Iran: U.S. Economic Sanctions and the
Authority to Lift Restrictions

Dianne E. Rennack
Specialist in Foreign Policy Legislation
November 21, 2014
Congressional Research Service
7-5700
www.crs.gov
R43311


Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions

Summary
The United States has led the international community in imposing economic sanctions on Iran,
in an effort to change the government of that country’s support of acts of international terrorism,
poor human rights record, weapons and missile development and acquisition, role in regional
instability, and development of a nuclear program.
This report identifies the legislative bases for sanctions imposed on Iran, and the nature of the
authority to waive or lift those restrictions. It comprises two tables that present legislation and
executive orders that are specific to Iran and its objectionable activities in the areas of terrorism,
human rights, and weapons proliferation. It will be updated if and when new legislation is
enacted, or, in the case of executive orders, if and when the President takes additional steps to
change U.S. policy toward Iran.
Other CRS reports address the U.S.-Iran relationship, including a comprehensive discussion of
the practical application of economic sanctions: CRS Report RS20871, Iran Sanctions, by
Kenneth Katzman. See also CRS Report R43333, Interim Agreement on Iran’s Nuclear Program,
by Kenneth Katzman and Paul K. Kerr; CRS Report R43492, Achievements of and Outlook for
Sanctions on Iran
, by Kenneth Katzman; CRS Report RL32048, Iran: U.S. Concerns and Policy
Responses
, by Kenneth Katzman; and CRS Report R40094, Iran’s Nuclear Program: Tehran’s
Compliance with International Obligations
, by Paul K. Kerr.

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Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions

Contents
Overview .......................................................................................................................................... 1
Authority to Waive or Lift Economic Sanctions .............................................................................. 2
International Terrorism Determination ...................................................................................... 3
Legislation and Executive Orders .................................................................................................... 4

Tables
Table 1. Iran—Economic Sanctions Currently Imposed in Furtherance of U.S. Foreign
Policy or National Security Objectives ......................................................................................... 5
Table 2. Executive Orders Issued to Meet Statutory Requirements To Impose Economic
Sanctions on Iran ........................................................................................................................ 29

Contacts
Author Contact Information........................................................................................................... 35

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Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions

Overview
The regime of economic sanctions against Iran is arguably the most complex the United States
and the international community have ever imposed on a rogue state. Iran’s economy was once
integrated into world trade, markets, and banking. As relations deteriorated, for the United States
starting during Iran’s 1979 revolution and hostage-taking at the U.S. Embassy, and for the larger
international community over more recent human rights, regional stability, and nuclear
proliferation concerns, this complete economic integration offered seemingly limitless
opportunities to impose economic restrictions and create points where pressure could be applied
to bring Iran back into conformity with international norms.
The June 2013 election of President Hassan Rouhani seemed to have created the possibility of an
opening between the United States and Iran. The presidents of each nation addressed a fall 2013
meeting of the U.N. General Assembly, and spoke directly to one another shortly thereafter—the
first direct contact at the top level in 34 years. Diplomatic staff representing the United States,
Russia, China, France, Britain (permanent members of the U.N. Security Council), plus Germany
(P5+1), met with Iran’s foreign ministry in mid-October 2013 on the heels of that contact. Over
November 7-9, 2013, these negotiators drafted an interim deal that would require Iran to limit its
nuclear program and, in exchange, require the United States and others to ease economic
sanctions affecting Iran’s access to some of its hard currency held abroad. The P5+1 and Iran
negotiators agreed to a Joint Plan of Action (JPOA) on November 24, 2013, under which Iran
would commit to placing “meaningful limits of its nuclear program,” and the P5+1 states would
“provide Iran with limited, targeted, and reversible sanctions relief for a six-month period.”1
Subsequently, all parties agreed to extend the terms of the JPOA an additional six months, to
November 24, 2014.
The sudden possibility that the United States may ease financial sector sanctions, and perhaps
commit to an eventual dismantling of the entire panoply of economic restrictions on Iran affecting
aid, trade, shipping, banking, insurance, underwriting, and support in the international financial
institutions, arrived at a time when Congress had been considering additional sanctions on Iran.
The House adopted H.R. 850, the Nuclear Iran Prevention Act of 2013, on July 31, 2013, by a
vote of 400-20. That act would require new economic restrictions on trade in cars manufacturing
and extractive industries, further impede financial activities, and place greater demands for
sanctions compliance by third countries. In the Senate, H.R. 850 was referred to the Committee
on Banking, Housing, and Urban Affairs, and a number of other legislative proposals have been
referred to committee that might provide the Senate a quick means to assert Congress’s influence
if implementation of the JPOA hits a snag or fails outright.2 The House Committee on Foreign

1 U.S. Department of the Treasury. Office of Foreign Assets Control. Guidance Relating to the Provision of Certain
Temporary Sanctions Relief In Order To Implement the Joint Plan of Action Reached on November 24, 2013, Between
the P5+1 and the Islamic Republic of Iran,
January 20, 2014. 79 F.R. 5025; January 30, 2014. See also: U.S.
Department of the Treasury. Office of Foreign Assets Control. Publication of Guidance Relating to the Provision of
Certain Temporary Sanctions Relief, as Extended, July 21, 2014.
79 F.R. 45233; August 4, 2014. See, also: Department
of the Treasury. Frequently Asked Questions Relating to the Temporary Sanctions Relief To Implement the Joint Plan
of Action Between the P5+1 and the Islamic Republic of Iran,
January 20, 2014. OFAC has also issued a number of
General Licenses related to sanctions relief, all available at www.treasury.gov/ofac. See also Iranian Transactions and
Sanctions Regulations, at 31 Code of Federal Regulations (CFR) Part 560.
2 National defense authorization acts were used to enact new sanctions and amend existing provisions on Iran in
FY2010, FY2012, and FY2013. See also: the Iran Sanctions Loophole Elimination Act of 2013 (S. 892); Iran Sanctions
(continued...)
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Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions

Affairs and Senate Committee on Foreign Relations have held hearings to assess the JPOA and
the United States’ diplomatic and economic options.3
Authority to Waive or Lift Economic Sanctions
The ability to impose and ease economic sanctions with some nimbleness and responsiveness to
changing events is key to effectively using the tool in furtherance of national security or foreign
policy objectives. Historically, both the President and Congress have recognized this essential
requirement and have worked together to provide the President substantial flexibility. In the
collection of laws that are the statutory basis for the U.S. economic sanctions regime on Iran, the
President retains, in varying degrees, the authority to tighten and relax restrictions.
In the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA;
P.L. 111-195, as amended; 22 U.S.C. 8501 et seq.),4 Congress grants to the President the authority
to terminate most of the sanctions imposed on Iran in that act as well as the Iran Threat Reduction
and Syria Human Rights Act of 2012 (P.L. 112-158; 22 U.S.C. 8701 et seq.), and Iran Freedom
and Counter-proliferation Act of 2012 (P.L. 112-239; 22 U.S.C. 8801 et seq.). Before terminating
these sanctions, however, the President must certify that the government of Iran has ceased its
engagement in the two critical areas of terrorism and weapons, as set forth in Section 401 of
CISADA—
SEC. 401 [22 U.S.C. 8551]. GENERAL PROVISIONS.
(a) SUNSET.—The provisions of this Act (other than sections 105 and 305 and the
amendments made by sections 102, 107, 109, and 205) shall terminate, and section
13(c)(1)(B) of the Investment Company Act of 1940, as added by section 203(a), shall cease
to be effective, on the date that is 30 days after the date on which the President certifies to
Congress that—
(1) the Government of Iran has ceased providing support for acts of international
terrorism and no longer satisfies the requirements for designation as a state sponsor of
terrorism (as defined in section 301) under—
(A) section 6(j)(1)(A) of the Export Administration Act of 1979 (50 U.S.C.
App. 2405(j)(1)(A)) (or any successor thereto);
(B) section 40(d) of the Arms Export Control Act (22 U.S.C. 2780(d)); or
(C) section 620A(a) of the Foreign Assistance Act of 1961 (22 U.S.C.
2371(a)); and

(...continued)
Implementation Act of 2013 (S. 965); Iran Nuclear Compliance Act of 2013 (S. 1765).
3 U.S. Congress, House Committee on Foreign Affairs, Joint hearing of the Subcommittee on Middle East and North
Africa and Subcommittee on Terrorism, Nonproliferation, and Trade, Implementation of the Iran Nuclear Deal, 113th
Cong., 2nd sess., January 28, 2014; and Senate Committee on Foreign Relations, Negotiations on Iran’s Nuclear
Program,
February 4, 2014.
4Section 401(a) and (b)(1) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
(CISADA; P.L. 111-195; 22 U.S.C. 8551), as amended. Table 1 shows the sanctions for which Section 401 waiver
authority is applicable.
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Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions

(2) Iran has ceased the pursuit, acquisition, and development of, and verifiably
dismantled its, nuclear, biological, and chemical weapons and ballistic missiles and
ballistic missile launch technology.
(b) PRESIDENTIAL WAIVERS.—
(1) IN GENERAL.—The President may waive the application of sanctions under
section 103(b), the requirement to impose or maintain sanctions with respect to a person
under section 105(a), 105A(a), 105B(a), or 105C(a) the requirement to include a person
on the list required by section 105(b), 105A(b), 105B(b), or 105C(b), the application of
the prohibition under section 106(a), or the imposition of the licensing requirement
under section 303(c) with respect to a country designated as a Destination of Diversion
Concern under section 303(a), if the President determines that such a waiver is in the
national interest of the United States.
International Terrorism Determination
To lift the majority of the economic sanctions imposed by CISADA, the President must determine
and certify that the government of Iran no longer supports acts of international terrorism. The
government of Iran is designated as a state sponsor of acts of international terrorism, effective
January 1984, pursuant to the Secretary of State’s authorities and responsibilities under Section
6(j) of the Export Administration Act of 1979. Various statutes impede or prohibit foreign aid,
financing, and trade because of that designation. Three laws (§620A, Foreign Assistance Act of
1961 [22 U.S.C. 2371]; §40, Arms Export Control Act [22 U.S.C. 2780]; and §6(j), Export
Administration Act of 1979 [50 U.S.C. app. 2405(j)]) form the “terrorist list.”5 Because these
statutes are not Iran-specific, they are not included in Table 1.
The President holds the authority to remove the designation of any country from the terrorist list.
Though each of the three laws provides slightly different procedures, the authority to delist Iran
resides with the President, and generally requires him to find that
• there has been a fundamental change in the leadership and policies of the
government;
• the government is not supporting acts of international terrorism; and
• the government has assured that it will not support terrorism in the future.
Alternatively, the President may notify Congress that the terrorism designation will be rescinded
in 45 days, and that the rescission is justified on the basis that
• the government has not supported an act of terrorism in the preceding six
months; and
• the government has assured that it will not support terrorism in the future.

5 §40A, Arms Export Control Act (22 U.S.C. 2780) also prohibits trade in defense articles and defense services to any
country the President finds “is not cooperating fully with Untied States antiterrorism efforts.” The President may waive
the prohibition if he finds it “important to the national interests” to do so. This provision requires the President to
annually identify uncooperative states; Iran has been listed since the provision’s enactment in 1996 (first list was issued
in 1997; authority to make certifications is currently delegated to the Secretary of State).
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Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions

In the case of foreign aid, the President also is authorized to provide aid despite the terrorism
designation if he finds that “national security interests or humanitarian reasons justify” doing so
and so notifies Congress 15 days in advance. In practical terms, the process of removing a state
from the list of sponsors of international terrorism is studied and argued throughout the entire
executive branch interagency, with those departments that are tasked with administering the
restrictions—primarily State, Commerce, Treasury, Justice, and Defense—each weighing in. For
a state to be delisted—which has occurred, most recently, to North Korea and Libya—the
Secretary of State publishes a public notice that the respective government no longer supports
acts of international terrorism; that starts the six-month countdown required by legislation. After
six months (or later), both the President and the Secretary of State issue determinations and
announcements, which is followed by a rewriting of each department’s regulations governing
exports, arms sales, transactions, and other related matters.
Legislation and Executive Orders
The two tables presented in this report identify the legislative bases for sanctions imposed on
Iran, and the nature of the authority to waive or lift those restrictions. Table 1 presents legislation,
and Table 2 shows executive orders that are specific to Iran and its objectionable activities in the
areas of terrorism, human rights, and weapons proliferation.
Public laws that are not specific to the objectionable activities of the government of Iran but have
been invoked to impede transactions or other economic or diplomatic relations are not included
here. Failure to achieve human rights standards as a condition for foreign aid (e.g., the Foreign
Assistance Act of 1961, the Trafficking Victims Protection Act of 2000, and related annual
appropriations), or refusal to comply with international nonproliferation norms (e.g., Chemical
and Biological Weapons Control and Warfare Elimination Act of 1991), for example, can trigger a
range of economic sanctions. These and other authorities have been applied to Iran. It is unlikely
that these statutes would be amended if and when they no longer apply to Iran. Sanctions
authorized by these statutes are applied, and lifted, by executive branch decision.
On the other hand, because the President holds sole authority to renew, alter, and revoke
executive orders he issues pursuant to the National Emergencies Act (NEA) and the International
Emergency Economic Powers Act (IEEPA), Table 2 includes actions taken that are specific to
Iran and also actions taken that are not specific to Iran (e.g., Executive Order 13224 and 13382
target terrorists and proliferators, respectively) but have been applied to that country. The
authorities in these orders have been exercised to affect Iran in a significant way. Executive
orders are subject to their underlying statutory authorities: economic sanctions are most often
based on the President’s authorities established in IEEPA. These are applied and lifted by the
President; often their implementation and administration are delegated to the Secretary of the
Treasury, who in turn assigns the task to Treasury’s Office of Foreign Assets Control. Many of the
Iran-specific sanctions in statute cite the President’s authority to curtail transactions under IEEPA.
In some instances, Congress has enacted restrictions on the President’s unilateral authority to
revoke an order, and the economic restrictions therein, until specific conditions are met.
The Departments of the Treasury and State have identified the provisions in laws and Executive
Orders that the United States would suspend or waive to implement the Joint Plan of Action of
November 24, 2013. In the following tables, these provisions are noted in bold in the far-right
columns.
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Table 1. Iran—Economic Sanctions Currently Imposed in Furtherance of U.S. Foreign Policy or National Security Objectives
Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
FOREIGN AID: AUTHORIZATION AND APPROPRIATIONS
Sec. 307, Foreign
General foreign
Limits proportionate share of foreign aid to
Statutory requirement
No waiver; exemption for certain UNICEF
Assistance Act of
policy reasons
international organizations which, in turn,
and IAEA programs. Secretary of State may
1961 (P.L. 87-195; 22
expend funds in Iran.
block funds if he determines that IAEA
U.S.C. 2227; as
programs are “inconsistent with U.S.
amended)
nonproliferation and safety goals, will provide
Iran with training or expertise ... , or are
being used as a cover for the acquisition of
sensitive nuclear technology” and notifies
Congress.
Sec. 7007, Foreign
General foreign
Prohibits direct funding to the Government of
Statutory requirement
No waiver, though “notwithstanding” clauses
Operations
policy reasons
Iran, including Export-Import Bank funds.
elsewhere in appropriations and authorization
Appropriations
statutes could result in aid being made
(P.L. 113-76; 128
available.
Stat. 494; as
continued)
Sec. 7015(f), Foreign General foreign
Prohibits most foreign aid to Iran, “except as
Statutory requirement
President may waive or lift by exercising
Operations
policy reasons
provided through the regular notification
notification procedures of the Committee on
Appropriations
procedures of the Committees on
Appropriations.
(P.L. 113-76; 128
Appropriations.”
Stat. 499; as
continued)
Sec. 7041(b),
Nuclear
Prohibits U.S. Export-Import Bank from
Statutory requirement
No waiver, though those sanctioned under
Foreign
nonproliferation
providing financing “to any person that is
Sec. 5(a)(2) and (3), Iran Sanctions Act of
Operations
subject to sanctions under” Sec. 5(a)(2) or (3)
1996, is subject to change. See below.
Appropriations
of the Iran Sanctions Act of 1996—those under
(P.L. 112-76; 128
sanctions for engaging in production or export
Stat. 523; as
to Iran of refined petroleum products.
continued)
CRS-5


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
IRAQ SANCTIONS ACT OF 1990
(P.L. 101-513; 50 U.S.C. 1701 note; extended to apply to Iran by Sec. 1603 of the Iran-Iraq Arms Non-proliferation Act of 1992; see below)
Sec. 586G Nonproliferation
Prohibits:
Statutory requirement
President may waive if he finds it “essential to
the national interest” to do so and notifies
—Sales under the Arms Export Control Act
the Armed Services, Foreign Affairs/Relations
(foreign military sales);
Committees 15 days in advance (Sec. 1606,
—Export licenses for commercial arms sales for
IIANA).
any USML item;
—Export of Commerce Control List items; and
—export of nuclear equipment, materials, or
technology.
IRAN-IRAQ ARMS NON-PROLIFERATION ACT OF 1992 (IIANA)
(Title XVI of P.L. 102-484 (National Defense Authorization Act for Fiscal Year 1993); 50 U.S.C. 1701 note; as amended)
Sec. 1603
Nonproliferation
Makes selected sanctions in Sec. 586G, Iran

President may waive; see Sec. 586G, Iran
Sanctions Act of 1990, applicable for Iran (see
Sanctions Act of 1990, above.
above).
Sec. 1604
Nonproliferation
For a period of 2 years, for any person who
Statutory requirement
President may waive if he finds it “essential to
“transfers goods or technology so as to
the national interest” to do so and notifies
contribute knowingly and material y” to Iran’s
the Armed Services, Foreign Affairs/Relations
efforts “to acquire chemical, biological, or
Committees 15 days in advance (Sec. 1606,
nuclear weapons or to acquire destabilizing
IIANA).
numbers and types of advanced conventional
weapons”:
—prohibits USG procurement contracts; and
—prohibits U.S. export licenses.
Sec. 1605
Nonproliferation
For any foreign government that “transfers
Statutory requirement
President may waive if he finds it “essential to
or retransfers goods or technology so as to
the national interest” to do so and notifies
contribute knowingly and material y” to Iran’s
the Armed Services, Foreign Affairs/Relations
efforts “to acquire chemical, biological, or
Committees 15 days in advance (Sec. 1606,
nuclear weapons or to acquire destabilizing
IIANA).
numbers and types of advanced conventional
CRS-6


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
weapons”:
—Suspends foreign aid for one year;
—Requires U.S. opposition and “no” votes in
international financial institutions for one year;
—Suspends weapons codevelopment and
coproduction agreements for one year;
—Suspends exchange agreements and related
exports pertaining to military and dual-use
technology for one year (unless such activities
contribute to U.S. security); and
—Prohibits the export of USML items for one
year.
Sec. 1605(c)
Nonproliferation
The President may exercise IEEPA authorities,
At the President’s
At the President’s discretion, following IEEPA
excluding instances of “urgent humanitarian
discretion
authorities (see below).
assistance,” toward the foreign country. (See
IEEPA authorities, below.)
IRAN SANCTIONS ACT OF 1996 (ISA 1996)
(P.L. 104-172; 50 U.S.C. 1701 note; as amended; Act sunsets effective December 31, 2016 (Sec. 13(b))
Sec. 5(a), Sec, 6
Nonproliferation
Sec. 5(a) identifies developing Iran’s energy
President imposes, based
The President may waive, case-by-case, for 6
sector as behavior to be investigated and cause
on investigation (Sec.
months and for further 6-12 months
Anti-terrorism
for sanctions:
4(e)). Generally, imposed
depending on circumstances, for a foreign
for a period of 2 years
national if he finds it “vital to the national
—investing in Iran’s petroleum resources;
(Sec. 9(b)).
security interests” and notifies the
—providing to Iran goods, services, technology,
Committees on Finance, Banking, Foreign
President may delay
information, or support relating to production
Relations. Foreign Affairs, Ways and Means,
imposition of sanctions
of refined petroleum products;
Financial Services, 30 days in advance (Sec.
for up to 90 days in order
4(c)).
—trades in, facilitates, or finances Iran’s refined
to initiate consultations
petroleum products;
with foreign government
The President may waive for 12 months if the
of jurisdiction (Sec. 9(a)).
targeted person is subject to a government
—joint ventures with the Government of Iran
cooperating with U.S. in multilateral
to develop refined petroleum resources;
nonproliferation efforts relating to Iran, it is
—supporting Iran’s development of petroleum
vital to national security interests, and he
notifies Congress 30 days in advance.
CRS-7


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
products;
The President may cancel an investigation
—supporting Iran’s development of
(precursor to imposing sanctions) if he
petrochemical products;
determines the person is no longer engaged
in objectionable behavior and has credible
—transporting crude oil from Iran; and
assurances such behavior will not occur in the
—concealing Iran origin of petroleum products
future (Sec. 4(e)).
in the course of transporting such products.
The President may not apply sanctions if
President may choose among the fol owing
transaction:
penalties, and is required to impose at least five
—meets an existing contract requirement;
(Sec. 6):
—is completed by a sole source supplier; or
—deny Export-Import Bank program funds;
—is “essential to the national security under
—deny export licenses;
defense coproduction agreements”;
—prohibit loans from U.S. financial institutions;
—is specifically designated under certain
—prohibit targeted financial institutions being
trade laws;
designated as a primary dealer or a repository
—complies with existing contracts and
of government funds;
pertains to spare parts, component parts,
—deny U.S. government procurement
servicing and maintenance, or information and
contracts;
technology relating to essential U.S. products,
or medicine, medical supplies or humanitarian
—limit or prohibit foreign exchange
items (Sec. 6(f)).
transactions;
The requirement to impose sanctions under
—limit or prohibit transactions with banks
Sec. 5(a) has no force or effect if the
under U.S. jurisdiction;
President determines Iran:
—prohibit transactions related to U.S.-based
—has ceased programs relating to nuclear
property;
weapons, chemical and biological weapons,
ballistic missiles;
—prohibit investments in equity of a targeted
entity;
—is no longer designated as a state supporter
of acts of international terrorism; and
—deny visas to, or expel, any person who holds
a position or controlling interest in a targeted
—“poses no significant threat to United
entity;
States national security, interests, or allies.”
(Sec. 8).
—impose any of the above on a targeted
entity’s principal executive officers; and
President may lift sanctions if he determines
CRS-8


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
—economic restrictions drawing from IEEPA
behavior has changed (Sec. 9(b)(2)).
authorities (see below).
President may waive sanctions if he

determines it is “essential to national security
interests” to do so (Sec. 9(c)).
President may delay imposition of sanctions
expanded by amendments in the
Comprehensive Iran Sanctions,
Accountability, and Divestment Act
(CISADA), relating to development and
export of refined petroleum products, for up
to 180 days, and in additional 180-day
increments, if President certifies objectionable
activities are being curtailed (CISADA, Sec.
102(h)).
State Department Public Notice 8610
of January 22, 2014
(79 F.R. 4522)
(Guidance of January 20, 2014) waives Sec.
5(a)(7) as it applies to National Iranian Oil
Company (NIOC) and the National Iranian
Tanker Company(NITC) for oil trade with
China, India, Japan, South Korea, Taiwan, and
Turkey, with conditions (vital to national
security interests).


Al U.S. government agencies are required to

President may waive contractor certification
certify any prospective contractor as not being
requirement, case-by-case, if he finds it
subject to sanctions under this section (Sec.
“essential to national security interests” to do
6(b)).
so (Sec. 6(b)(5)).
Sec. 5(b), Sec. 6
Nonproliferation
Sec. 5(b) identifies developing Iran’s WMD or
Statutory requirement;
The President may not apply sanctions if:
other military capabilities as cause for sanctions:
generally imposed for a
Anti-terrorism
period of 2 years (Sec.
—in the case of joint venture, is terminated
—exports, transfers, and transshipments of
9(b)).
within 180 days;
military/weapons goods, services, or technology;
and
President may delay
—President determines the government of
imposition of sanctions
jurisdiction did not know person was engaged
—joint ventures relating to uranium mining,
for up to 90 days in order
in activity, or has taken steps to prevent
production, or transportation.
to initiate consultations
recurrence;
CRS-9


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
President may choose among the fol owing
with foreign government
—case-by-case, President determines
penalties, and is required to impose at least five
of jurisdiction (Sec. 9(a)).
approval of activity is “vital to national
(Sec. 6):
security interests of the United States” and
notifies Congress; or
—deny Export-Import Bank program funds;
The President may not apply sanctions if
—deny export licenses;
transaction:
—prohibit loans from U.S. financial institutions;
—meets an existing contract requirement;
—prohibit targeted financial institutions being
—is completed by a sole source supplier; or
designated as a primary dealer or a repository
of government funds;
—is “essential to the national security under
defense coproduction agreements”;
—deny U.S. government procurement
contracts;
—is specifically designated under certain
trade laws;
—limit or prohibit foreign exchange
transactions;
—complies with existing contracts and
pertains to spare parts, component parts,
—limit or prohibit transactions with banks
servicing and maintenance, or information and
under U.S. jurisdiction;
technology relating to essential U.S. products,
—prohibit transactions related to U.S.-based
or medicine, medical supplies or humanitarian
property;
items (Sec. 5(f)).
—prohibit investments in equity of a targeted

entity;

—deny visas to, or expel, any person who holds

a position or controlling interest in a targeted
entity;
President may waive contractor certification
requirement, case-by-case, if he finds it
—impose any of the above on a targeted
“essential to national security interests” to do
entity’s principal executive officers; and
so (Sec. 6(b)(5)).
—economic restrictions drawing from IEEPA
President may lift sanctions if he determines
authorities (see below).
behavior has changed (Sec. 9(b)(2)).
Al U.S. government agencies are required to
President may waive sanctions if he
certify any prospective contractor as not being
determines it is “essential to national security
subject to sanctions under this section (Sec.
interests” to do so (Sec. 9(c)).
6(b)).
CRS-10


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
IRAN, NORTH KOREA, AND SYRIA NONPROLIFERATION ACT (INKSA)
(P.L. 106-178; 50 U.S.C. 1701 note; as amended)
Sec. 3
Nonproliferation
Foreign persons identified by President as having At the President’s
President may choose to not impose
transferred to or acquired from Iran goods,
discretion
sanctions, but must justify to Committees on
services, or technology related to weapons or
Foreign Affairs and Foreign Relations (Sec. 4).
missile proliferation may, at the President’s
discretion, be:
President may choose to not impose
sanctions if he finds:
—denied entering into procurement contracts
with the U.S. government;
—targeted person did not knowingly engage in
objectionable transaction;
—prohibited transactions relating to import
into the United States;
—transaction did not materially contribute to
proliferation;
—prohibited arms sales from the United States
of USML articles and services;
—government of jurisdiction adheres to
relevant nonproliferation regime; or
—denied export licenses for items controlled
under the Export Administration Act of 1979 or
—government of jurisdiction “has imposed
Export Administration Regulations.
meaningful penalties” (Sec. 5(a)).
TRADE SANCTIONS REFORM AND EXPORT ENHANCEMENT ACT OF 2000 (TSRA)
(Title IX of P.L. 106-387 (Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2001); 22 U.S.C. 7201 et seq.; as
amended)
Sec. 906 (22 U.S.C.
Anti-terrorism
Requires export licenses for agricultural
Statutory requirement
No waiver; the executive branch (primarily
7205)
commodities, medicines, medical devices to any
Departments of Commerce, for exportation,
government designated as a state sponsor of
and Treasury for related transactions) may
acts of international terrorism.
issue export licenses limited to a 12-month
duration but there is no limit on the number
or nature of licenses generally.
Sec. 908 (22 U.S.C.
Anti-terrorism
Prohibits U.S. assistance—foreign aid, export
Statutory requirement
President may waive if “it is in the national
7207)
assistance, credits, guarantees—for commercial
security interest of the United States to do
exports to Iran.
so, or for humanitarian reasons.”
CRS-11


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
IRAN NUCLEAR PROLIFERATION PREVENTION ACT OF 2002 (INPPA)
(Subtitle D of title XIII of P.L. 107-228 (Foreign Relations Authorization Act for Fiscal Year 2003))
Sec. 1343(b) (22
Nonproliferation
Requires the U.S. representative to the IAEA to
Discretionary, based on
No waiver; however, “nay” votes are based
U.S.C. 2027(b))
oppose programs that are “inconsistent with
findings of the Secretary
on the Secretary of State’s annual review of
nuclear nonproliferation and safety goals of the
of State
IAEA programs and determinations.
United States.”
CRS-12


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
IRAN FREEDOM SUPPORT ACT (IFSA)
(P.L. 109-293; 50 U.S.C. 1701 note)
Sec. 101
Democracy
Makes permanent the restrictions the President
Statutory requirement
President may terminate the sanctions if he
promotion
imposed under IEEPA/NEA authorities in
notifies Congress 15 days in advance, unless
Executive Order 12957, which:
“exigent circumstances” warrant terminating
General foreign
the restrictions without notice, in which case
policy reasons
—prohibits any U.S. person from entering into a
Congress shal be notified within 3 days after
contract or financing or guaranteeing
termination.
performance under a contract relating to
petroleum resource development in Iran;
and Executive Order 12959, which:
—prohibits any U.S. person from investing in
Iran;
and Executive Order 13059, which:
—prohibits any U.S. person from exporting
where the end-user is Iran or the Government
of Iran;
—prohibits any U.S. person from investing in
Iran;
—prohibits any U.S. person from engaging in
transactions or financing related to Iran-origin
goods or services.
COMPREHENSIVE IRAN SANCTIONS, ACCOUNTABILITY, AND DIVESTMENT ACT OF 2010 (CISADA)
(P.L. 111-195; 22 U.S.C. 8501 et seq.; as amended)
Sec. 103(b)(1) and (2) Nonproliferation
Prohibits most imports into the United States of Statutory requirement
Allows imports, exports, food, medicine, and
(22 U.S.C. 8512)
goods of Iranian origin.
humanitarian aid as covered by IEEPA and
Human rights
TSRA.
Prohibits a U.S. person from exporting most
Anti-terrorism
U.S.-origin goods, services, or technology to
President may allow exports if he determines
Iran.
to do so is in the national interest.

Most of CISADA, including sanctions under
this section, ceases to be effective when
CRS-13


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
President removes Iran’s designation as a
sponsor of acts of international terrorism and
that country has ceased its pursuit of
weapons of mass destruction (WMD) (Sec.
401; 22 U.S.C. 8551).
President may waive if he finds it “in the
national interest” to do so (Sec. 401(b)).
Sec. 103(b)(3) (22
Nonproliferation
Freezes assets of individual, family member, or
President determines
President’s discretion.
U.S.C. 8512)
associates acting on behalf of individual, in
Human rights
compliance with IEEPA authorities.
Most of CISADA, including sanctions under

this section, ceases to be effective when
Anti-terrorism
President removes Iran’s designation as a
sponsor of acts of international terrorism and
that country has ceased its pursuit of WMD
(Sec. 401; 22 U.S.C. 8551).
President may waive if he finds it “in the
national interest” to do so (Sec. 401(b)).
Sec. 104(c) (22 U.S.C. Anti-money
Imposes IEEPA-authorized economic
Statutory requirement
Secretary of the Treasury may waive if he
8513(c))
laundering
restrictions, to be issued by Secretary of the
finds it “necessary to the national interest” to
Treasury in new regulations and prohibits U.S.
do so (subsec. (f)).
Anti-terrorism
banks opening or maintaining correspondent or
(financing)
payable-through accounts for any foreign
Most of CISADA, including sanctions under
this section, ceases to be effective when
Nonproliferation
financial institution that:
President removes Iran’s designation as a
—facilitates Iran’s acquisition of WMD;
sponsor of acts of international terrorism and
that country has ceased its pursuit of WMD
—facilitates Iran’s support of foreign terrorist
(Sec. 401; 22 U.S.C. 8551).
organizations (FTO);
—facilitates activities of persons subject to U.N.
Security Council sanctions;
—engages in money laundering;
—facilitates Iran’s Central Bank or other
financial institution in objectionable activities; or
—facilitates transactions of IRGC or others
under IEEPA sanctions.
CRS-14


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
Sec. 104(c)(4) (22
Anti-money
Subjects National Iranian Oil Company (NIOC)
Requires Secretary of the
Secretary of the Treasury may waive if he
U.S.C. 8513(c)(4))
laundering
and National Iranian Tanker Company (NITC)
Treasury determination
finds it “necessary to the national interest” to
to IEEPA-authorized economic restrictions,
do so (subsec. (f)).
Anti-terrorism
promulgated by the Secretary of the Treasury
(financing)
under Sec. 104(c) (above) if found to be
If the country of primary jurisdiction is
exempted under Sec. 1245, National Defense
Nonproliferation
affiliated with the Iranian Revolutionary Guard
Corps (IRGC).
Authorization Act, 2012 (NDAA’12), that
exemption extends to financial entities

engaged in transactions with NIOC and NITC
(Sec. 104(c)(4)(C)).
Most of CISADA, including sanctions under
this section, ceases to be effective when
President removes Iran’s designation as a
sponsor of acts of international terrorism and
that country has ceased its pursuit of WMD
(Sec. 401; 22 U.S.C. 8551).
Sec. 104A (22 U.S.C.
Anti-money
Expands restriction established in Sec. 104
Requires Secretary of the
Secretary of the Treasury may waive if he
8513A)
laundering
(above) to also apply to any foreign financial
Treasury to issue new
finds it “necessary to the national interest” to
institution that facilitates, participates, or assists
regulations
do so (subsec. (f)).
Anti-terrorism
in activities identified in Sec. 104(c).
(financing)
Most of CISADA, including sanctions under
this section, ceases to be effective when
Nonproliferation
President removes Iran’s designation as a
sponsor of acts of international terrorism and
that country has ceased its pursuit of WMD
(Sec. 401; 22 U.S.C. 8551).
Sec. 105 (22 U.S.C.
Human rights
Imposes sanctions on individuals the President
Statutory requirement of
President may terminate sanctions when he
8514)
identifies as responsible for or complicit in the
the President
determines and certifies that the government
human rights crackdown around the 2009
of Iran has released political prisoners
national election.
detained around the June 2009 election;
ceased related objectionable activities;
Sanctions include visa ineligibility and IEEPA-
investigated related killings, arrests, and
related economic restrictions.
abuses; and made public commitment to
establishing an independent judiciary and
upholding international human rights
standards.
Most of CISADA, including sanctions under
CRS-15


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
this section, ceases to be effective when
President removes Iran’s designation as a
sponsor of acts of international terrorism and
that country has ceased its pursuit of WMD
(Sec. 401; 22 U.S.C. 8551).
President may waive if he finds it “in the
national interest” to do so (Sec. 401(b)).
Sec. 105A (22 U.S.C.
Human rights
Imposes sanctions on any individual the
Statutory requirement of
President may terminate sanctions when he
8514A)
President identifies as providing goods or
the President
determines an individual has taken steps
technology to the government of Iran to
toward stopping objectionable activity, and
facilitate human rights abuses, including
will not reengage.
“sensitive technology.” Includes making such
materials available to the IRGC.
Most of CISADA, including sanctions under
this section, ceases to be effective when
Sanctions include visa ineligibility and IEEPA-
President removes Iran’s designation as a
related economic restrictions.
sponsor of acts of international terrorism and
that country has ceased its pursuit of WMD
(Sec. 401; 22 U.S.C. 8551).
President may waive if he finds it “in the
national interest” to do so (Sec. 401(b)).
Sec. 105B (22 U.S.C.
Human rights
Imposes sanctions on any individual the
Statutory requirement of
Most of CISADA, including sanctions under
8514B)
(freedom of
President identifies as engaging in censorship or
the President
this section, ceases to be effective when
expression and
limiting the freedom of assembly.
President removes Iran’s designation as a
assembly)
sponsor of acts of international terrorism and
Sanctions include visa ineligibility and IEEPA-
that country has ceased its pursuit of WMD
related economic restrictions.
(Sec. 401; 22 U.S.C. 8551).
President may waive if he finds it “in the
national interest” to do so (Sec. 401(b)).
Sec. 105C (22 U.S.C.
Human rights
Imposes sanctions on any individual the
Statutory requirement of
Most of CISADA, including sanctions under
8514C)
(diversion of food
President identifies as diverting food and
the President
this section, ceases to be effective when
and medicine)
medicine from reaching the Iranian people.
President removes Iran’s designation as a
sponsor of acts of international terrorism and
Sanctions include visa ineligibility and IEEPA-
that country has ceased its pursuit of WMD
related economic restrictions.
(Sec. 401; 22 U.S.C. 8551).
President may waive if he finds it “in the
CRS-16


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
national interest” to do so (Sec. 401(b)).
Sec. 106 (22 U.S.C.
Human rights
Prohibits entering into procurement contracts
Statutory requirement of
President may exempt some products defined
8515)
(freedom of
with any individual the President identifies as
the President
in specific trade laws and IEEPA.
expression and
exporting sensitive technology to Iran.
assembly)
Most of CISADA, including sanctions under
Sec. 412, Iran Threat Reduction and Syria
this section, ceases to be effective when
Human Rights Act (ITRSHRA), further defines
President removes Iran’s designation as a
“sensitive technology.”
sponsor of acts of international terrorism and
that country has ceased its pursuit of WMD
(Sec. 401; 22 U.S.C. 8551).
President may waive if he finds it “in the
national interest” to do so (Sec. 401(b)).
Sec. 108 (22 U.S.C.
International
President may issue any regulations to comply
Discretion of the
Discretion of the President.
8516)
obligations
with U.N. Security Council resolutions.
President
Most of CISADA, including sanctions under
this section, ceases to be effective when
President removes Iran’s designation as a
sponsor of acts of international terrorism and
that country has ceased its pursuit of WMD
(Sec. 401; 22 U.S.C. 8551).
Sec. 303 (22 U.S.C.
Export controls
President may identify and designate a country
Discretion of the
President terminates designation—and
8543)
(nonproliferation;
as a “Destination of Division Concern” if he
President
ensuing trade restrictions—on determining
anti-terrorism)
finds it diverts export-controlled goods and
that country “has adequately strengthened
technology to Iran that would materially
the export control system.”
contribute to that state’s development of
WMD, delivery systems, and international
Most of CISADA, including sanctions under
terrorism.
this section, ceases to be effective when
President removes Iran’s designation as a
President may delay or deny export licenses.
sponsor of acts of international terrorism and
that country has ceased its pursuit of WMD
(Sec. 401; 22 U.S.C. 8551).
NATIONAL DEFENSE AUTHORIZATION ACT FOR FISCAL YEAR 2012 (NDAA 2012)
(Sec. 1245 of P.L. 112-81; 22 U.S.C. 8513a; as amended)
Sec. 1245
Anti-money
Designates Iran’s financial sector, including its
Statutory requirement
President may delay imposition of sanctions if
laundering
Central Bank, as a “primary money laundering
government of primary jurisdiction reduces
concern.”
its crude oil purchases from Iran. Renewable
CRS-17


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
—Requires the President to block and prohibit
every 180 days.
all transactions of any Iranian financial institution
President may waive imposition if he finds it
under U.S. jurisdiction.
“in the national security interest of the United
—Requires the President to prohibit opening of
States” to do so.
correspondent and payable-through accounts
Sanctions under this section cease to be
for any institution that conducts transactions for
effective 30 days after President certifies and
the Central Bank of Iran.
removes Iran’s designation as a sponsor of
—Authorizes the President to impose IEEPA-
acts of international terrorism and that
based sanctions.
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785) (Sec. 1245(i)).
State Department Public Notice 8610
of January 22, 2014
(79 F.R. 4522)
(Guidance of January 20, 2014) waives Sec.
1245 for foreign financial institutions under
the primary jurisdiction of China, India, Japan,
South Korea, the authorities on Taiwan, and
Turkey, subject to conditions. Also waived for
“foreign financial institutions under the
primary jurisdiction of Switzerland that are
notified directly in writing by the U.S.
Government, to the extent necessary for
such foreign financial institutions to engage in
financial transactions with the Central Bank of
Iran in connection with the repatriation of
revenues and the establishment of a financial
channel as specifically provided for in the Joint
Plan of Action of November 24, 2013.”
State Department Public Notice 8594
of January 15, 2014
(79 F.R. 2746), the
Secretary of State determined, that as of
November 29, 2013, India, Malaysia, China,
South Korea, Singapore, South Africa, Sri
Lanka, Taiwan, and Turkey are exempted
from restriction for Iran oil trade. Supersedes
a similar determination of June 5, 2013.
Extended for Malaysia, Singapore, and South
CRS-18


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
Africa by Public Notice 8753 of May 27, 2014
(79 F.R. 32011).
State Department Public Notice 8678
of March 25, 2014
(79 F.R. 18382), the
Secretary of State determined, that as of
March 4, 2014, Belgium, the Czech Republic,
France, Germany, Greece, Italy, Netherlands,
Poland, Spain, and the United Kingdom are
exempted from restriction for Iran oil trade.
Extended for these “EU10” by Public Notice
8865 of August 29, 2014 (79 F.R. 54342).
IRAN THREAT REDUCTION AND SYRIA HUMAN RIGHTS ACT OF 2012 (ITRSHRA)
(P.L. 112-158; 22 U.S.C. 8701 et seq.)
Sec. 211 (22 U.S.C.
Nonproliferation
President imposes IEEPA-based sanctions on any Statutory requirement
President may waive imposition if he finds it
8721)
person he determines has engaged in
“vital to the national security interests of the
Anti-terrorism
transactions relating to providing a vessel or
United States” to do so.
insuring a shipping service that materially
contributes to the government of Iran’s
Most of ITR, including sanctions under this
proliferation activities.
section, ceases to be effective when President
removes Iran’s designation as a sponsor of
acts of international terrorism and that
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
Sec. 212 (22 U.S.C.
Nonproliferation
President imposes IEEPA- and Iran Sanctions
Statutory requirement
President may terminate if objectionable
8722)
Act- (ISA) based sanctions (see above) on any
activity has ceased.
Anti-terrorism
person he determines has provided
underwriting services or insurance for NIOC or
Most of ITR, including sanctions under this
NITC.
section, ceases to be effective when President
removes Iran’s designation as a sponsor of
acts of international terrorism and that
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
Sec. 213 (22 U.S.C.
Nonproliferation
President imposes IEEPA- and ISA-based
Statutory requirement
Most of ITR, including sanctions under this
8723)
sanctions (see above) on any person he
section, ceases to be effective when President
CRS-19


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
Anti-terrorism
determines has engaged in transactions relating
removes Iran’s designation as a sponsor of
to Iran’s sovereign debt.
acts of international terrorism and that
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
Sec. 217 (22 U.S.C.
Nonproliferation
Requires President to certify that the Central
Statutory requirement
President may still lift sanctions, but is slowed
8724)
Bank of Iran is not engaging in activities related
in doing so and must certify on new
Anti-terrorism
to WMD or terrorism before he lifts IEEPA-
conditions relating to terrorism and
based sanctions imposed pursuant to E.O.
proliferation.
13599 (see Table 2).
Requires President to certify that sanctions
evaders are engaged in activities related to
WMD or terrorism before he lifts IEEPA-based
sanctions imposed pursuant to E.O. 13608 (see
Table 2).
Sec. 218 (22 U.S.C.
Nonproliferation
Extends IEEPA-based sanctions imposed on
Statutory requirement
Most of ITR, including sanctions under this
8725)
parent companies to their foreign subsidiaries,
section, ceases to be effective when President
Anti-terrorism
to prohibit transactions with the government of
removes Iran’s designation as a sponsor of
Iran.
acts of international terrorism and that
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
Sec. 220(c) (22 U.S.C. Nonproliferation
President may impose IEEPA-based sanctions on At the President’s
President’s discretion.
8726(c))
financial messaging services that facilitate
discretion
Anti-terrorism
transactions for the Central Bank of Iran or
Most of ITR, including sanctions under this
other restricted financial institutions.
section, ceases to be effective when President
removes Iran’s designation as a sponsor of
acts of international terrorism and that
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
Sec. 221 (22 U.S.C.
Nonproliferation
Requires the President to identify senior Iranian
Statutory requirement
President may waive if he finds it “essential to
8727)
government officials involved in proliferation,
the national interests of the United States”
Anti-terrorism
support of terrorism, or human rights
and notifies Congress in advance.
Human rights
violations. Requires the Secretaries of State and
Homeland Security to, respectively, deny
Most of ITR, including sanctions under this
section, ceases to be effective when President
CRS-20


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
identified persons and their family members
removes Iran’s designation as a sponsor of
visas and entry into the United States.
acts of international terrorism and that
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
Sec. 301 (22 U.S.C.
National security
Requires the President to identify members,
Statutory requirement
President may waive if he finds it “vital to the
8741)
agents, and affiliates of the IRGC and impose
national security interests of the United
Nonproliferation
IEEPA-based sanctions. Requires the Secretaries
States to do so.”
of State and Homeland Security to, respectively,
deny identified persons and their family
Most of ITR, including sanctions under this
members visas and entry into the United States.
section, ceases to be effective when President
removes Iran’s designation as a sponsor of
acts of international terrorism and that
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
Sec. 302 (22 U.S.C.
National security
Requires the President to identify those who
Statutory requirement
President may terminate when he determines
8742)
materially engage in support or transactions
objectionable activities have ceased.
Nonproliferation
with the IRGC or related entities subject to
IEEPA-based sanctions. Further requires the
President may waive if activities have ceased
President to impose ISA-based sanctions on and
or if “it is essential to the national security
additional IEEPA-based sanctions on those he
interests of the United States to do so.”
identifies.
President may forego imposing sanctions if
President is not required to publicly identify
similar exception has been made under Sec.
such individual if “doing so would cause damage
104(c) of CISADA (see above).
to the national security of the United States.”
Most of ITR, including sanctions under this
section, ceases to be effective when President
removes Iran’s designation as a sponsor of
acts of international terrorism and that
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
State Department Public Notice 8610
of January 22, 2014
(79 F.R. 4522)
(Guidance of January 20, 2014) waives Sec.
302(e) as it would “cause damage to the
national security of the United States to
CRS-21


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
identify or designate a foreign person” in
connection with transactions by non-U.S.
persons engaged in trade in oil to China,
India, Japan, South Korea, Taiwan, and
Turkey, with conditions.
Sec. 303 (22 U.S.C.
Nonproliferation
President is required to identify any agency of a
Statutory requirement;
President may terminate if objectionable
8743)
foreign country that materially assists or
however, President
activities have ceased, or if “it is essential to
United Nations
engages in transactions with IRGC or any entity
selects specific actions
the national security interests of the United
compliance
subject to U.N. Security Council sanctions.
States to terminate such measures.”
President may cut off most foreign aid, deny
President may waive imposition of any
arms sales and transfers, deny export licenses,
measure if he explains his decision to
require opposition to loans to that foreign
Congress (and justification may be subsequent
country in the international financial institutions,
to action taken).
deny USG financial assistance, or impose other
IEEPA-based sanctions.
Most of ITR, including sanctions under this
section, ceases to be effective when President
removes Iran’s designation as a sponsor of
acts of international terrorism and that
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
Sec. 411 (22 U.S.C.
Human rights
Requires the President to maintain IEEPA-based
Statutory requirement
President’s determination.
8751)
sanctions pursuant to E.O. 13606 (see Table 2)
Nonproliferation
until he certifies Iran has ceased its support of
Anti-terrorism
international terrorism and pursuit of weapons
proliferation, under Sec. 401, CISADA (see
above).
Sec. 501 (22 U.S.C.
Nonproliferation
Requires the Secretaries of State and Homeland
Statutory requirement
Most of ITR, including sanctions under this
8771)
Security to, respectively, deny visas and entry
section, ceases to be effective when President
into the United States to Iranian citizens who
removes Iran’s designation as a sponsor of
seek education in the United States related to
acts of international terrorism and that
energy, nuclear science, or nuclear engineering.
country has ceased its pursuit of WMD (Sec.
401, CISADA; 22 U.S.C. 8551) (Sec. 605; 22
U.S.C. 8785).
CRS-22


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
IRAN FREEDOM AND COUNTER-PROLIFERATION ACT OF 2012 (IFCA)
(Title XII, subtitle D, of National Defense Authorization Act for Fiscal Year 2013; NDAA 2013; P.L. 112-239; 22 U.S.C. 8801 et seq.)
Sec. 1244 (22 U.S.C.
Nonproliferation
Designates entities that operate Iran’s ports,
Statutory requirement
Humanitarian-related transactions are
8803)
and entities in energy, shipping, and shipbuilding,
exempted.
including NITC, IRISL, and NIOC, and their
affiliates, as “entities of proliferation concern.”
President may exempt transactions related to
Afghanistan reconstruction and development,
Requires the President to block transactions
if he determines it in the national interest to
and interests in property under U.S. jurisdiction
do so.
of such entities.
President may exempt application to those
Requires the President to impose ISA-based
countries exempted from NDAA’12
sanctions on any person who knowingly engages
requirements (see above).
in trade related to energy, shipping, or
shipbuilding sectors of Iran.
Some aspects of trade in natural gas are
exempted.
President may waive for 180 days if he finds it
“vital to the national security of the United
States” to do so.
State Department Public Notice 8610
of January 22, 2014
(79 F.R. 4522)
(Guidance of January 20, 2014) waives Sec.
1244(c)(1) for
—Transactions by non-U.S. persons for the
export from Iran of petrochemical products
and associated services, with exceptions;
—Transactions by U.S. or non-U.S. persons
for the supply and installation of spare parts
necessary for the safety of flight for Iranian
civil aviation, with exceptions;
—Transactions by non-U.S. persons for Iran
oil exports to China, India, Japan, South
Korea, Taiwan, and Turkey, with exceptions;
and
—Transactions by non-U.S. persons for the
CRS-23


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
sale, supply or transfer to or from Iran of
precious metals, with exceptions.
State Department Public Notice 8610
of January 22, 2014
(79 F.R. 4522)
(Guidance of January 20, 2014) waives Sec.
1244(d) for
—Transactions by non-U.S. persons in
connection with Iran oil exports to China,
India, Japan, South Korea, Taiwan, and
Turkey, and for insurance and transportation
services, with exceptions.
State Department Public Notice 8632
of February 10, 2014
(79 F.R. 9030) waives
secs. 1244(i), 1245(g), 1246(e), and 1247(f)
for certain transactions related to Islamic
Republic of Iran Broadcasting (IRIB). See also
State Department Public Notice 8855
of August 22, 2014
(79 F.R. 51390).
State Department Public Notice 8809
of July 28, 2014
(79 F.R. 45228) waives Sec.
1244(c), (d), Sec. 1245(a), (c), Sec. 1246, and
Sec. 1247(a) for certain transactions.
Sec. 1245 (22 U.S.C.
Nonproliferation
Requires the President to impose ISA-based
Statutory requirement
President may exempt those he determines
8804)
sanctions on any person who knowingly engages
are exercising “due diligence” to comply with
in trade related to precious metal, or material
restrictions.
used in energy, shipping, or shipbuilding, if
controlled by IRGC or other sanctioned entity.
President may waive for 180 days, and may
renew that waiver in 6-month increments, if
he finds it “vital to the national security of the
United States” to do so.
State Department Public Notice 8610
of January 22, 2014
(79 F.R. 4522)
(Guidance of January 20, 2014) waives Sec.
1245(a)(1)(A), 1245(c), for
—Transactions by non-U.S. persons related
CRS-24


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
to precious metals, with exceptions.
State Department Public Notice 8632
of February 10, 2014
(79 F.R. 9030) waives
secs. 1244(i), 1245(g), 1246(e), and 1247(f)
for certain transactions related to Islamic
Republic of Iran Broadcasting (IRIB). See also
State Department Public Notice 8855
of August 22, 2014
(79 F.R. 51390).
State Department Public Notice 8809
of July 28, 2014
(79 F.R. 45228) waives Sec.
1244(c), (d), Sec. 1245(a), (c), Sec. 1246, and
Sec. 1247(a) for certain transactions.
Sec. 1246 (22 U.S.C.
Nonproliferation
Requires the President to impose ISA-based
Statutory requirement
Humanitarian-related transactions are
8805)
sanctions on any person who knowingly
exempted.
provides underwriting or insurance services to
any sanctioned entity with respect to Iran.
President may exempt those he determines
are exercising “due diligence” to comply with
restrictions.
President may waive for 180 days, and may
renew that waiver in 6-month increments, if
he finds it “vital to the national security of the
United States” to do so.
State Department Public Notice 8610
of January 22, 2014
(79 F.R. 4522)
(Guidance of January 20, 2014) waives Sec.
1246(a) for
—Transactions by non-U.S. persons related
to oil exports to China, India, Japan, South
Korea, Taiwan, and Turkey, with exceptions;
—Transactions by non-U.S. persons in
connection with export of Iran petrochemical
products, with exceptions;
—Transactions by non-U.S. persons in
connection with trade in precious metals,
CRS-25


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
with exceptions;
—Transactions by non-U.S. persons in
connection with Iran’s automotive sector,
with exceptions; and
—Transactions by U.S. and non-U.S. persons
related to civil aviation, with exceptions.
State Department Public Notice 8632
of February 10, 2014
(79 F.R. 9030) waives
secs. 1244(i), 1245(g), 1246(e), and 1247(f)
for certain transactions related to Islamic
Republic of Iran Broadcasting (IRIB). See also
State Department Public Notice 8855
of August 22, 2014
(79 F.R. 51390).
State Department Public Notice 8809
of July 28, 2014
(79 F.R. 45228) waives Sec.
1244(c), (d), Sec. 1245(a), (c), Sec. 1246, and
Sec. 1247(a) for certain transactions.
Sec. 1247 (22 U.S.C.
Nonproliferation
Requires the President to prohibit any
Statutory requirement
Humanitarian-related transactions are
8806)
correspondent or payable-through account by a
exempted.
foreign financial institution that is found to
facilitate a “significant financial transaction” on
President may exempt application to those
behalf of any Iranian Specially Designated
countries exempted from NDAA’12
National (SDN).
requirements (see above).

President may waive for 180 days, and may
renew that waiver in 6-month increments, if
he finds it “vital to the national security of the
United States” to do so.
State Department Public Notice 8610
of January 22, 2014
(79 F.R. 4522)
(Guidance of January 20, 2014) waives Sec.
1247(a) for
—Transactions by foreign financial institutions
related to oil exports to China, India, Japan,
South Korea, Taiwan, and Turkey;
CRS-26


Statutory Basis
Rationale
Restriction
Authority To Impose
Authority To Lift or Waive
—Transactions by foreign financial institutions
related to export of petrochemical products,
with exceptions;
—Transactions of foreign financial institutions
related to trade in precious metals, with
exceptions; and
—Transactions of foreign financial institutions
related to civil aviation, with exceptions.
State Department Public Notice 8632
of February 10, 2014
(79 F.R. 9030) waives
secs. 1244(i), 1245(g), 1246(e), and 1247(f)
for certain transactions related to Islamic
Republic of Iran Broadcasting (IRIB). See also
State Department Public Notice 8855
of August 22, 2014
(79 F.R. 51390).
State Department Public Notice 8809
of July 28, 2014
(79 F.R. 45228) waives Sec.
1244(c), (d), Sec. 1245(a), (c), Sec. 1246, and
Sec. 1247(a) for certain transactions.
Sec. 1248 (22 U.S.C.
Human rights
Requires the President to apply Sec. 105(c),
Statutory requirement
President may waive if he finds it “in the
8807)
CISADA-based sanctions (see above) to the
national interest” to do so (Sec. 401(b),
Islamic Republic of Iran Broadcasting and the
CISADA).
President of that entity, and to add this entity
and individual to the SDN list.
President may terminate sanctions when he
determines and certifies that the government
of Iran has released political prisoners
detained around the June 2009 election;
ceased related objectionable activities;
investigated related killings, arrests, and
abuses; and made public commitment to
establishing an independent judiciary and
upholding international human rights
standards (Sec. 105(d), CISADA).
Notes: AECA = Arms Export Control Act; CISADA = Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010; DNI = Director of National
Intelligence; E.O. = Executive Order; FTO = Foreign Terrorist Organization; IAEA = International Atomic Energy Agency; IEEPA = International Emergency Economic
CRS-27


Powers Act; IFI = International Financial Institution; IFSA = Iran Freedom Support Act; IIANA = Iran-Iraq Arms Non-Proliferation Act of 1992; INA = Immigration and
Nationality Act of 1952; INKSA = Iran, North Korea, Syria Nonproliferation Act; IRGC = Iranian Revolutionary Guard Corps; ISA = Iran Sanctions Act of 1996;
ITRSHRA = Iran Threat Reduction and Syria Human Rights Act of 2012; NDAA = National Defense Authorization Act; NEA = National Emergencies Act; NICO =
Naftiran Intertrade Company; NIOC = National Iranian Oil Company; NITC = National Iranian Tanker Company; SDN = Specially Designated National; TSRA = Trade
Sanctions Reform Act of 2000; UNICEF = U.N. Children’s Fund; UNPA = United Nations Participation Act of 1945; UNSC = United Nations Security Council; USC =
United States Code; USML = United States Munitions List; USTR = U.S. Trade Representative; WMD = Weapons of Mass Destruction.

CRS-28


Table 2. Executive Orders Issued to Meet Statutory Requirements To Impose Economic Sanctions on Iran
Underlying
Executive Order
Statute
Restriction
Authority To Lift or Waive
E.O. 12170
IEEPA / NEA
Declares a national emergency exists relating to 1979 events in
President
(November 14, 1979)
Iran; blocks Iranian government property subject to U.S.
jurisdiction.
Secretary of the Treasury administers.
E.O. 12938
IEEPA / NEA
Declares a national emergency exists relating to the proliferation of President
(November 14, 1994) AECA
weapons of mass destruction and the means of delivery. Succeeds
and replaces similar authorities of 1990 and 1994. Establishes
(also invoked in
export controls, sanctions affecting foreign aid, procurement,
Sec. 3(b)(1),
imports, on proliferators. Establishes sanctions—affecting
INKSA)
foreign aid, IFI support, credits, arms sales, exports, imports,
landing rights—targeting foreign countries that produce or
use chemical or biological weapons.
Secretaries of State, Commerce, Defense, and the Treasury
administer.
E.O. 12957
IEEPA / NEA
Declares a national emergency exists relating to Iran’s proliferation
President
(March 15, 1995)
activities; prohibits persons under U.S. jurisdiction from
Sec. 101(a), IFSA, codifies this EO. The President must notify
entering into certain transactions with respect to Iranian
Congress 15 days in advance of its termination, unless exigent
petroleum resources.
circumstances justify acting first.
Secretaries of the Treasury and State administer.
E.O. 12959
IEEPA / NEA
Expands national emergency set forth in E.O. 12957; prohibits President
(May 6, 1995)
ISDC ‘85
entering into new investment.
Sec. 101(a), IFSA, codifies this EO. The President must notify
Secretaries of the Treasury and State administer.
Congress 15 days in advance of its termination, unless exigent
circumstances justify acting first.
E.O. 13059
IEEPA / NEA
Clarifies steps taken in E.O. 12957 and E.O. 12959; prohibits
President
(August 19, 1997)
ISDC ‘85
most imports from Iran, exports to Iran, new investment,
Sec. 101(a), IFSA, codifies this EO. The President must notify
transactions relating to Iran-origin goods regardless of their
Congress 15 days in advance of its termination, unless exigent
location
circumstances justify acting first.
Secretaries of the Treasury and State administer.
E.O. 13224
IEEPA / NEA
Declares a national emergency exists relating to international
President
(September 23, 2001) UNPA’45
terrorism, in the aftermath of events of September 11, 2001;
blocks property and prohibits transactions with persons who
(also invoked in
commit, threaten to commit, or support terrorism.
CRS-29


Underlying
Executive Order
Statute
Restriction
Authority To Lift or Waive
Sec. 211,
Generates a list of designated individuals who are
ITRSHRA)
incorporated into the Specially Designated Nationals (SDN)
list.
Secretaries of the Treasury, State, Homeland Security, and
the Attorney General administer.
E.O. 13382
IEEPA / NEA
Expands national emergency set forth in E.O. 12938; blocks
President
(June 28, 2005)
(also invoked in
property of WMD proliferators and their supporters.
Guidance of January 20, 2014: “The USG will not impose
Sec. 211,
Secretaries of State, the Treasury, and the Attorney General
blocking sanctions under section 1(a)(iii) of E.O. 13382 ...
ITRSHRA)
administer.
with respect to persons” who facilitate certain activities
related to safety of Iran’s civil aviation industry.
Guidance of January 20, 2014: “The USG will not impose
blocking sanctions under section 1(a)(iii) of E.O. 13382...with
respect to non-U.S. persons” who facilitate export of
petroleum and related products from Iran to China, India,
Japan, South Korea, Taiwan, or Turkey.
E.O. 13438
IEEPA / NEA
Expands national emergency relating to events in Iraq and set
President
(July 17, 2007)
forth in E.O. 13303, May 22, 2003; blocks property of certain
persons who threaten stabilization efforts in Iraq.
Secretaries of the Treasury, State, and Defense administer.
E.O. 13553
IEEPA / NEA
Expands national emergency set forth in E.O. 12957; blocks
President
(September 28, 2010) CISADA
property of certain persons with respect to human rights
abuses by the government of Iran. Generates a list of
designated individuals for whom property under U.S.
jurisdiction is blocked. Imposes sanctions on those who enter
into transactions with designated individuals.
This is the initial implementation of requirements under
CISADA.
Secretaries of the Treasury and State administer.
E.O. 13574
IEEPA / NEA
Expands national emergency set forth in E.O. 12957;
President
(May 23, 2011)
ISA ‘96
implements new sanctions added to ISA. Prohibits U.S.
financial institutions from making loans or credits, or engaging
CISADA
in foreign exchange transactions. Prohibits imports from, and

blocks property of, a sanctioned person.
CRS-30


Underlying
Executive Order
Statute
Restriction
Authority To Lift or Waive
The President, and Secretaries of the Treasury and State,
administer.
E.O. 13590
IEEPA / NEA
Expands national emergency set forth in E.O. 12957; blocks
President
(November 20, 2011)
property of those who trade in goods, services, technology,
or support for Iran’s energy and petrochemical sectors.
Prohibits Ex-Im Bank from entering into transactions with
sanctioned person. Requires Federal Reserve to deny goods
and services. Prohibits U.S. financial institutions from making
most loans or credits.
Secretaries of State, the Treasury, and Commerce, the U.S.
Trade Representative (USTR), Chairman of Federal Reserve
Board, and President of Ex-Im Bank, administer.
E.O. 13599
IEEPA / NEA
Expands national emergency set forth in E.O. 12957; blocks
President
(February 5, 2012)
NDAA ‘12
property of the government of Iran and Iranian financial
Sec. 217, ITRSHRA, requires the President notify Congress 90
institutions, including the Central Bank of Iran.
days in advance of termination of this E.O., and certify a
Secretaries of the Treasury, State, and Energy, and DNI
number of objectionable activities have ceased.
administer.
E.O. 13606
IEEPA / NEA
Expands, in the case of Iran, national emergency set forth in
President
(April 22, 2012)
E.O. 12957; blocks the property and suspends entry into the
Sec. 411, ITRSHRA, requires the President notify Congress 30
United States of persons found to commit human rights
days in advance of termination of this E.O., and certify a
abuses by the governments of Iran and Syria, facilitated misuse number of objectionable activities have ceased pursuant to
of information technology. Generates new list of SDN.
Sec. 401, CISADA.
Secretaries of the Treasury and State administer.
E.O. 13608
IEEPA / NEA
Expands, in the case of Iran, national emergency set forth in
President
(May 1, 2012)
E.O. 12957; prohibits transactions with and suspends entry
Sec. 217, ITRSHRA, requires the President notify Congress 30
into the United States of foreign sanctions evaders. Generates days in advance of termination of this E.O., and certify a
new list of SDN.
number of objectionable activities have ceased pursuant to
Secretaries of the Treasury and State administer.
Sec. 401, CISADA.
E.O. 13622
IEEPA / NEA
Expands national emergency set forth in E.O. 12957;
President
(July 30, 2012)
NDAA ‘12
authorizes sanctions on foreign financial institutions that
Guidance of January 20, 2014: “The USG will not impose
finance activities with NIOC, NICO. Prohibits correspondent
correspondent or payable-through account sanctions under
and payable-through accounts. Prohibits Ex-Im financing,
section 1(a)(i)-(ii) of E.O. 13622 ... with respect to foreign
designation as a primary dealer of U.S. debt instruments,
financial institutions” that facilitate export of petroleum and
access to U.S. financial institutions. Blocks property, denies
CRS-31


Underlying
Executive Order
Statute
Restriction
Authority To Lift or Waive
imports and exports.
related products from Iran to China, India, Japan, South
The President, and Secretaries of the Treasury, State, and
Korea, Taiwan, or Turkey.
Commerce, the USTR, Chairman of Federal Reserve Board,
Guidance of January 20, 2014: “The USG will not impose
and President of Ex-Im Bank, administer.
correspondent or payable-through account sanctions under
section 1(a)(iii) of E.O. 13622...on foreign financial
institutions” that are not otherwise subject to sanctions.
Guidance of January 20, 2014: “The USG will not impose
sanctions under section 2(a)(i) of E.O. 13622...on non-U.S.
persons” who engage in transactions relating to export of
petroleum and related products from Iran to China, India,
Japan, South Korea, Taiwan, or Turkey.
Guidance of January 20, 2014: “The USG will not impose
sanctions under section...2(a)(ii) of E.O. 13622...on non-U.S.
persons not otherwise subject to” the Iran Transactions
Sanctions Regime and engage in petrochemical exports
transactions with specific Iranian entities.
Guidance of January 20, 2014: “The USG will not impose
blocking sanctions under section 5(a) of E.O. 13622...with
respect to persons” who facilitate trade in gold and precious
metals.
Guidance of January 20, 2014: “The USG will not impose
blocking sanctions under section 5(a) of E.O. 13622...with
respect to non-U.S. persons” who facilitate export of
petroleum and related products from Iran to China, India,
Japan, South Korea, Taiwan, or Turkey.
E.O. 13628
IEEPA / NEA
Expands national emergency set forth in E.O. 12957; primarily President
(October 9, 2012)
ISA ‘96
implements ITRSHRA. Further prohibits U.S. financial
institutions from making loans or credits, foreign exchange
CISADA
transactions, and transfers or credits between financial
ITRSHRA
institutions. Blocks property of those who deal in equity or
debt instruments of a sanctioned person. Prohibits imports,
INA
exports. Extends sanctions to other officers of sanctioned
entities. Blocks property affiliated with human rights abusers,
including those who limit freedom of expression. Denies
access to certain financing tools, property, and imports, if one
CRS-32


Underlying
Executive Order
Statute
Restriction
Authority To Lift or Waive
engaged in expansion of Iran’s refined petroleum sector.
Blocks entry into the United States of those who engage in
certain human rights abuses.
The President, and Secretaries of the Treasury, State, and
Commerce, the USTR, Chairman of Federal Reserve Board,
and President of Ex-Im Bank, administer.
E.O. 13645
IEEPA / NEA
Expands national emergency set forth in E.O. 12957; imposes
President
(June 3, 2013)
CISADA
restrictions on foreign financial institutions engaged in
Guidance of January 20, 2014: “The USG will not impose
transactions relating to, or maintaining accounts dominated
IFCA
blocking sanctions under section ... 2(a)(i)-(ii) of E.O. 13645
by, Iran’s currency (rial). Prohibits opening or maintaining
with respect to persons” who engage in various transactions
INA
U.S.-based payable-through correspondent accounts. Blocks
related to petrochemical products.
property under U.S. jurisdiction. Imposes restrictions on
those, including foreign financial institutions, found to be
Guidance of January 20, 2014: “The USG will not impose
materially assisting in any way an Iran-related SDN. Imposes
blocking sanctions under section...2(a)(i)-(i ) of E.O. 13645
restrictions on those found to engage in transactions related
with respect to persons” who facilitate trade in gold and
to Iran’s petroleum or related products. Requires the
precious metals.
Secretary of State to impose restrictions on financing (Federal Guidance of January 20, 2014: “The USG will not impose
Reserve, Ex-Im Bank, commercial banks) on those found to
blocking sanctions under... section 2(a)(i)-(ii) of E.O.
engage in significant transactions related to Iran’s automotive
13645...with respect to persons” who facilitate certain
sector. Blocks property of those found to have engage in
activities related to safety of Iran’s civil aviation industry.
diversion of goods and services intended for the people of
Iran
Guidance of January 20, 2014: “The USG will not impose
blocking sanctions under section. .2(a)-(ii) of E.O. 13645...with
The President, and Secretaries of the Treasury, State,
respect to non-U.S. persons” who facilitate export of
Homeland Security, and Commerce, the USTR, Chairman of
petroleum and related products from Iran to China, India,
Federal Reserve Board, and President of Ex-Im Bank,
Japan, South Korea, Taiwan, or Turkey.
administer.
Guidance of January 20, 2014: “The USG will not impose
correspondent or payable-through account sanctions under
section...3(a)(i) of E.O. 13645...on foreign financial
institutions” that are not otherwise subject to sanctions.
Guidance of January 20, 2014: “The USG will not impose
correspondent or payable-through account sanctions under
section 3(a)(i) of E.O. 13645 with respect to foreign financial
institutions” that facilitate trade in gold and precious metals.
Guidance of January 20, 2014: “The USG will not impose
correspondent or payable-through account sanctions under
CRS-33


Underlying
Executive Order
Statute
Restriction
Authority To Lift or Waive
section 3(a)(i) of E.O. 13645...on foreign financial institutions”
that facilitate certain activities related to safety of Iran’s civil
aviation industry.
Guidance of January 20, 2014: “The USG will not impose
correspondent or payable-through account sanctions under
section ...3(a)(i) of E.O. 13645...with respect to foreign
financial institutions” that facilitate export of petroleum and
related products from Iran to China, India, Japan, South
Korea, Taiwan, or Turkey.
Guidance of January 20, 2014: “The USG will not impose
correspondent or payable-through account sanctions under
section...3(a)(ii) of E.O. 13645...on foreign financial
institutions” that engage in sale, supply, or transfer related to
Iran’s automotive sector.
Guidance of January 20, 2014: “The USG will not impose
sanctions described in section 6 of E.O. 13645” on persons
who engage in sale, supply, or transfer related to Iran’s
automotive sector.
Notes: AECA = Arms Export Control Act; CISADA = Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010; DNI = Director of National
Intelligence; E.O. = Executive Order; IEEPA = International Emergency Economic Powers Act; IFI = International Financial Institution; IFCA = Iran Freedom and Counter-
proliferation Act of 2012; IFSA = Iran Freedom Support Act; INA = Immigration and Nationality Act of 1952; INKSA = Iran, North Korea, Syria Nonproliferation Act;
ISA = Iran Sanctions Act of 1996; ITRSHRA = Iran Threat Reduction and Syria Human Rights Act of 2012; NDAA = National Defense Authorization Act; NEA =
National Emergencies Act; NICO = Naftiran Intertrade Company; NIOC = National Iranian Oil Company; SDN = Special y Designated National; UNPA = United
Nations Participation Act of 1945; USTR = U.S. Trade Representative.

CRS-34

Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions


Author Contact Information
Dianne E. Rennack
Specialist in Foreign Policy Legislation
drennack@crs.loc.gov, 7-7608

Congressional Research Service
35