lebanon). (Iranian
entities and persons sanctioned by the United Nations are in Table 6.)
The main points of Resolution 1929 are:35
• It adds several firms affiliated with the Revolutionary Guard firms to the list of
sanctioned entities.
• It makes mandatory a ban on travel for Iranian persons named in it and in
previous resolutions—including those Iranians for whom there was a non-
binding travel ban in previous resolutions.
• It gives countries the authorization to inspect any shipments—and to dispose of
its cargo—if the shipments are suspected to carry contraband items. However,
inspections on the high seas are subject to concurrence by the country that owns
that ship. This provision is modeled after a similar provision imposed on North
Korea, which did cause that country to reverse some of its shipments.
• It prohibits countries from allowing Iran to invest in uranium mining and related
nuclear technologies, or nuclear-capable ballistic missile technology.
• It bans sales to Iran of most categories of heavy arms to Iran and requests
restraint in sales of light arms, but does not bar sales of missiles not on the “U.N.
Registry of Conventional Arms.”

34 See CRS Report RL31258, Suits Against Terrorist States by Victims of Terrorism, by Jennifer K. Elsea.
35 Text of the resolution is at http://www.isis-online.org/uploads/isis-reports/documents/
Draft_resolution_on_Iran_annexes.pdf.
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• It requires countries to insist that their companies refrain from doing business
with Iran if there is reason to believe that such business could further Iran’s
WMD programs.
• It requests, but does not mandate, that countries prohibit Iranian banks to open in
their countries, or for their banks to open in Iran, if doing so could contribute to
Iran’s WMD activities.
• It authorizes the establishment of a “panel of experts,” which is chaired by senior
State Department arms control and proliferation adviser Robert Einhorn, to assess
the effect of the resolution and previous Iran resolutions and suggest ways of
more effective implementation.
• The resolution did not make mandatory some measures that reportedly were
considered, including barring any foreign investment in Iranian bond offerings;
banning insurance for transport contracts for shipments involving Iran; banning
international investment in Iran’s energy sector; banning the provision of trade
credits to Iran, or banning all financial dealings with Iranian banks.
Table 4. Summary of Provisions of U.N. Resolutions on Iran Nuclear Program
(1737, 1747, 1803, and 1929)
Require Iran to suspend uranium enrichment, and to refrain from any development of ballistic missiles that are
nuclear capable (1929)
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
Prohibit Iran from investing abroad in uranium mining, related nuclear technologies or nuclear capable ballistic missile
technology
Freeze the assets of over 80 named Iranian persons and entities, including Bank Sepah, and several corporate affiliates
of the Revolutionary Guard.
Require that countries ban the travel of over 40 named Iranians
Mandates that countries not export major combat systems to Iran
Calls for “vigilance” (a non-binding call to cut off business) with respect to all Iranian banks, particularly Bank Melli and
Bank Saderat.
Calls for vigilance (voluntary restraint) with respect to providing international lending to Iran and providing trade
credits and other financing and financial interactions.
Calls 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 banned for carriage to Iran.
Searches in international waters would require concurrence of the country where the ship is registered.
A Sanctions Committee, composed of the 15 members of the Security Council, monitors Implementation of all Iran
sanctions and collects and disseminates information on Iranian violations and other entities involved in banned
activities. A “panel of experts” is empowered by 1929 to make recommendations for improved enforcement.
Source: Text of U.N. Security Council resolutions 1737, 1747, 1803, and 1929. http://www.un.org. More
information on specific provisions of each of these resolutions and the nuclear negotiations with Iran is in CRS
Report. CRS Report RL32048, Iran: U.S. Concerns and Policy Responses, by Kenneth Katzman.
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International Implementation and Compliance
U.S. allies have supported the Obama Administration’s sanctions toward Iran, in part because the
approach is perceived as not purely punitive, and in part because concerns about Iran’s nuclear
advancement have increased. U.S. and European/allied approaches have been gradually
converging since 2002, when the nuclear issue came to the fore, but as of 2010, an unprecedented
degree of global consensus has emerged on how to deal with Iran. There is a degree of consensus
among experts that many countries, not only allies of the United States, are complying with the
provisions of U.N. sanctions, but there are selected exceptions (discussed below). Implementation
appears to be somewhat less complete in Iran’s immediate region, perhaps because its neighbors
do not want confrontation with Iran and are hesitant to disrupt traditional relationships among
traders and businessmen in the region.
European Union and Other Western States
In its July 27, 2010, sanctions measures, the product of consensus among the EU states, the EU
countries imposed sanctions on Iran that exceed those mandated in Security Council resolutions.
Concurrent with the EU announcement, not only Norway (not an EU member) but also Canada
and Australia announced similar, although less sweeping, Iran sanctions. A comparison between
U.S., U.N., and EU sanctions against Iran is contained in the chart below, although noting that
there are differing legal bases and authorities for these sanctions. A U.S. President cannot
mandate a foreign company take any particular action; however, the U.S. government can
penalize or reward foreign firms who take action that supports U.S. objectives. U.N. Security
Council resolutions are considered binding on U.N. Member states. The EU clarified in late
October 2010, that its sanctions against Iran do not ban importation of Iranian oil and gas, nor do
they ban exports of gasoline to Iran.
Japan and South Korea
In early September 2010, Japan and then South Korea announced Iran sanctions similar to those
of the EU. Both countries adopted measures limiting trade financing for Iran, limiting new
banking relations with Iran, sanctioning numerous named Iranian entities, and restricting new
projects in Iran’s energy sector. The sanctions adopted by both were far more extensive than was
expected by U.S. officials.
India/Asian Clearing Union
India has generally been considered friendly toward Iran and unlikely to impose any national
sanctions on that country. Therefore, many experts were surprised when India’s central bank, in
late December 2010, announced that it would no longer use a regional body, the Asian Clearing
Union, to handle transactions with Iran. The Asian Clearing Union, based in Tehran, was set up in
the 1970s by the United Nations to ease commerce among Asian nations. There have been
allegations in recent years that Iran might be using the Clearing Union to handle transactions so
as to avoid limitations imposed by European and other banks.
The Indian move complicated India’s purchases of about 350,000-400,000 barrels per day of
Iranian oil, and Indian officials subsequently undertook negotiations with Iran to find an alternate
mechanism to clear Indian payments for that oil and other Iranian goods. Still, the Indian move—
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and the reported difficulty in agreeing to a replacement payments mechanism—appeared to signal
that India was taking steps to join U.S./European-led efforts to shut Iran out of the international
financial system. The Indian move followed President Obama’s visit there in November 2010.
Several banks considered as replacement mechanisms were either under U.N. sanctions or fear
fallout (restrictions in the U.S. banking system) from transacting banking business for Iran. In
mid-February 2010, India and Iran agreed to use Europaisch-Iranische Handelsbank (EIH) to
clear the payments. EIH has accounts with National Iranian Oil Company as well as with the
Central Bank of Germany, rendering the bank able to process the Indian payments to Iran. Some
Members of Congress have previously characterized that bank as one of Iran’s few remaining
access points to the European financial system and had asked the German government to order it
closed.36 On May 23, 2011, the EU named EIH and about 100 other entities as Iran proliferation-
related activities, meaning the bank might be forced to close and India and Iran will again have to
seek an alternative payments mechanism.
China, Russia, and Others
The position of Russia, China, and several other countries on the issue of Iran sanctions has been
of concern to several Members of Congress. The formal position of both Russia and China is that
they will impose only those sanctions required by applicable U.N. Security Council resolutions,
but not impose sanctions beyond those specifically mandated. As noted below, some Members
and outside experts express concern that Chinese firms, in particular, are moving to fill the void
left by vacating European firms (“backfill”), but Administration officials say they have not seen
evidence of such a trend.
An even more significant concern is that these and other countries are refusing or failing to
prevent Iran from acquiring weapons and WMD technology. Secretary of State Clinton singled
out China on January 19, 2011, as not enforcing all aspects of international sanctions that bar
sales of most nuclear-related equipment to Iran; the comment came of the eve of the state visit to
the United States by President Hu Jintao. On March 9, 2011, State Department Special Adviser
for Non-Proliferation and Arms Control, Robert Einhorn, said Iran may be working with Chinese
firms to obtain sensitive technology useful for nuclear weapons development. In some cases, Iran
has been able, according to some reports, to obtain sophisticated technology even from U.S.
firms.37
A related issue is Iran’s efforts to use the high seas or the territory of other countries to supply
weapons to groups it supports (such shipments are barred by U.N. resolutions; see above). In
March 2011, Israel intercepted a freighter, the Victoria, that it said was carrying Iranian weapons
to Palestinian militant groups. Also in March 2011, Turkey, generally considered friendly toward
Iran, complied with U.N. requirements by twice forcing the landing in Turkey of Iranian cargo
aircraft. In both cases, the aircraft were searched, and in one instance, weapons were removed,
allegedly bound for Syria, before the aircraft were allowed to proceed.

36 Letter signed by eleven U.S. Senators to German Foreign Minister Guido Westerwelle. February 1, 2011.
37 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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Contrast With Previous Periods
The emerging consensus on Iran sanctions differs from early periods when there was far more
disagreement. Reflecting the traditional European preference for providing incentives rather than
enacting economic punishments, during 2002-2005, there were active negotiations between the
European Union and Iran on a “Trade and Cooperation Agreement” (TCA). Such an agreement
would have lowered the tariffs or increased quotas for Iranian exports to the EU countries.38
However, negotiations were discontinued after the election of Ahmadinejad in June 2005, at
which time Iran’s position on its nuclear program hardened. Similarly, there is insufficient
international support to grant Iran membership in the World Trade Organization (WTO) until
there is progress on the nuclear issue. Iran first attempted to apply to join the WTO in July 1996.
On 22 occasions after that, representatives of the Clinton and then the George W. Bush
Administration blocked Iran from applying (applications must be by consensus of the 148
members). As discussed above, as part of an effort to assist the EU-3 nuclear talks with Iran, at a
WTO meeting in May 2005, no opposition to Iran’s application was registered, and Iran formally
began accession talks.
Earlier, during the 1990s, EU countries maintained a policy of “critical dialogue” with Iran, and
the EU and Japan refused to join the 1995 U.S. trade and investment ban on Iran. The European
dialogue with Iran was suspended in April 1997 in response to the German terrorism trial
(“Mykonos trial”) that found high-level Iranian involvement in killing Iranian dissidents in
Germany, but resumed in May 1998 during Khatemi’s presidency. In the 1990s, European and
Japanese creditors—over U.S. objections—rescheduled about $16 billion in Iranian debt. These
countries (governments and private creditors) rescheduled the debt bilaterally, in spite of Paris
Club rules that call for multilateral rescheduling. In July 2002, Iran tapped international capital
markets for the first time since the Islamic revolution, selling $500 million in bonds to European
banks. (A provision of H.R. 6296 would make sanctionable under ISA the purchase of Iranian
sovereign debt).
World Bank Loans
The July 27, 2010, EU measures appear to narrow substantially the prior differences between the
EU and the United States over international lending to Iran. As noted above, the United States
representative to international financial institutions is required to vote against international
lending, but that vote, although weighted, is not sufficient to block international lending. 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 irrigation projects, but the loans were approved. To block that lending,
the FY1994-FY1996 foreign aid 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 by the amount of those loans. The
legislation contributed to a temporary halt in new bank lending to Iran. (In the 111th Congress, a
provision of H.R. 6296—Title VII—cut off U.S. contributions to the World Bank, International
Finance Corp., and the Multilateral Investment Guarantee Corp. if the World Bank approves a
new Country Assistance Strategy for Iran or makes a loan to Iran.)

38 During the active period of talks, which began in December 2002, there were working groups focused not only on the
TCA terms and proliferation issues but also on Iran’s human rights record, Iran’s efforts to derail the Middle East peace
process, Iranian-sponsored terrorism, counter-narcotics, refugees, migration issues, and the Iranian opposition PMOI.
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During 1999-2005, Iran’s moderating image had led the World Bank to consider new loans over
U.S. opposition. 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
$725 million in loans were approved for environmental management, housing reform, water and
sanitation projects, and land management projects, in addition to $400 million in loans for
earthquake relief.

Table 5. Points of Comparison Between U.S., U.N., and EU Sanctions Against Iran
Implementation by EU (July 27,
2010) and Some Allied
U.S. Sanctions
U.N. Sanctions
Countries
General Observation: Most
Increasingly sweeping, but still
EU abides by all U.N. sanctions on
sweeping sanctions on Iran of
intended to primarily target Iran’s
Iran, but new package of Iran
virtually any country in the world
nuclear and other WMD programs.
sanctions announced July 27, 2010,
No mandatory sanctions on Iran’s
more closely aligns EU sanctions
energy sector.
with those of the U.S. than ever
before.
Japan and South Korean sanctions
(September 2010) similar to EU.
Ban on U.S. Trade with and
U.N. sanctions do not ban civilian
No general EU ban on trade in
Investment in Iran:
trade with Iran or general civilian
civilian goods with Iran, although the
sector investment in Iran. Nor do
July 27, 2010, sanctions ban sales of
Executive order 12959 bans (with
U.N. sanctions mandate restrictions
energy related equipment and
limited exceptions) U.S. firms from
on provision of trade financing or
services. On May 23, 2011, the EU
exporting to Iran, importing from
financing guarantees by national
named about 100 entities as Iran
Iran, or investing in Iran.
export credit guarantee agencies.
proliferation-related entities which
There is an exemption for sales to
EU entities would be unable to do
Iran of food and medical products,
business with.
but no trade financing or financing
EU, Japan, and South Korea
guarantees are permitted.
measures ban “medium and long
term” trade financing and financing
guarantees. Short term financing is
permitted, but there is a cal for EU
states to “exercise restraint” on
that.
Sanctions on Foreign Firms that
No U.N. equivalent exists. However,
July 27, 2010, EU sanctions prohibit
Do Business With Iran’s Energy
preambular language in Resolution
EU companies from financing energy
Sector:
1929 “not[es] the potential
sector projects in Iran (a de-facto
connection between Iran’s revenues
ban on energy sector investment)
The Iran Sanctions Act, P.L. 104-172
derived from its energy sector and
and ban sales to Iran of equipment
(as amended most recently by the
the funding of Iran’s proliferation-
or services for its energy sector,
Comprehensive Iran Sanctions,
sensitive nuclear activities.” This
including projects outside Iran. No
Accountability, and Divestment Act
wording is interpreted by most
ban on buying oil or gas from Iran
of 2010, P.L. 111-195) mandates
observers as providing U.N. support
or selling gasoline to Iran.
specified sanctions on foreign firms
for countries who want to ban their
that invest threshold amounts in
companies from investing in Iran’s
Japan and South Korean measures
Iran’s Energy Sector or that sell
energy sector.
ban new energy projects in Iran and
certain threshold amounts of refined
call for restraint on ongoing
petroleum or refinery related
projects.
equipment or services to Iran.
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Implementation by EU (July 27,
2010) and Some Allied
U.S. Sanctions
U.N. Sanctions
Countries
Ban on Foreign Assistance:
No U.N. equivalent
EU measures of July 27, 2010, ban
grants, aid, and concessional loans
U.S. foreign assistance to Iran—
to Iran. Also prohibit financing of
other than purely humanitarian aid—
enterprises involved in Iran’s energy
is banned under Section 620A of the
sector.
Foreign Assistance Act . That section
bans U.S. assistance to countries on
Japan and South Korea measures
the U.S. list of “state sponsors of
did not specifically ban aid or
terrorism.” Iran has been on this
lending to Iran.
“terrorism list” since January 1984.
Iran is also routinely denied direct
U.S. foreign aid under the annual
foreign operations appropriations
acts (most recently in Section 7007
of division H of P.L. 111-8).
Ban on Arms Exports to Iran:
Resolution 1929 (operative paragraph EU sanctions include a
8) bans al U.N. member states from
comprehensive ban on sale to Iran
Because Iran is on the “terrorism
selling or supplying to Iran major
of all types of military equipment,
list,” it is ineligible for U.S. arms
weapons systems, including tanks,
not just major combat systems.
exports pursuant to Section 40 of
armored vehicles, combat aircraft,
the Arms Export Control Act
warships, and most missile systems,
No similar Japan and South Korean
(AECA, P.L. 95-92). The International or related spare parts or advisory
measures announced, but neither
Trafficking in Arms Regulations
services for such weapons systems.
has exported arms to Iran.
(ITAR, 22 CFR Part 126.1) also cite
the President’s authority to control
arms exports, and to comply with
U.N. Security Council Resolutions as
a justification to ban arms exports
and imports.
Restriction on Exports to Iran of The U.N. Resolutions on Iran,
EU bans the sales of dual use items
“Dual Use Items”:
cumulatively, ban the export of
to Iran, in line with U.N.
almost all dual-use items to Iran.
resolutions.
Primarily under Section 6(j) of the
Export Administration Act (P.L. 96-
Japan announced ful adherence to
72) and Section 38 of the Arms
strict export control regimes when
Export Control Act, there is a denial
evaluating sales to Iran.
of license applications to sell Iran
goods that could have military
applications.
Sanctions Against International
Resolution 1747 (oper. paragraph 7)
The July 27, 2010, measures
Lending to Iran:
requests, but does not mandate, that
prohibit EU members from
countries and international financial
providing grants, aid, and
Under Section 1621 of the
institutions refrain from making
concessional loans to Iran, including
International Financial Institutions
grants or loans to Iran, except for
through international financial
Act (P.L. 95-118), U.S.
development and humanitarian
institutions.
representatives to international
purposes.
financial institutions, such as the
No specific similar Japan or South
World Bank, are required to vote
Korea measures announced.
against loans to Iran by those
institutions.
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Implementation by EU (July 27,
2010) and Some Allied
U.S. Sanctions
U.N. Sanctions
Countries
Sanctions Against Foreign Firms Resolution 1737 (oper. paragraph 12) The EU measures imposed July 27,
that Sell Weapons of Mass
imposes a worldwide freeze on the
2010, commit the EU to freezing
Destruction-Related Technology assets and property of Iranian entities the assets of entities named in the
to Iran:
named in an Annex to the
U.N. resolutions, as well as
Resolution. Each subsequent
numerous other named Iranian
Several laws and regulations,
Resolution has expanded the list of
entities.
including the Iran-Syria North Korea
Iranian entities subject to these
Nonproliferation Act (P.L. 106-178),
sanctions.
Japan and South Korea froze assets
the Iran-Iraq Arms Nonproliferation
of U.N.-sanctioned entities.
Act (P.L. 102-484) and Executive
Order 13382 provide for sanctions

against entities, Iranian or otherwise,
that are determined to be involved in
or supplying Iran’s WMD programs
(asset freezing, ban on transaction
with the entity).
Ban on Transactions With
No direct equivalent
No direct equivalent, but EU
Terrorism Supporting Entities:
measures taken July 27, 2010,
The U.N. Resolutions against Iran are include some IRGC Qods Force and
Executive Order 13224 bans
intended primarily to slow or halt
related persons and entities as
transactions with entities determined Iran’s nuclear and other WMD
subject to a freeze on EU-based
by the Administration to be
programs. However, Resolution 1747 assets.
supporting international terrorism.
(oper. paragraph 5) bans Iran from
Numerous entities, including some of exporting any arms—a provision
Iranian origin, have been so
widely interpreted as trying to
designated.
reduce Iran’s material support to
groups such as Lebanese Hizbollah,
Hamas, Shiite militias in Iraq, and
insurgents in Afghanistan.
Travel Ban on Named Iranians:
Resolution 1803 imposed a binding
The EU sanctions announced July
ban on international travel by several
27, 2010, contains an Annex of
The Comprehensive Iran Sanctions,
Iranians named in an Annex to the
named Iranians subject to a ban on
Accountability, and Divestment Act
Resolution. Resolution 1929
travel to the EU countries. An
of 2010 (P.L. 111-195) provides for a
extended that ban to additional
additional 32 Iranians involved in
prohibition on travel to the U.S. ,
Iranians, and forty Iranians are now
human rights abuses were subjected
blocking of U.S.-based property, and
subject to the ban. However, the
to EU sanctions on April 14, 2011.
ban on transactions with Iranians
Iranians subject to the travel ban are
determined to be involved in serious
so subjected because of their
Japan and South Korea announced
human rights abuses against Iranians
involvement in Iran’s WMD
bans on named Iranians.
since the June 12, 2009, presidential
programs, not because of
election there.
involvement in human rights abuses.
Restrictions on Iranian Shipping: Resolution 1803 and 1929 authorize
The EU measures announced July
countries to inspect cargoes carried
27, 2010, bans Iran Air Cargo from
Under Executive Order 13382, the
by Iran Air and Islamic Republic of
access to EU airports. The
U.S. Treasury Department has
Iran Shipping Lines (IRISL)—or any
measures also freeze the EU-based
named Islamic Republic of Iran
ships in national or international
assets of IRISL and its affiliates.
Shipping Lines and several affiliated
waters—if there is an indication that
Insurance and re-insurance for
entities as entities whose U.S.-based
the shipments include goods whose
Iranian firms is banned.
property is to be frozen.
export to Iran is banned.
Japan and South Korean measures
take similar actions against IRISL and
Iran Air.
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Implementation by EU (July 27,
2010) and Some Allied
U.S. Sanctions
U.N. Sanctions
Countries
Banking Sanctions:
No direct equivalent
The EU announcement on July 27,
2010, prohibit the opening in EU
A number or provisions and policies
However, two Iranian banks are
countries of any new branches or
have been employed to persuade
named as sanctioned entities under
offices of Iranian banks. The
foreign banks to end their
the U.N. Security Council
measures also prohibit EU banks
relationships with Iranian banks.
resolutions.
from offices or accounts in Iran. In
Several Iranian banks have been
addition, the transfer of funds
named as proliferation or terrorism
exceeding 40,000 Euros (about
supporting entities under Executive
$50,000) between and Iranian bank
Orders 13382 and 13224,
and an EU bank require prior
respectively.
authorization by EU bank
P.L. 111-195 contains a provision
regulators.
that prohibits banking relationships
Japan and South Korea measures
with U.S. banks for any foreign bank
similar to the above, with South
that conducts transactions with Iran’s
Korea adhering to the same 40,000
Revolutionary Guard or with Iranian
Euro authorization requirement.
entities sanctioned under the various
Japan and S. Korea froze the assets
U.N. resolutions.
of 15 Iranian banks; South Korea
targeted Bank Mellat for freeze.
No direct equivalent, although, as
Resolution 1929 (oper. paragraph 7)
EU measures on July 27, 2010,
discussed above, U.S. proliferations
prohibits Iran from acquiring an
require adherence to this provision
laws provide for sanctions against
interest in any country involving
of Resolution 1929.
foreign entities that help Iran with its
uranium mining, production, or use
nuclear and ballistic missile programs. of nuclear materials, or technology
related to nuclear-capable ballistic
missiles.
Operative Paragraph 9 of Resolution
1929 prohibits Iran from undertaking
“any activity” related to ballistic
missiles capable of delivering a
nuclear weapon.

Effects of Sanctions on Iran
The effectiveness of U.S. and international sanctions on Iran is often difficult to measure and may
vary depending upon which goals are being examined. U.S. officials acknowledge that the
sanctions have not achieved the fundamental goal of altering Iran’s commitment to its nuclear
program, but they and others believe that the sanctions may be possibly be achieving the related
goal of slowing the advancement of Iran’s nuclear program. Most outside experts agree that the
sanctions are compounding the mismanagement and other structural inadequacies of Iran’s
economy and that the sanctions are only beginning to apply pressure on Iran’s economy as
worldwide enforcement and understanding of Iran’s evasions ramps up. At the same time, there is
a view that high oil prices are helping Iran weather the economic effects of the sanctions.
At various conferences, some Administration officials have urged to allow time for the existing
sanctions to work but have not ruled out new international sanctions. Still, as of late May 2011,
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there do not appear to be active discussions among the P5+1 contact group on Iran’s nuclear
program to draw up a new U.N. Security Council sanctions resolution. Most experts believe that
the most effective sanction would be a mandated, worldwide embargo on the purchase of Iranian
crude oil, although there are no indications that such a step is to be proposed at the United
Nations in the near term or that doing so would achieve consensus. With the United States and
Europe seeking to boost economic growth, a sanction that would result in a further increase in oil
prices would appear unlikely to attract broad support. Specific sanctions effects are discussed
below.
Effect on Nuclear Negotiations
There is a consensus that U.S. and U.N. sanctions have not, to date, accomplished their core
strategic objective of causing a demonstrable shift in Iran’s commitment to its nuclear program.
Most experts assess that the optimal means for sanctions to affect the nuclear program is by
contributing to a decision by Iran to a compromise that would limit Iran’s nuclear development.
In late November 2010, Iran accepted new nuclear talks in Geneva. However, during two days of
talks (December 6 and 7), Iran did not agree to curbs on its enrichment of uranium, the core U.S.
demand. There was an agreement to have new talks in Turkey, which took place during January
21-22, 2011. However, the talks, by all accounts, made little progress as Iran refused to discuss
details of various proposals for nuclear confidence building measures. The talks were said to have
nearly broken down at the end of the first day and an exchange of letters between Iran and the EU
foreign policy representative (acting on behalf of the P5+1) during February–May 2011 did not
indicate sufficient Iranian flexibility to prompt the P5+1 to seek to schedule new talks with Iran.
Counter-Proliferation Effects
A related issue is whether the cumulative sanctions have, in and of themselves, added bottlenecks
to Iran’s nuclear efforts by making it difficult for Iran to import needed materials or skills. In a
statement in the UAE on January 10, 2011, Secretary of State Clinton said that “The sanctions are
working…. Their program, from our best estimate, has been slowed down.”39 Others, however,
say that there is not clear evidence that sanctions are slowing Iran’s program in that International
Atomic Energy Agency (IAEA) reports—including the latest one issued May 24, 2011—say that
Iran’s stockpile of low-enriched uranium continues to expand.40 The lack of clear evidence that
Iran is trying to acquire a nuclear weapons capability could be caused by Iranian decisions rather
than the effect of sanctions.
General Political Effects
It has been hoped that international sanctions might widen splits in Iran’s leadership and cause its
leaders to reconsider major foreign policy decisions, particularly the nuclear program. There are
growing indications of splits in the Iranian leadership - particularly between Ahmadinejad and the
Supreme Leader – but this split does not appear to be driven primarily by differences over how to
react to international sanctions. In September 2010, a senior leader, Ali Akbar Hashemi-

39 Landler, Mark. “Clinton Says Sanctions Have Stalled Iran’s Effort to Make Nuclear Weapons.” New York Times,
January 11, 2011.
40 The text of the report is at http://www.isis-online.org/uploads/isis-reports/documents/Iran_24May2011.pdf.
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Rafsanjani, criticized Ahmadinejad for dismissing the effect of the burgeoning sanctions on Iran’s
economy. Possibly in retaliation, in March 2011 Ahmadinejad succeeded in ousting Rafsanjani
from a key position—chairman of the powerful “Assembly of Experts.”
At the broader level, in February 2011, the opposition Green movement began returning to the
streets with significant protests. However, the protests have not been sustained since and there is
no evidence that international sanctions are affecting the strength of the domestic opposition
either positively or negatively. The opposition is driven by long-standing political grievances and
has not, to date, been joined by labor groups or other protesters articulating purely economic
demands.
While the Green movement has not necessarily broadened, anecdotal reports suggest that many
Iranians, particularly in the middle class are blaming the regime for economic difficulties. There
has been unrest among small and large merchants who are having trouble obtaining trade
financing, insurance, and shipping availability, which is driving up their costs by an estimated
40%, even if the merchants can complete desired transactions at all.41 A substantial portion of the
Iranian economy depends on import-export activity, so the damage to that sector from
international sanctions has been considerable.
Economic Effects
An IMF statement issued June 13, 2011 casts some doubt that international sanctions are
seriously harming Iran’s economy. The statement, based on a May 28-June 9 study visit, indicated
that Iran’s GDP is growing at a rate of about 3.5%, and that the government has brought inflation
down from 25% in 2008 to about 12% in 2010/2011. The IMF also credits positive economic
effects to the government’s privatization program. Many believe that the economic effects of
international sanctions can be tolerated by the regime as long as world oil prices remain high, at
nearly $100 per barrel in June 2011.
U.S. officials believe that Iran’s economy will inevitably begin to suffer as U.S. and partner
strategy shuts Iran out of the global financial system, raises the costs for Iran of financing its
transactions, and causes international firms to exit Iran:
• During 2006 and 2010, Treasury and State Departments officials say they
persuaded at least 80 banks not to process transactions for Iranian banks. Among
those that have pulled out of Iran are UBS (Switzerland), HSBC (Britain),
Germany’s Commerzbank A.G., and Deutsche Bank AG. U.S. financial
diplomacy has reportedly convinced Kuwaiti banks to stop transactions with
Iranian accounts,42 and some banks in Asia (primarily South Korea and Japan)
and the rest of the Middle East have done the same. Then-Under Secretary Levey
said on September 20, 2010, that “today, Iran is effectively unable to access
financial services from reputable banks and is increasingly unable to conduct
major transactions in dollars or Euros.”43

41 “Iran’s Gateway in Dubai Highlights Sanctions Bite.” Associated Press, February 1, 2011.
42 Mufson, Steven and Robin Wright. “Iran Adapts to Economic Pressure.” Washington Post, October 29, 2007.
43 Speech by Stuart Levey before the Center for Strategic and International Studies. September 20, 2010.
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• In late September 2010, the value of Iran’s currency, the rial, fell by about 15%
when the UAE, a major financial hub for Iran, began restricting transactions with
Iranian banks sanctioned by U.N. resolutions and by the United States.
• Treasury Department’s designations of affiliates and ships belong to Islamic
Republic of Iran Shipping Lines (IRISL) reportedly are harming Iran’s ability to
ship goods and raised the prices of goods to Iranian import-export dealers. Some
ships have been impounded by various countries for non-payment of debts due
on them.
Foreign Companies Exiting the Iran Market
Many experts believe that, over time, the efficiency and output of Iran’s economy will decline as
foreign expertise departs and Iran invites in or makes purchases from less capable foreign
companies. Neither the U.S. ban on trade and investment with Iran, nor U.N. sanctions, nor
European Union sanctions on Iran, ban trade with Iran in all civilian goods. Still, because the
international community has sought to isolate Iran economically, companies all over the world
have come to a decision to end their business with Iran, even when such business would not
appear to violate any U.N. or national sanction.
• ABB of Switzerland said in January 2010 it would cease doing business with
Iran.
• Siemens of Germany was active in the Iran telecommunications infrastructure
market, but announced in February 2010 that it would cease pursuing business in
Iran. Finemeccanica, a defense and transportation conglomerate of Italy, followed
suit, as did Thyssen-Krupp, a German steelmaker.
• Germany’s Daimler (Mercedes-Benz maker) said in April 2010 it would freeze
planned exports to Iran of cars and trucks.
• In August-September 2010, Japan and South Korea announced that their
automakers Toyota, Hyundai, and Kia Motors would cease selling automobiles to
Iran.
Foreign Firms Remaining in the Iran Market
Some firms continue to run the financial risk of doing business with Iran. Some of the well-
known firms that continue to do so include Alcatel-Lucent of France; Bank of Tokyo-Mitsubishi
UFJ; BNP Paribas of France; Bosch of Germany; Canon of Japan; Fiat SPA of Italy; Ericsson of
Sweden; ING Group of the Netherlands; Mercedes of Germany; Renault of France; Samsung of
South Korea; Sony of Japan; Volkswagen of Germany; Volvo of Sweden; and numerous others.
Some of the foreign firms that trade with Iran, such as Mitsui and Co. of Japan, Alstom of France,
and Schneider Electric of France, are discussed in the March 7, 2010, New York Times article on
foreign firms that do business with Iran and also receive U.S. contracts or financing. The Times
article does not claim that these firms have violated any U.S. sanctions laws.
Other questions have arisen over how U.S. sanctions might apply to business with foreign firms
that Iran might acquire a full or partial interest in. Such firms include Daewoo Electronics of
South Korea, where an Iranian firm—Entekhab Industrial Corp.—is a leading bidder to take over
that firm. Another example is Adabank of Turkey, which reportedly might be sold to Iran.
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Subsidy Phase-Out Issue
A larger issue, which may have been affected by sanctions, but perhaps positively for Iran, is a
long-delayed plan to phase out state subsidies on staple goods such staples as gasoline and some
foods over the next five years. International sanctions might have helped Ahmadinejad convince
the Majles (parliament) that passing the subsidy reduction plan was urgent if Iran was to parry the
effects of burgeoning international sanctions. After several delays, the program started on
December 19, 2010, with a reduction in subsidies of gasoline and bread. The price of traditional
bread immediately escalated to 40 cents, from 15 cents, when the program began. Gasoline prices
now run on a tiered system in which a small increment is available at the subsidized price of
about 1.60 per gallon, but amounts above that threshold are available only at a price of about
$2.60 per gallon, close to the world price. The lower and lower middle class is being
compensated with direct cash payments of about $40 per month.44
The IMF statement of June 13, 2011, discussed above, said that the program removed about $60
billion in subsidies. The statement also credits the regime with successfully containing initial
impact of the rise in domestic energy prices on inflation.
Nor has the subsidy phase out produced major additional unrest. When the plan went into effect
in December 2010, some Iranian truckers simply stopped working on the grounds that their work
was no longer profitable (because the government limited the amount of extra fees that can be
charged to make up for the increase in costs). However, the subsidy phase out did not produce
new Green movement demonstrations or other indicators of opposition.
Effect on the Energy Sector
As noted throughout, the U.S. objective has been to target sanctions against Iran’s energy sector,
considered the engine of Iran’s economy and source of most of its revenue. Depriving the regime
of revenue, it is believed, will reduce its ability to enlist and maintain the loyalty of security
personnel or to buy off key interest groups. There are clear indications that the sanctions—
coupled with the overall sense that Iran is isolated from the international community—are
causing substantial injury to this sector. State Department Special Advisor Einhorn testified on
July 29, 2010, that about $50 billion in investment in Iran’s energy sector had been deterred by
sanctions and other forms of pressure. Some U.S. officials in 2011 put the figure closer to $60
billion in lost investment. As noted above, several major European firms have either announced
pullouts from some of their Iran projects, declined to make further investments, or resold their
investments to other companies. Observers at key energy fields in Iran say there is little evidence
of foreign investment activity and little new development activity sighted, including at the large
South Pars gas field that Iran has focused on for at least 10 years. It is highly unlikely that Iran
will attract the $145 billion in new investment by 2018 that Iran’s deputy Oil Minister said in
November 2008 that Iran needs.
Possibly or partly as a result, Iran’s oil production has fallen slightly to about 3.8 million barrels
per day (mbd) from about 4.1 million barrels per day (mbd) in the mid-2000s, and is projected to
fall to about 3.3 mbd by 2015.45 Others maintain that Iran’s gas sector can more than compensate

44 Erdbink, Thomas. “Leaving Iran’s Middle Class Behind.” Washington Post, November 7, 2010.
45 http://online.wsj.com/article/SB10001424052748704569204575328851816763476.html.
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for declining oil exports, although it needs gas to reinject into its oil fields and remains a
relatively minor gas exporter. It exports about 3.6 trillion cubic feet of gas, primarily to Turkey.
Some Members of Congress believe that ISA would have been even more effective if successive
administrations had imposed sanctions available in U.S. law, and have expressed frustration that
the executive branch has imposed few, if any, actual sanctions under ISA.
The EU sanctions apparently have also derailed a BP-NIOC joint venture in the Rhum gas field,
200 miles off the coast of Scotland. BP announced in November 2010 that it would stop
production there to ensure compliance with the EU sanctions. In addition, partners in the Trans-
Adriatic Pipeline (TAP) said in September 2010 that the pipeline would not be used to transport
Iranian gas to Europe.
Some believe that a key to further harming Iran’s energy sector is to persuade remaining oil
services firms to pull out of Iran. In press articles and in the December 1, 2010, House Foreign
Affairs Committee hearing discussed above, the large oil services firm Schlumberger, which in
incorporated in the Netherlands Antilles, has said it will wind down its business with Iran.
However, press reports citing company documents say all contracts with Iran might not be
terminated until at least 2013.46
Concerns About “Backfill”
There has been a concern that some of the investment void might be “backfilled,” at least partly,
by Asian firms such as those from China, Malaysia, Vietnam, and countries in Eastern Europe.
Russian firms are said to be in talks with Iran on new energy projects. However, many such deals
are said to be in preliminary stages, and clear examples of “backfilling” are few, to date. Most of
the potential backfilling companies are perceived as not being as technically capable as those that
have withdrawn from Iran. In July 2010, after the enactment of Resolution 1929 and CISADA,
the Revolutionary Guard’s main construction affiliate, Khatem ol-Anbiya, announced it had
withdrawn from developing Phases 15 and 16 of South Pars—a project worth $2 billion.47
Khatem ol-Anbiya took over that project in 2006 when Norway’s Kvaerner pulled out of it. It is
likely that the IRGC perceived its involvement as likely to scare away foreign participation in the
work because U.S. and U.N. sanctions are targeting the IRGC and its corporate affiliates.
Effect on Gasoline Availability and Importation
In March 2010, well before the passage of CSIDA on June 24, 2010, several gas suppliers to Iran,
anticipating this legislation, announced that they had stopped or would stop supplying gasoline to
Iran.48 Others have ceased since the enactment of CISADA, and some observers say that gasoline
deliveries to Iran have fallen from about 3.5 million barrels per day before CISADA to about
900,000 barrels per day.49 That is a decline of nearly 75%, a reduction that most experts continue
to view as valid. As noted in a New York Times report of March 7, 2010,50 and a Government

46 Stockman, Farah. “Oil Firm Says It Will Withdraw From Iran.” Boston Globe, November 12, 2010.
47 “Iran Revolutionary Guards Pull Out of Gas Deal Over Sanctions.” Platts, July 19, 2010.
48 Information in this section derived from, Blas, Javier. “Traders Cut Iran Petrol Line.” Financial Times, March 8,
2010.
49 Information provided at Foundation for Defense of Democracies conference on Iran. December 9, 2010.
50 Becker, Jo and Ron Nixon. “U.S. Enriches Companies Defying Its Policy on Iran.” New York Times, March 7, 2010.
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Accountability Office study released September 3, 2010,51 some firms that have supplied Iran
have received U.S. credit guarantees or contracts.
The main suppliers to Iran over the past few years, and the GAO-reported status of their sales to
Iran are listed below (with the caveat that some reports say that partners or affiliates of these
firms may still sell to Iran in cases where the corporate headquarters have announced a halt):
• Vitol of Switzerland (notified GAO it stopped selling to Iran in early 2010);
• Trafigura of Switzerland (notified GAO it stopped selling to Iran in November
2009);
• Glencore of Switzerland (notified GAO it stopped selling in September 2009);
• Total of France (notified GAO it stopped sales to Iran in May 2010);
• Reliance Industries of India (notified GAO it stopped sales to Iran in May 2009).
Reliance has also told press outlets on April 1, 2010 that it would not import
Iranian crude oil in 2010;
• Petronas of Malaysia (said on April 15, 2010, it had stopped sales to Iran);52
• Lukoil of Russia (reportedly to have ended sales to Iran in in April 2010,53
although some reports continue that Lukoil affiliates are supplying Iran);
• Royal Dutch Shell of the Netherlands (notified GAO it stopped sales in October
2009);
• Kuwait’s Independent Petroleum Group told U.S. officials it is no longer selling
gasoline to Iran, as of September 2010; 54
• Tupras of Turkey (according to the State Department on May 24, 2011);
• British Petroleum of United Kingdom, Shell, Q8, Total, and OMV are no longer
selling aviation fuel to Iran Air, according to U.S. State Department officials on
May 24, 2011;
• One UAE firm, Dragon Oil, has not renewed a deal with Iran, which expired in
July 2010, to swap oil with Iran via Turkmenistan. Another UAE firm, Golden
Crown Petroleum FZE, told the author in April 2011 that, as of June 29, 2010, it
no longer leases vessels for the purpose of shipping petroleum products from or
through Iran;
• Munich Re, Allianz, Hannover Re (Germany) were providing insurance and re-
insurance for gasoline shipments to Iran. However, they reportedly have exited
the market for insuring gasoline shipments for Iran;55
• Lloyd’s (Britain). The major insurer had been the main company insuring Iranian
gas (and other) shipping, but reportedly has ended that business as of July 2010

51 GAO-10-967R. Exporters of Refined Petroleum Products to Iran. September 3, 2010.
52 http://www.ft.com/cms/s/0/009370f0-486e-11df-9a5d-00144feab49a.html.
53 http://www.defenddemocracy.org/index.php?option=com_content&task=view&id=11788115&Itemid=105.
54 http://www.defenddemocracy.org/index.php?option=com_content&task=view&id=11788115&Itemid=105.
55 http://www.defenddemocracy.org/index.php?option=com_content&task=view&id=11788115&Itemid=105.
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According to the State Department, key shipping associations have created
clauses in their contracts that enable ship owners to refuse to deliver gasoline to
Iran;
• The State Department reported on September 30, 2010, that Hong Kong company
NYK Line Ltd. had ended shipping business with Iran (on any goods, not just
gasoline);
• According to the State Department on May 24, 2011, Linde of Germany has said
it had stopped supplying gas liquefaction technology to Iran, contributing to
Iran’s decision to suspend its LNG program.
Firms Believed to Still Be Supplying Gasoline or Related Equipment
• The firms sanctioned by the Administration on May 24, 2011 (discussed above):
PCCI (Jersey/Iran); Royal Oyster Group (UAE); Speedy Ship (UAE/Iran);
Tanker Pacific (Singapore); Ofer Brothers Group (Israel); Associated
Shipbroking (Monaco); and Petroleos de Venezuela (Venezuela);
• Zhuhai Zhenrong, Unipec, and China Oil of China are said by GAO to still be
selling to Iran and have not denied continuing sales to the GAO;
• Emirates National Oil Company of UAE was reported by GAO to still be selling
to Iran;
• Hin Leong Trading of Singapore was reported by GAO to still be selling gasoline
to Iran;
• Some refiners in Bahrain reportedly may still be selling gasoline to Iran.
Despite the large reduction in gasoline sales to Iran, as of late 2010, Iranian officials have said
they have largely coped with the reduction in gasoline imports. The phaseout of gasoline
subsidies discussed above has already reportedly begun to reduce demand for gasoline. Still, in
December 2010 Iran slowed gasoline shipments to Afghanistan under a long-standing
arrangement, possible to have gasoline available inside Iran to cope with any unrest that might
result from real or perceived gas shortages.
Even before the subsidy reduction, there had not been gasoline shortages or gasoline rationing,
although some Iranian oppositionists have reported otherwise. Iran has coped by converting at
least two petrochemical plants to gasoline production, through a generally inferior process that
initially produces benzene. The gasoline produced reportedly has led to a large increase in air
pollution in Tehran, which was expected. Iran also says it has accelerated renovations and other
improvements to existing gasoline refineries, allocating $2.2 billion for that purpose.
Building new refining capacity appears to be Iran’s long term effort to reduce its vulnerability to
gasoline supply reductions. Iran’s deputy oil minister said in July 2010 Iran would try to invest
$46 billion to upgrade its nine refineries and build seven new ones, a far larger amount than Iran
had previously allocated to oil refining capacity.
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Recent or Pending Legislation to Impose
Additional Sanctions
Some in the 112th Congress believe that the cumulative effect of U.S. and international sanctions
remain insufficient to accomplish key U.S. policy goals toward Iran, and are advocating further
steps. However, in June 2011, outgoing Deputy Secretary of State Jim Steinberg told journalists
(“The Cable”) that the Administration does not support new legislation because the
Administration is already implementing and expanding sanctions against Iran.56
Among specific recent proposals for new sanctions, in the 111th Congress, Representative
Sherman introduced H.R. 6296, which, in Section 202, would amend ISA to make sanctionable
“long term agreements” to buy oil from Iran—agreements that would involve large, up-front
payments to Iran for purchases of oil over a long period of time. A provision of that bill would
have extended ISA sanctionability to any energy project conducted with NIOC, anywhere in the
world. An amended version of the bill was introduced in the 112th Congress (H.R. 1655,
introduced April 15, 2011).
Another bill, H.R. 1905, contains language restating the provisions of ISA and would:
• Add two sanctions to the available ISA menu: a ban on visas for the principal
officers or controlling shareholders of sanctioned firms (and their subsidiaries,
parents, and affiliates); and application of any ISA sanction to these persons.
• Require the President to impose at least six out of the expanded ISA menu of 11
available sanctions.
• Would subject to ISA sanctions any purchases of Iranian oil or gas if the
Revolutionary Guard is involved in the transaction (production or sale of that gas
or oil).
• States that it is U.S. policy to support those in Iran seeking democracy.
• Would require an Administration report listing all persons who are members of
named Iranian government institutions, including high ranking Revolutionary
Guard officers – and ban visas for the named individuals.
• Contains elements similar to H.R. 740 on Securities and Exchange Commission
(SEC) disclosures.
Another bill that focuses primarily on economic sanctions and proliferation sanctions is S.1048,
introduced May 23, 2011. (A companion measure, H.R. 2105, was introduced in the House on
June 3, 2011.) Among other provisions, this bill:
• States (Section 101) that it is the policy of the United States to prevent Iran from
acquiring a nuclear weapons capability.
• Primarily targets affiliates of the Revolutionary Guard for sanctions, and expands
the list of sanctions (adding a ban on financing, aid, or investment) to be imposed

56 Josh Rogin. “Steinberg: No Need for Another Iran Sanctions Bill.” Foreign Policy: The Cable. June 15, 2011.
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on violators named under the Iran, Syria, North Korea Non-Proliferation Act,
discussed above.
• Like H.R. 1905, subjects to ISA sanctions purchases of Iranian oil or gas in
which the Revolutionary Guard or its affiliates are involved.
• Would sanction foreign firms that participate in energy-related joint ventures with
Iran outside Iranian territory.
• Would prohibit ships to put into port in the United States if the vessel entered a
port in Iran, North Korea, or Syria any time 180 days prior.
• Like H.R. 1905, would deny visas to senior officials of Iran, but extends that to
North Korea and Syria, and does not define specific government agencies in Iran
whose members shall be named by the Administration.
• Provides for sanctions against any person determined to be providing or
acquiring militarily useful equipment to/from Iran, North Korea, or Syria.
• Contains Iran human rights-related and SEC disclosure provisions similar to bills
discussed below.
Other economic sanctions-related measures introduced in the 112th Congress include S. 366 and
H.R. 740. These bills would require firms to declare in their required filings with the Securities
and Exchange Commission whether that firm had undertaken activity that could violate ISA,
CISADA, or executive orders (13224 or 13382) and regulations that bar dealings with designated
Iranian entities.
Another apparent trend in the 112th Congress, based on introduced legislation, is to expand the
sanctioning of Iranians named as human rights abusers. This builds on the human rights
provisions of CISADA and the earlier Iran Freedom Support Act. In particular, the Iran Human
Rights and Democracy Promotion Act of 2011 (S.879 and H.R. 1714) would: make mandatory
investigations of Iranian human rights abusers; sanction the sale to Iran of equipment that could
be used to suppress demonstrations; reauthorize the Iran Freedom Support Act (see below); and
create a “Special Representative” position at the Department of State to focus on highlighting
Iran’s human rights abuses and coordinate U.S. and international responses. As noted, portions of
H.R. 1905 and S. 1048, which mainly focus on economic sanctions, also contain measures to
further penalize Iranian human rights abusers or otherwise promote Internet freedom and
democracy in Iran.
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Table 6. 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 Company (Arak supplier)
Kalaye Electric (Natanz supplier))
Pars Trash Company (centrifuge program) Farayand Technique (centrifuge program)
Defense Industries Organization (DIO)
7th of Tir (DIO subordinate)
Shahid Hemmat Industrial Group (SHIG)—missile program
Shahid Bagheri Industrial Group (SBIG)—missile program
Fajr Industrial Group (missile program)
Mohammad Qanadi, AEIO Vice President
Behman Asgarpour (Arak manager)
Ehsan Monajemi (Natanz construction manager)
Jafar Mohammadi (Adviser to AEIO)
Gen. Hosein Salimi (Commander, IRGC Air Force)
Dawood Agha Jani (Natanz official)
Ali Hajinia Leilabadi (director of Mesbah Energy)
Lt. Gen. Mohammad Mehdi Nejad Nouri (Malak Ashtar University of Defence Technology rector)
Bahmanyar Morteza Bahmanyar (AIO official)
Reza Gholi Esmaeli (AIO official)
Ahmad Vahid Dastjerdi (head of Aerospace Industries Org., AIO)
Maj. Gen. Yahya Rahim Safavi (Commander in Chief, IRGC)
Entities/Persons Added by Resolution 1747
Ammunition and Metal urgy Industries Group (controls 7th of Tir)
Parchin Chemical Industries (branch of DIO)
Karaj Nuclear Research Center
Novin Energy Company
Cruise Missile Industry Group
Sanam Industrial Group (subordinate to AIO)
Ya Mahdi Industries Group
Kavoshyar Company (subsidiary of AEIO)
Sho’a Aviation (produces IRGC light aircraft for asymmetric warfare)
Bank Sepah (funds AIO and subordinate entities)
Esfahan Nuclear Fuel Research and Production Center and Esfahan Nuclear Technology Center
Qods Aeronautics Industries (produces UAV’s, para-gliders for IRGC asymmetric warfare)
Pars Aviation Services Company (maintains IRGC Air Force equipment)
Gen. Mohammad Baqr Zolqadr (IRGC officer serving as deputy Interior Minister
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Brig. Gen. Qasem Soleimani (Qods Force commander)
Fereidoun Abbasi-Davani (senior defense scientist)
Mohasen Fakrizadeh-Mahabai (defense scientist)
Seyed Jaber Safdari (Natanz manager)
Mohsen Hojati (head of Fajr Industrial Group)
Ahmad Derakshandeh (head of Bank Sepah)
Brig. Gen. Mohammad Reza Zahedi (IRGC ground forces commander)
Amir Rahimi (head of Esfahan nuclear facilities)
Mehrdada Akhlaghi Ketabachi (head of SBIG)
Naser Maleki (head of SHIG)
Brig. Gen. Morteza Reza’i (Deputy commander-in-chief, IRGC)
Vice Admiral Ali Akbar Ahmadiyan (chief of IRGC Joint Staff)
Brig. Gen. Mohammad Hejazi (Basij commander)
Entities Added by Resolution 1803
Thirteen Iranians named in Annex 1 to Resolution 1803; al reputedly involved in various aspects of nuclear program. Bans travel
for five named Iranians.
Electro Sanam Co.
Abzar Boresh Kaveh Co. (centrifuge production)
Barzaganin Tejaral Tavanmad Saccal
Jabber Ibn Hayan
Khorasan Metal urgy Industries
Niru Battery Manufacturing Co. (Makes batteries for Iranian military and missile systems)
Ettehad Technical Group (AIO front co.)
Industrial Factories of Precision
Joza Industrial Co.
Pshgam (Pioneer) Energy Industries
Tamas Co. (involved in uranium enrichment)
Safety Equipment Procurement (AIO front, involved in missiles)
Entities Added by Resolution 1929
Over 40 entities added; makes mandatory a previously non-binding travel ban on most named Iranians of previous resolutions.
Adds one individual banned for travel—AEIO head Javad Rahiqi
Amin Industrial Complex
Armament Industries Group
Defense Technology and Science Research Center (owned or controlled by Ministry of Defense)…….
Doostan International Company
Farasakht Industries
First East Export Bank, PLC (only bank added by 1929)
Kaveh Cutting Tools Company
M. Babaie Industries
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Malek Ashtar University (subordinate of Defense Technology and Science Research Center, above)
Ministry of Defense Logistics Export (sells Iranian made arms to customers worldwide)
Mizan Machinery Manufacturing
Modern Industries Technique Company
Nuclear Research Center for Agriculture and Medicine (research component of the AEIO)
Pejman Industrial Services Corp.
Sabalan Company
Sahand Aluminum Parts Industrial Company
Shahid Karrazi Industries
Shahid Sattari Industries
Shahid Sayyade Shirazi Industries (acts on behalf of the DIO)
Special Industries Group (another subordinate of DIO)
Tiz Pars (cover name for SHIG)
Yazd Metal urgy Industries
The following are Revolutionary Guard affiliated firms, several are subsidiaries of Khatam ol-Anbiya, the main Guard construction
affiliate:
Fater Institute
Garaghe Sazendegi Ghaem
Gorb Karbala
Gorb Nooh
Hara Company
Imensazan Consultant Engineers Institute
Khatam ol-Anbiya
Makin
Omran Sahel
Oriental Oil Kish
Rah Sahel
Rahab Engineering Institute
Sahel Consultant Engineers
Sepanir
Sepasad Engineering Company
The fol owing are entities owned or controlled by Islamic Republic of Iran Shipping Lines (IRISL):
Irano Hind Shipping Company
IRISL Benelux
South Shipping Line Iran
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, September 2007
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Shahid Bakeri Industrial Group (Iran)
June 2005, February 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 Economic
June 2006
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)
September 2007
Korea Mining and Development Corp. (N. Korea)
September 2007
Islamic Revolutionary Guard Corps (IRGC)
October 21, 2007
Ministry of Defense and Armed Forces Logistics
October 21, 2007
Bank Melli (Iran’s largest bank, widely used by Guard); Bank Melli Iran
October 21, 2007
Zao (Moscow); Melli Bank PC (U.K.)
Bank Kargoshaee
October 21, 2007
Arian Bank (joint venture between Melli and Bank Saderat). Based in
October 21, 2007
Afghanistan
Bank Mellat (provides banking services to Iran’s nuclear sector);
October 21, 2007
Mellat Bank SB CJSC (Armenia). Reportedly has $1.4 billion in assets
in UAE
Persia International Bank PLC (U.K.)
October 21, 2007
Khatam ol Anbiya Gharargah Sazendegi Nooh (main IRGC
October 21, 2007
construction and contracting arm, with $7 billion in oil, gas deals)
Oriental Oil Kish (Iranian oil exploration firm)
October 21, 2007
Ghorb Karbala; Ghorb Nooh (synonymous with Khatam ol Anbiya)
October 21, 2007
Sepasad Engineering Company (Guard construction affiliate)
October 21, 2007
Omran Sahel (Guard construction affiliate)
October 21, 2007
Sahel Consultant Engineering (Guard construction affiliate) October
21,
2007
Hara Company
October 21, 2007
Gharargahe Sazandegi Ghaem
October 21, 2007
Bahmanyar Morteza Bahmanyar (AIO, Iran missile official, see above
October 21, 2007
under Resolution 1737)
Ahmad Vahid Dastjerdi (AIO head, Iran missile program)
October 21, 2007
Reza Gholi Esmaeli (AIO, see under Resolution 1737)
October 21, 2007
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Morteza Reza’i (deputy commander, IRGC) See also Resolution 1747
October 21, 2007
Mohammad Hejazi (Basij commander). Also, Resolution 1747
October 21, 2007
Ali Akbar Ahmadian (Chief of IRGC Joint Staff). Resolution 1747
October 21, 2007
Hosein Salimi (IRGC Air Force commander). Resolution 1737
October 21, 2007
Qasem Soleimani (Qods Force commander). Resolution 1747
October 21, 2007
Future Bank (Bahrain-based but allegedly controlled by Bank Melli) March 12, 2008
Yahya Rahim Safavi (former IRGC Commander in Chief
July 8, 2008
Mohsen Fakrizadeh-Mahabadi (senior Defense Ministry scientist)
July 8, 2008
Dawood Agha-Jani (head of Natanz enrichment site)
July 8, 2008
Mohsen Hojati (head of Fajr Industries, involved in missile program)
July 8, 2008
Mehrdada Akhlaghi Ketabachi (heads Shahid Bakeri Industrial Group)
July 8, 2008
Naser Maliki (heads Shahid Hemmat Industrial Group)
July 8, 2008
Tamas Company (involved in uranium enrichment)
July 8, 2008
Shahid Sattari Industries (makes equipment for Shahid Bakeri)
July 8, 2008
7th of Tir (involved in developing centrifuge technology)
July 8, 2008
Ammunition and Metal urgy Industries Group (partner of 7th of Tir)
July 8, 2008
Parchin Chemical Industries (deals in chemicals used in ballistic missile July 8, 2008
programs)
Karaj Nuclear Research Center
August 12, 2008
Esfahan Nuclear Fuel Research and Production Center (NFRPC)
August 12, 2008
Jabber Ibn Hayyan (reports to Atomic Energy Org. of Iran, AEIO)
August 12, 2008
Safety Equipment Procurement Company
August 12, 2008
Joza Industrial Company (front company for Shahid Hemmat
August 12, 2008
Industrial Group, SHIG)
Islamic Republic of Iran Shipping Lines (IRISL) and 18 affiliates,
September 10, 2008
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 Armament
September 17, 2008
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 to Iran’s October 22, 2008
Ministry of Defense and Armed Forces Logistics
Banco Internacional de Desarol o, C.A., Venezuelan-based Iranian bank,
sanctioned as an affiliate of the Export Development Bank.
Assa Corporation (alleged front for Bank Melli involved in managing
December 17, 2008
property in New York City on behalf of Iran)
11 Entities Tied to Bank Melli: Bank Melli Iran Investment (BMIIC);
March 3, 2009
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
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IRGC General Rostam Qasemi, head of Khatem ol-Anbiya
February 10, 2010 (see also October 21, 2007)
Construction Headquarters (key corporate arm of the IRGC)
Fater Engineering Institute (linked to Khatem ol-Anbiya)
February 10, 2010
Imensazen Consultant Engineers Institute (linked to Khatem ol-
February 10, 2010
Anbiya)
Makin Institute (linked to Khatem ol-Anbiya)
February 10, 2010
Rahab Institute (linked to Khatem on-Anbiya)
February 10, 2010
Entities sanctioned on June 16, 2010
- Post Bank of Iran
- IRGC Air Force
- IRGC Missile Command
- Rah Sahel and Sepanir Oil and Gas Engineering (for ties to Khatem ol-Anibya IRGC construction affiliate)
- Mohammad Ali Jafari—IRGC Commander-in-Chief since September 2007
- Mohammad Reza Naqdi—Head of the IRGC’s Basij militia force that suppresses dissent (since October 2009)
- Ahmad Vahedi—Defense Minister
- javedan Mehr Toos, Javad Karimi Sabet (procurement brokers or atomic energy managers)
- Naval Defense Missile Industry Group (controlled by the Aircraft Industries Org that manages Iran’s missile programs)
- Five front companies for IRISL: Hafiz Darya Shipping Co.; Soroush Sarzamin Asatir Ship Management Co.; Safiran Payam Darya;
and Hong Kong-based Seibow Limited and Seibow Logistics.
Also identified on June 16 were 27 vessels linked to IRISKL and 71 new names of already designated IRISL ships.
Several Iranian entities were also designated as owned or controlled by Iran for purposes of the ban on U.S. trade with Iran.
Entities sanctioned on November 30, 2010
- Pearl Energy Company (formed by First East Export Bank , a subsidiary of Bank Mel at
- Pearl Energy Services, SA
- Ali Afzali (high official of First East Export Bank)
- IRISL front companies: Ashtead Shipping, Byfleet Shipping, Cobham Shipping, Dorking Shipping, Effingham Shipping, Farnham
Shipping, Gomshal Shipping, and Horsham Shipping (al located in the Isle of Man).
- IRISL and affiliate officials: Mohammad Hosein Dajmar, Gholamhossein Golpavar, Hassan Jalil Zadeh, and Mohammad Haji Pajand.
Entities sanctioned on December 21, 2010:
- Bonyad (foundation) Taavon Sepah, for providing services to the IRGC
- Ansar Bank (for providing financial services to the IRGC)
- Mehr Bank (same justification as above)
- Moal em Insurance Company (for providing marine insurance to IRISL, Islamic Republic of Iran Shipping Lines)
Entities Sanctioned Under Executive Order 13224 (Terrorism Entities)
Qods Force
October 21, 2007
Bank Saderat (al egedly used to funnel Iranian money to Hezbollah,
October 21, 2007
Hamas, PIJ, and other Iranian supported terrorist groups)
Al Qaeda Operatives in Iran: Saad bin Laden; Mustafa Hamid;
January 16, 2009
Muhammad Rab’a al-Bahtiyti; Alis Saleh Husain
Qods Force senior officers: Hushang Allahdad, Hossein Musavi,Hasan
August 3, 2010
Mortezavi, and Mohammad Reza Zahedi
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Iranian Committee for the Reconstruction of Lebanon, and its
August 3, 2010
director Hesam Khoshnevis, for supporting Lebanese Hizbal ah
Imam Khomeini Relief Committee Lebanon branch, and its director
August 3, 2010
Ali Zuraik, for providing support to Hizbal ah
Razi Musavi, a Syrian based Iranian official allegedly providing support
August 3, 2010
to Hizballah
Liner Transport Kish (for providing shipping services to transport
December 21, 2010
weapons to Lebanese Hizbal ah)
Entities Sanctioned Under the Iran North Korea Syria Non-Proliferation Act or Executive Order 12938
The designations are under the Iran, North Korea, Syria Non-Proliferation Act (INKSNA) unless specified. These designations
expire after two years, unless re-designated
Baltic State Technical University and Glavkosmos, both of Russia
July 30, 1998 (E.O. 12938). Both removed in 2010—Baltic
on Jan. 29, 2010, and Glavkosmos on March 4, 2010
D. Mendeleyev University of Chemical Technology of Russia and
January 8, 1999 (E.O. 12938). Both removed on May 21,
Moscow Aviation Institute
2010
Norinco (China). For al eged missile technology sale to Iran.
May 2003
Taiwan Foreign Trade General Corporation (Taiwan)
July 4, 2003
Tula Instrument Design Bureau (Russia). For alleged sales of laser-
September 17, 2003 (also designated under Executive
guided artillery shells to Iran.
Order 12938), removed May 21, 2010
13 entities sanctioned including companies from Russia, China,
April 7, 2004
Belarus, Macedonia, North Korea, UAE, and Taiwan.
14 entities from China, North Korea, Belarus, India (two nuclear
September 29, 2004
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 missile
December 2004 and January 2005
program. Many, such as North Korea’s Changgwang Sinyong and
China’s Norinco and Great Wal 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), India (two
December 26, 2005
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 and Prachi
August 4, 2006 (see below for Rosobornexport removal)
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. Rosobornexport, Tula Design, and Komna Design Office of January 2007 (see below for Tula and Rosoboronexport
Machine Building, and Alexei Safonov (Russia); Zibo Chemical, China
removal)
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 penalized for
April 23, 2007
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
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(Mexico); and Arif Durrani (Pakistani national).
13 entities: China Xinshidai Co.; China Shipbuilding and Offshore
October 23, 2008. Rosoboronexport removed May 21,
International Corp.; Huazhong CNC (China); IRGC; Korea Mining
2010.
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);
16 entities: Belarus: Belarusian Optical Mechanical Association;
May 23, 2011
Beltech Export; China: Karl Lee; Dalian Sunny Industries; Dalian
Zhongbang Chemical Industries Co.; Xian Junyun Electronic; Iran:
Milad Jafari; DIO; IRISL; Qods Force; SAD Import-Export; SBIG;
North Korea: Tangun Trading; Syria: Industrial Establishment of
Defense; Scientific Studies and Research Center; Venezuela: CAVIM.
Entities Designated as Threats to Iraqi Stability under Executive Order 13438
Ahmad Forouzandeh. Commander of the Qods Force Ramazan
January 9, 2008
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 funnels
January 9, 2008
Iranian arms to Shiite militias in Iraq.
Isma’il al-Lami (Abu Dura). Shiite militia leader, breakaway from Sadr
January 9, 2008
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 pro-
January 9, 2008
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
Iranians Sanctioned Under September 29, 2010, Executive Order 13553 on Human Rights Abusers
1. IRGC Commander Mohammad Ali Jafari
Al sanctioned on September 29, 2010
2. Minister of Interior at time of June 2009 elections Sadeq Mahsouli
3. Minister of Intelligence at time of elections Qolam Hossein
Mohseni-Ejei
4. Tehran Prosecutor General at time of elections Saeed Mortazavi
5. Minister of Intelligence Heydar Moslehi
6. Former Defense Minister Mostafa Mohammad Naj ar
7. Deputy National Police Chief Ahmad Reza Radan
8. Basij (security militia) Commander at time of elections Hossein
Taeb
9. Tehran Prosecutor General Abbas Dowlatabadi (appointed August
Sanctioned on February 23, 2011
2009). Has indicted large numbers of Green movement protesters.
10. Basij forces commander (since October 2009) Mohammad Reza
Naqdi (was head of Basij intelligence during post 2009 election
crackdown)
11. Islamic Revolutionary Guad Corps (IRGC)
Sanctioned on June 9, 2011.
12. Basij Resistance Force
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Iran Sanctions

13. Law Enforcement Forces (LEF)
14. LEF Commander Ismail Ahmad Moghadam




Author Contact Information

Kenneth Katzman

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


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