Iran Sanctions
September 10, 2019
Successive Administrations have used sanctions extensively against Iran to try to change
Iran’s behavior. Sanctions have had a substantial effect on Iran’s economy but little
Kenneth Katzman
observable effect on Iran’s pursuit of core strategic objectives. Iran has provided support
Specialist in Middle
for regional armed factions, developed ballistic missiles, and expanded its conventional
Eastern Affairs
weapons development programs during periods when international sanctions were in

force, when they were suspended, and after U.S. sanctions were reimposed in late 2018.

During 2012-2015, when the global community was relatively united in pressuring Iran, Iran’s economy shrank as
its crude oil exports fell by more than 50%, and Iran had limited ability to utilize its $120 billion in assets held
abroad. Iran accepted the 2015 multilateral nuclear accord (Joint Comprehensive Plan of Action, JCPOA), which
provided Iran broad relief through the waiving of relevant sanctions, revocation of relevant executive orders
(E.O.s), and the lifting of U.N. and EU sanctions. Remaining in place were a general ban on U.S. trade with Iran
and U.S. sanctions on Iran’s support for regional governments and armed factions, its human rights abuses, its
efforts to acquire missile and advanced conventional weapons capabilities, and the Islamic Revolutionary Guard
Corps (IRGC). Under U.N. Security Council Resolution 2231, which enshrined the JCPOA, nonbinding U.N.
restrictions on Iran’s development of nuclear-capable ballistic missiles and a binding ban on its importation or
exportation of arms remain in place for several years.
JCPOA sanctions relief enabled Iran to increase its oil exports to nearly pre-sanctions levels, regain access to
foreign exchange reserve funds and reintegrate into the international financial system, achieve about 7% yearly
economic growth (2016-17), attract foreign investment, and buy new passenger aircraft. The sanctions relief
contributed to Iranian President Hassan Rouhani’s reelection in the May 19, 2017, vote.
Sanctions are at the core of Trump Administration policy to apply “maximum pressure” on Iran, with the stated
purpose of compelling Iran to negotiate a revised JCPOA that takes into account U.S. concerns beyond Iran’s
nuclear program. On May 8, 2018, President Trump announced that the United States would no longer participate
in the JCPOA and U.S. secondary sanctions were reimposed by November 6, 2018. The reinstatement of U.S.
sanctions has driven Iran’s economy into recession as major companies exit the Iranian economy rather than risk
being penalized by the United States. Iran’s oil exports have decreased dramatically, particularly after the
Administration in May 2019 ended sanctions excerptions for the purchase of Iranian oil. In the summer of 2019,
the Administration has sanctioned numerous entities that are supporting Iran’s remaining oil trade. The value of
Iran’s currency has declined sharply, and there has been some unrest.
The European Union and other countries are trying to keep the economic benefits of the JCPOA flowing to Iran in
order to persuade Iran to remain in the accord. In January 2019, the European countries created a trading
mechanism (Special Purpose Vehicle) that presumably can increase trade with Iran by circumventing U.S.
secondary sanctions, and the EU countries are contemplating providing Iran with $15 billion in credits, secured by
future oil deliveries, to fuel that trading mechanism. On May 3, 2019, the Administration ended some waivers for
foreign governments to provide technical assistance to some JCPOA-permitted aspects of Iran’s nuclear program,
but it extended other waivers in August 2019. The economic difficulties and other U.S. pressure measures have
prompted Iran to cease performing some of the nuclear commitments of the JCPOA, and contributed to Iranian
leaders’ apparent decision to attack and interfere with some commercial shipping in the Persian Gulf. But, at least
for now, Iran is refusing to begin talks with the United States on a revised JCPOA.
See also CRS Report R43333, Iran Nuclear Agreement and U.S. Exit, by Paul K. Kerr and Kenneth Katzman; and
CRS Report R43311, Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions, by Dianne E.
Rennack.
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Overview and Objectives
Sanctions have been a significant component of U.S. Iran policy since Iran’s 1979 Islamic
Revolution that toppled the Shah of Iran, a U.S. ally. In the 1980s and 1990s, U.S. sanctions were
intended to try to compel Iran to cease supporting acts of terrorism and to limit Iran’s strategic
power in the Middle East more generally. After the mid-2000s, U.S. and international sanctions
focused largely on ensuring that Iran’s nuclear program is for purely civilian uses. During 2010-
2015, the international community cooperated closely with a U.S.-led and U.N.-authorized
sanctions regime in pursuit of the goal of persuading Iran to agree to limits to its nuclear program.
Still, sanctions against Iran have multiple objectives and address multiple perceived threats from
Iran simultaneously.
This report analyzes U.S. and international sanctions against Iran. CRS has no way to
independently corroborate whether any individual or other entity might be in violation of U.S. or
international sanctions against Iran. The report tracks “implementation” of the various U.S. laws
and executive orders as designations and imposition of sanctions. Some sanctions require the
blocking of U.S.-based property of sanctioned entities. CRS has not obtained information from
the executive branch indicating that such property has been blocked, and it is possible that
sanctioned entities do not have any U.S. assets that could be blocked.
The sections below are grouped by function, in the chronological order in which these themes
have emerged.1
Blocked Iranian Property and Assets
Post-JCPOA Status: Iranian Assets Still Frozen, but Some Issues Resolved
U.S. sanctions on Iran were first imposed during the U.S.-Iran hostage crisis of 1979-1981, in the
form of executive orders issued by President Jimmy Carter blocking nearly all Iranian assets held
in the United States. These included E.O. 12170 of November 14, 1979, blocking all Iranian
government property in the United States, and E.O 12205 (April 7, 1980) and E.O. 12211 (April
17, 1980) banning virtually all U.S. trade with Iran. The latter two orders were issued just prior to
the failed April 24-25, 1980, U.S. effort to rescue the U.S. Embassy hostages held by Iran.
President Jimmy Carter also broke diplomatic relations with Iran on April 7, 1980. The trade-
related orders (12205 and 12211) were revoked by Executive Order 12282 of January 19, 1981,
following the “Algiers Accords” that resolved the U.S.-Iran hostage crisis. Iranian assets still
frozen are analyzed below.
U.S.-Iran Claims Tribunal
The Accords established a “U.S.-Iran Claims Tribunal” at the Hague that continues to arbitrate
cases resulting from the 1980 break in relations and freezing of some of Iran’s assets. All of the
4,700 private U.S. claims against Iran were resolved in the first 20 years of the Tribunal, resulting
in $2.5 billion in awards to U.S. nationals and firms.

1 On November 13, 2012, the Administration published in the Federal Register (Volume 77, Number 219) “Policy
Guidance” explaining how it implements many of the sanctions, and in particular defining what products and chemicals
constitute “petroleum,” “petroleum products,” and “petrochemical products” that are used in the laws and executive
orders discussed below. See http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-27642.pdf.
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The major government-to-government cases involved Iranian claims for compensation for
hundreds of foreign military sales (FMS) cases that were halted in concert with the rift in U.S.-
Iran relations when the Shah’s government fell in 1979. In 1991, the George H. W. Bush
Administration paid $278 million from the Treasury Department Judgment Fund to settle FMS
cases involving weapons Iran had received but which were in the United States undergoing repair
and impounded when the Shah fell.
On January 17, 2016, (the day after the JCPOA took effect), the United States announced it had
settled with Iran for FMS cases involving weaponry the Shah was paying for but that was not
completed and delivered to Iran when the Shah fell. The Shah’s government had deposited its
payments into a DOD-managed “Iran FMS Trust Fund,” and, after 1990, the Fund had a balance
of about $400 million. In 1990, $200 million was paid from the Fund to Iran to settle some FMS
cases. Under the 2016 settlement, the United States sent Iran the $400 million balance in the
Fund, plus $1.3 billion in accrued interest, paid from the Department of the Treasury’s “Judgment
Fund.” In order not to violate U.S. regulations barring direct U.S. dollar transfers to Iranian
banks, the funds were remitted to Iran in late January and early February 2016 in foreign hard
currency from the central banks of the Netherlands and of Switzerland. Some remaining claims
involving the FMS program with Iran remain under arbitration at the Tribunal.
Other Iranian Assets Frozen
Iranian assets in the United States are blocked under several provisions, including Executive
Order 13599 of February 2010. The United States did not unblock any of these assets as a
consequence of the JCPOA.
 About $1.9 billion in blocked Iranian assets are bonds belonging to Iran’s Central
Bank, frozen in a Citibank account in New York belonging to Clearstream, a
Luxembourg-based securities firm, in 2008. The funds were blocked on the
grounds that Clearstream had improperly allowed those funds to access the U.S.
financial system. Another $1.67 billion in principal and interest payments on that
account were moved to Luxembourg and are not blocked.
 About $50 million of Iran’s assets frozen in the United States consists of Iranian
diplomatic property and accounts, including the former Iranian embassy in
Washington, DC, and 10 other properties in several states, and related accounts.2
 Among other frozen Iranian assets are real estate holdings of the Assa Company,
a UK-chartered entity, which allegedly was maintaining the interests of Iran’s
Bank Melli in a 36-story office building in New York City and several other
properties around the United States (in Texas, California, Virginia, Maryland, and
other parts of New York City). An Iranian foundation, the Alavi Foundation,
allegedly is an investor in the properties. The U.S. Attorney for the Southern
District of New York blocked these properties in 2009. The Department of the
Treasury report avoids valuing real estate holdings, but public sources assess
these blocked real estate assets at nearly $1 billion. In June 2017, litigation won
the U.S. government control over the New York City office building.
Use of Iranian Assets to Compensate U.S. Victims of Iranian Terrorism
There are a total of about $46 billion in court awards that have been made to victims of Iranian
terrorism. These include the families of the 241 U.S. soldiers killed in the October 23, 1983,

2 http://www.treasury.gov/resource-center/sanctions/Documents/tar2010.pdf.
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bombing of the U.S. Marine barracks in Beirut. U.S. funds equivalent to the $400 million balance
in the DOD account (see above) have been used to pay a small portion of these judgments. The
Algiers Accords apparently precluded compensation for the 52 U.S. diplomats held hostage by
Iran from November 1979 until January 1981. The FY2016 Consolidated Appropriation (Section
404 of P.L. 114-113) set up a mechanism for paying damages to the U.S. embassy hostages and
other victims of state-sponsored terrorism using settlement payments paid by various banks for
concealing Iran-related transactions, and proceeds from other Iranian frozen assets.
In April 2016, the U.S. Supreme Court determined the Central Bank assets, discussed above,
could be used to pay the terrorism judgments, and the proceeds from the sale of the frozen real
estate assets mentioned above will likely be distributed to victims of Iranian terrorism as well.3
On the other hand, in March 2018, the U.S. Supreme Court ruled that U.S. victims of an Iran-
sponsored terrorist attack could not seize a collection of Persian antiquities on loan to a
University of Chicago museum to satisfy a court judgment against Iran.
Other past financial disputes include the errant U.S. shoot-down on July 3, 1988, of an Iranian
Airbus passenger jet (Iran Air flight 655), for which the United States paid Iran $61.8 million in
compensation ($300,000 per wage-earning victim, $150,000 per non-wage earner) for the 248
Iranians killed. The United States did not compensate Iran for the airplane itself, although
officials involved in the negotiations told CRS in November 2012 that the United States later
arranged to provide a substitute used aircraft to Iran.
For more detail on the use of Iranian assets to compensate victims of Iranian terrorism, see CRS
Report RL31258, Suits Against Terrorist States by Victims of Terrorism, by Jennifer K. Elsea and
CRS Legal Sidebar LSB10104, It Belongs in a Museum: Sovereign Immunity Shields Iranian
Antiquities Even When It Does Not Protect Iran, by Stephen P. Mulligan.
Executive Order 13599 Impounding Iran-Owned Assets
Post-JCPOA Status: Still in Effect
Executive Order 13599, issued February 5, 2012, directs the blocking of U.S.-based assets of
entities determined to be “owned or controlled by the Iranian government.” The order was issued
to implement Section 1245 of the FY2012 National Defense Authorization Act (P.L. 112-81) that
imposed secondary U.S. sanctions on Iran’s Central Bank. The order requires that any U.S.-based
assets of the Central Bank of Iran, or of any Iranian government-controlled entity, be blocked by
U.S. banks. The order goes beyond the regulations issued pursuant to the 1995 imposition of the
U.S. trade ban with Iran, in which U.S. banks are required to refuse such transactions but to return
funds to Iran. Even before the issuance of the rder, and in order to implement the ban on U.S.
trade with Iran (see below) successive Administrations had designated many entities as “owned or
controlled by the Government of Iran.”
Numerous designations have been made under Executive Order 13599, including the June 4,
2013, naming of 38 entities (mostly oil, petrochemical, and investment companies) that are
components of an Iranian entity called the “Execution of Imam Khomeini’s Order” (EIKO).4

3 “U.S. Court Reverses Record Forfeiture Order over Iran Assets.” Associated Press. July 21, 2016.
4 http://global.factiva.com/hp/printsavews.aspx?pp=Print&hc=Publication; and Department of Treasury announcement
of June 4, 2013.
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EIKO was characterized by the Department of the Treasury as an Iranian leadership entity that
controls “massive off-the-books investments.”
Implementation of the U.S. JCPOA Withdrawal. To implement the JCPOA, many 13599-
designated entities specified in the JCPOA (Attachment 3) were “delisted” from U.S. secondary
sanctions (no longer considered “Specially Designated Nationals,” SDNs), and referred to as
“designees blocked solely pursuant to E.O 13599.”5 That characterization permitted foreign
entities to conduct transactions with the listed entities without U.S. sanctions penalty but
continued to bar U.S. persons (or foreign entities owned or controlled by a U.S. person) from
conducting transactions with these entities. In concert with the U.S. withdrawal from the JCPOA,
virtually all of the 13599-designated entities that were delisted as SDNs were relisted as SDNs on
November 5, 2018.6
Civilian Nuclear Entity Exception. The Atomic Energy Organization of Iran (AEOI), and 23 of its
subsidiaries, were relisted under E.O. 13599 but they were not relisted as entities subject to
secondary sanctions (SDNs) under E.O. 13382. This listing decision was made in order to
facilitate continued IAEA and EU and other country engagement with Iran’s civilian nuclear
program under the JCPOA.7 The May 2019 ending of some waivers for nuclear technical
assistance to Iran modified this stance somewhat (see subhead on waivers and exceptions under
the JCPOA, below).
Sanctions for Iran’s Support for Armed Factions and
Terrorist Groups
Most of the U.S.-Iran hostage crisis sanctions were lifted upon release of the hostages in 1981.
The United States began imposing sanctions against Iran again in the mid-1980s for its support
for regional groups committing acts of terrorism. The Secretary of State designated Iran a “state
sponsor of terrorism” on January 23, 1984, following the October 23, 1983, bombing of the U.S.
Marine barracks in Lebanon by elements that established Lebanese Hezbollah. This designation
triggers substantial sanctions on any nation so designated.
None of the laws or executive orders in this section were waived or revoked to implement the
JCPOA. No entities discussed in this section were “delisted” from sanctions under the JCPOA.
Sanctions Triggered by Terrorism List Designation
The U.S. naming of Iran as a “state sponsor of terrorism”—commonly referred to as Iran’s
inclusion on the U.S. “terrorism list”—triggers several sanctions. The designation is made under
the authority of Section 6(j) of the Export Administration Act of 1979 (P.L. 96-72, as amended),
sanctioning countries determined to have provided repeated support for acts of international
terrorism. The sanctions triggered by Iran’s state sponsor of terrorism designation are as follows:
 Restrictions on sales of U.S. dual use items. The restriction—a presumption of
denial of any license applications to sell dual use items to Iran—is required by
the Export Administration Act, as continued by executive orders under the
authority of the International Emergency Economic Powers Act, IEEPA. The

5 https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20181105_names.aspx.
6 For a full list of entities designated under E.O. 13599, go to the following link: https://www.treasury.gov/ofac/
downloads/13599/13599list.pdf.
7 U.S. diplomatic “non-paper” provided to CRS.
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restrictions are enforced through Export Administration Regulations (EARs)
administered by the Bureau of Industry and Security (BIS) of the Commerce
Department.
 Ban on direct U.S. financial assistance and arms sales to Iran. Section 620A of
the Foreign Assistance Act, FAA (P.L. 87-95) and Section 40 of the Arms Export
Control Act (P.L. 95-92, as amended), respectively, bar any U.S. foreign
assistance to terrorism list countries. Included in the definition of foreign
assistance are U.S. government loans, credits, credit guarantees, and Ex-Im Bank
loan guarantees. Successive foreign aid appropriations laws since the late 1980s
have banned direct assistance to Iran, and with no waiver provisions. The
FY2012 foreign operations appropriation (Section 7041(c)(2) of P.L. 112-74)
banned the Ex-Im Bank from using funds appropriated in that act to finance any
entity sanctioned under the Iran Sanctions Act. The foreign aid provisions of the
FY2019 Consolidated Appropriation (Section 7041) made that provision
effective for FY2019.
 Requirement to oppose multilateral lending. U.S. officials are required to vote
against multilateral lending to any terrorism list country by Section 1621 of the
International Financial Institutions Act (P.L. 95-118, as amended [added by
Section 327 of the Anti-Terrorism and Effective Death Penalty Act of 1996 (P.L.
104-132)]). Waiver authority is provided.
 Withholding of U.S. foreign assistance to countries that assist or sell arms to
terrorism list countries. Under Sections 620G and 620H of the Foreign
Assistance Act, as added by the Anti-Terrorism and Effective Death Penalty Act
(Sections 325 and 326 of P.L. 104-132), the President is required to withhold
foreign aid from any country that aids or sells arms to a terrorism list country.
Waiver authority is provided. Section 321 of that act makes it a crime for a U.S.
person to conduct financial transactions with terrorism list governments.
 Withholding of U.S. Aid to Organizations That Assist Iran. 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. For example, if an international organization spends 3% of its
budget for programs in Iran, then the United States is required to withhold 3% of
its contribution to that international organization. No waiver is provided for.
Exception for U.S. Humanitarian Aid
The terrorism list designation, and other U.S. sanctions laws barring assistance to Iran, do not bar
U.S. disaster aid. The United States donated $125,000, through relief agencies, to help victims of
two earthquakes in Iran (February and May 1997); $350,000 worth of aid to the victims of a June
22, 2002, earthquake; and $5.7 million in assistance for victims of the December 2003 earthquake
in Bam, Iran, which killed 40,000. The U.S. military flew 68,000 kilograms of supplies to Bam.

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Requirements for Removal from Terrorism List
Terminating the sanctions triggered by Iran’s terrorism list designation would require Iran’s removal from the
terrorism list. The Arms Export Control Act spells out two different requirements for a President to remove a
country from the list, depending on whether the country’s regime has changed.
If the country’s regime has changed: the President can remove a country from the list immediately by certifying that
regime change in a report to Congress.
If the country’s regime has not changed: the President must report to Congress 45 days in advance of the effective
date of removal. The President must certify that (1) the country has not supported international terrorism within
the preceding six months, and (2) the country has provided assurances it will not do so in the future. In this latter
circumstance, Congress has the opportunity to block the removal by enacting a joint resolution to that effect. The
President has the option of vetoing the joint resolution, and blocking the removal would require a veto override.
Sanctions on States “Not Cooperating” Against Terrorism
Section 330 of the Anti-Terrorism and Effective Death Penalty Act (P.L. 104-132) added a
Section 40A to the Arms Export Control Act that prohibits the sale or licensing of U.S. defense
articles and services to any country designated (by each May 15) as “not cooperating fully with
U.S. anti-terrorism efforts.” The President can waive the provision upon determination that a
defense sale to a designated country is “important to the national interests” of the United States.
Every May since the enactment of this law, Iran has been designated as a country that is “not fully
cooperating” with U.S. antiterrorism efforts. However, the effect of the designation is largely
mooted by the many other authorities that prohibit U.S. defense sales to Iran.
Executive Order 13224 Sanctioning Terrorism-Supporting Entities
Executive Order 13324 (September 23, 2001) mandates the freezing of the U.S.-based assets of
and a ban on U.S. transactions with entities determined by the Administration to be supporting
international terrorism. This order was issued two weeks after the September 11, 2001, attacks on
the United States, 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, initially targeting Al Qaeda.
Use of the Order to Target Iranian Arms Exports
E.O. 13224 is not specific to Iran and does not explicitly target Iranian arms exports to
movements, governments, or groups in the Middle East region. However, successive
Administrations have used the order—and the orders discussed immediately below—to sanction
such Iranian activity by designating persons or entities that are involved in the delivery or receipt
of such weapons shipments. Some persons and entities that have been sanctioned for such activity
have been cited for supporting groups such as the Afghan Taliban organization and the Houthi
rebels in Yemen, which are not named as terrorist groups by the United States.
Application of CAATSA to the Revolutionary Guard
Section 105 of the Countering America’s Adversaries through Sanctions Act (CAATSA, P.L. 115-
44, signed on August 2, 2017), mandates the imposition of E.O. 13324 penalties on the Islamic
Revolutionary Guard Corps (IRGC) and its officials, agents, and affiliates by October 30, 2017
(90 days after enactment). The IRGC was named as a terrorism-supporting entity under E.O
13224 within that deadline. The Treasury Department made the designation of the IRGC as a
terrorism-supporting entity under that E.O. on October 13, 2017.
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Implementation
No entities designated under E.O. 13224 were delisted to implement the JCPOA. Numerous Iran-
related entities, including members of Iran-allied organizations such as Lebanese Hezbollah and
Iraqi Shia militias, have been designated under the order since JCPOA implementation, as shown
in the tables at the end of this report.
Foreign Terrorist Organization Designations
Sanctions similar to those of E.O. 13224 are imposed on Iranian and Iran-linked entities through
the State Department authority under Section 219 of the Immigration and Nationality Act
(8.U.S.C. 1189) to designate an entity as a Foreign Terrorist Organization (FTO). In addition to
the sanctions of E.O. 13224, any U.S. person (or person under U.S. jurisdiction) who “knowingly
provides material support or resources to an FTO, or attempts or conspires to do so” is subject to
fine or up to 20 years in prison. A bank that commits such a violation is subject to fines.
Implementation: The following organizations have been designated as FTOs for acts of terrorism
on behalf of Iran or are organizations assessed as funded and supported by Iran:
 Islamic Revolutionary Guard Corps (IRGC). Designated April 8, 2019. See
CRS Insight IN11093, Iran’s Revolutionary Guard Named a Terrorist
Organization, by Kenneth Katzman. On April 22, 2019, the State Department
issued guidelines for implementing the IRGC FTO designation, indicating that it
would not penalize routine diplomatic or humanitarian-related dealings with the
IRGC by U.S. partner countries or nongovernmental entities.8
 Lebanese Hezbollah
 Kata’ib Hezbollah. Iran-backed Iraqi Shi’a militia.
 Hamas. Sunni, Islamist Palestinian organization that essentially controls the
Gaza Strip.
 Palestine Islamic Jihad. Small Sunni Islamist Palestinian militant group
 Al Aqsa Martyr’s Brigade. Secular Palestinian militant group.
 Popular Front for the Liberation of Palestine-General Command (PFLP-
GC). Leftwing secular Palestinian group based mainly in Syria.
 Al Ashtar Brigades. Bahrain militant opposition group
Other Sanctions on Iran’s “Malign” Regional Activities
Some sanctions have been imposed to try to curtail Iran’s destabilizing influence in the region.
Executive Order 13438 on Threats to Iraq’s Stability
 Issued on July 7, 2007, the order blocks U.S.-based property of persons who are
determined by the Administration to “have committed, or pose a significant risk
of committing” acts of violence that threaten the peace and stability of Iraq, or
undermine efforts to promote economic reconstruction or political reform in Iraq.
The order extends to persons designated as materially assisting such designees.
The order was clearly directed at Iran for its provision of arms or funds to Shiite
militias there. Persons sanctioned under the order include IRGC-Qods Force

8 “Exclusive: U.S. Carves out Exceptions for Foreigners Dealing with Revolutionary Guards.” Reuters, April 21, 2019.
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officers, Iraqi Shiite militia-linked figures, and other entities. Some of these
sanctioned entities worked to defeat the Islamic State in Iraq and are in
prominent roles in Iraq’s parliament and political structure.
Executive Order 13572 on Repression of the Syrian People.
 Issued on April 29, 2011, the order blocks the U.S.-based property of persons
determined to be responsible for human rights abuses and repression of the
Syrian people. The IRGC-Qods Force (IRGC-QF), IRGC-QF commanders, and
others are sanctioned under this order.
The Hizballah International Financing Prevention Act (P.L. 114-102) and
Hizballah International Financing Prevention Amendments Act of 2018 (S.
1595, P.L. 115-272).
 The latter Act was signed by President Trump on October 23, 2018—the 25th
anniversary of the Marine barracks bombing in Beirut. The original law, modeled
on the 2010 Comprehensive Iran Sanctions, Accountability, and Divestment Act
(“CISADA,” see below), excludes from the U.S. financial system any bank that
conducts transactions with Hezbollah or its affiliates or partners. The more recent
law expands the authority of the original law by authorizing the blocking of U.S.-
based property of and U.S. transactions with any “agency or instrumentality of a
foreign state” that conducts joint operations with or provides financing or arms to
Lebanese Hezbollah. These latter provisions clearly refer to Iran, but are largely
redundant with other sanctions on Iran.
Ban on U.S. Trade and Investment with Iran
Status: Trade ban eased for JCPOA, but back in full effect on August 6, 2018
In 1995, the Clinton Administration expanded U.S. sanctions against Iran by issuing Executive
Order 12959 (May 6, 1995) banning U.S. trade with and investment in Iran. The order was issued
under the authority primarily of the International Emergency Economic Powers Act (IEEPA, 50
U.S.C. 1701 et seq.),9 which gives the President wide powers to regulate commerce with a foreign
country when a ”state of emergency” is declared in relations with that country. E.O. 12959
superseded Executive Order 12957 (March 15, 1995) barring U.S. investment in Iran’s energy
sector, which accompanied President Clinton’s declaration of a “state of emergency” with respect
to Iran. Subsequently, E.O 13059 (August 19, 1997) added a prohibition on U.S. companies’
knowingly exporting goods to a third country for incorporation into products destined for Iran.
Each March since 1995, the U.S. Administration has renewed the “state of emergency” with
respect to Iran. IEEPA gives the President the authority to alter regulations to license transactions
with Iran—regulations enumerated in Section 560 of the Code of Federal Regulations (Iranian
Transactions Regulations, ITRs).

9 The executive order was issued not only under the authority of IEEPA but also the National Emergencies Act (50
U.S.C. 1601 et seq.; §505 of the International Security and Development Cooperation Act of 1985 (22 U.S.C. 2349aa-
9) and §301 of Title 3, United States Code.
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Section 103 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
(CISADA, P.L. 111-195) codified the trade ban and reinstated the full ban on imports that had
earlier been relaxed by April 2000 regulations. That relaxation allowed importation into the
United States of Iranian nuts, fruit products (such as pomegranate juice), carpets, and caviar. U.S.
imports from Iran after that time were negligible.10 Section 101 of the Iran Freedom Support Act
(P.L. 109-293) separately codified the ban on U.S. investment in Iran, but gives the President the
authority to terminate this sanction with presidential notification to Congress of such decision 15
days in advance (or 3 days in advance if there are “exigent circumstances”).
JCPOA-Related Easing and Reversal
In accordance with the JCPOA, the ITRs were relaxed to allow U.S. importation of the Iranian
luxury goods discussed above (carpets, caviar, nuts, etc.), but not to permit general U.S.-Iran
trade. U.S. regulations were also altered to permit the sale of commercial aircraft to Iranian
airlines that are not designated for sanctions. The modifications were made in the Departments of
State and of the Treasury guidance issued on Implementation Day and since.11 In concert with the
May 8, 2018, U.S. withdrawal from the JCPOA, the easing of the regulations to allow for
importation of Iranian carpets and other luxury goods was reversed on August 6, 2018.
What U.S.-Iran Trade Is Allowed or Prohibited?
The following provisions apply to the U.S. trade ban on Iran as specified in regulations (Iran
Transaction Regulations, ITRs) written pursuant to the executive orders and laws discussed above
and enumerated in regulations administered by the Office of Foreign Assets Control (OFAC) of
the Department of the Treasury.
 Oil Transactions. All U.S. transactions with Iran in energy products are banned.
The 1995 trade ban (E.O. 12959) expanded a 1987 ban on imports from Iran that
was imposed by Executive Order 12613 of October 29, 1987. The earlier import
ban, authorized by Section 505 of the International Security and Development
Cooperation Act of 1985 (22 U.S.C. 2349aa-9), barred the importation of Iranian
oil into the United States but did not ban the trading of Iranian oil overseas. The
1995 ban prohibits that activity explicitly, but provides for U.S. companies to
apply for licenses to conduct “swaps” of Caspian Sea oil with Iran. These swaps
have been prohibited in practice; a Mobil Corporation application to do so was
denied in April 1999, and no applications have been submitted since. The ITRs
do not ban the importation, from foreign refiners, of gasoline or other energy
products in which Iranian oil is mixed with oil from other producers. The product
of a refinery in any country is considered to be a product of the country where
that refinery is located, even if some Iran-origin crude oil is present.
 Transshipment and Brokering. The ITRs prohibit U.S. transshipment of
prohibited goods across Iran, and ban any activities by U.S. persons to broker
commercial transactions involving Iran.

10 Imports were mainly of artwork for exhibitions around the United States, which are counted as imports even though
the works return to Iran after the exhibitions conclude.
11 The text of the guidance is at https://www.treasury.gov/resource-center/sanctions/Programs/Documents/
implement_guide_jcpoa.pdf.
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 Iranian Luxury Goods. Pursuant to the JCPOA, Iranian luxury goods, such as
carpets and caviar, could be imported into the United States after January 2016.
This prohibition went back into effect on August 6, 2018 (90-day wind-down).
 Shipping Insurance. Obtaining shipping insurance is crucial to Iran’s expansion
of its oil and other exports. A pool of 13 major insurance organizations, called the
International Group of P & I Clubs, dominates the shipping insurance industry
and is based in New York. The U.S. presence of this pool renders it subject to the
U.S. trade ban, which complicated Iran’s ability to obtain reinsurance for Iran’s
shipping after Implementation Day. On January 16, 2017, the Obama
Administration issued waivers of Sections 212 and 213 of the ITRSHRA to allow
numerous such insurers to give Iranian ships insurance.12 However, this waiver
ended on August 6, 2018 (90-day wind-down).
 Civilian Airline Sales. The ITRs have always permitted the licensing of goods
related to the safe operation of civilian aircraft for sale to Iran (§560.528 of Title
31, C.F.R.), and spare parts sales have been licensed periodically. However, from
June 2011 until Implementation Day, Iran’s largest state-owned airline, Iran Air,
was sanctioned under Executive Order 13382 (see below), rendering licensing of
parts or repairs for that airline impermissible. Several other Iranian airlines were
sanctioned under that order and Executive Order 13224. In accordance with the
JCPOA, the United States relaxed restrictions on to allow for the sale to Iran of
finished commercial aircraft, including to Iran Air, which was “delisted” from
sanctions.13 A March 2016 general license allowed for U.S. aircraft and parts
suppliers to negotiate sales with Iranian airlines that are not sanctioned, and
Boeing and Airbus subsequently concluded major sales to Iran Air. In
conjunction with the U.S. withdrawal from the JCPOA, preexisting licensing
restrictions went back into effect on August 6, 2018, and the Boeing and Airbus
licenses to sell aircraft to Iran were revoked. Sales of some aircraft spare parts
(“dual use items”) to Iran also require a waiver of the relevant provision of the
Iran-Iraq Arms Non-Proliferation Act, discussed below. In April 2019, OFAC
granted a license for Franco-Italian aircraft maker ATR to supply spare parts
(with U.S. content) to the five new ATR aircraft delivered to Iran in 2018.14
 Personal Communications, Remittances, and Publishing. The ITRs permit
personal communications (phone calls, emails) between the United States and
Iran, personal remittances to Iran, and Americans to engage in publishing
activities with entities in Iran (and Cuba and Sudan).
 Information Technology Equipment. CISADA exempts from the U.S. ban on
exports to Iran information technology to support personal communications
among the Iranian people and goods for supporting democracy in Iran. In May

12 Shipping insurers granted the waiver include Assuranceforeningen Skuld, Skuld Mutual Protection and Indemnity
Association, Ltd. (Bermuda), Gard P and I Ltd. (Bermuda), Assuranceforeningen Gard, the Britannia Steam Ship
Insurance Association Limited, The North of England Protecting and Indemnity Association Ltd., the Shipowners’
Mutual Protection and Indemnity Association (Luxembourg), the Standard Club Ltd., the Standard Club Europe Ltd.,
The Standard Club Asia, the Steamship Mutual Underwriting Association Ltd. (Bermuda), the Swedish Club, United
Kingdom Mutual Steam Ship Assurance Association Ltd. (Bermuda), United Kingdom Mutual Steam Ship Association
Ltd. (Europe), and the West of England Ship Owners Mutual Insurance Association (Luxembourg).
13 Reuters, February 21, 2014; “Exclusive: Boeing Says Gets U.S. License to Sell Spare Parts to Iran,” Reuters, April 4,
2014.
14 Tasnim news agency. August 14, 2019.
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2013, OFAC issued a general license for the exportation to Iran of goods (such as
cell phones) and services, on a fee basis, that enhance the ability of the Iranian
people to access communication technology.
 Food and Medical Exports. Since April 1999, sales to Iran by U.S. firms of food
and medical products have been permitted, subject to OFAC stipulations. In
October 2012, OFAC permitted the sale to Iran of specified medical products,
such as scalpels, prosthetics, canes, burn dressings, and other products, that could
be sold to Iran under “general license” (no specific license application required).
This list of general license items list was expanded in 2013 and 201615 to include
more sophisticated medical diagnostic machines and other medical equipment.
Licenses for exports of medical products not on the general license list are
routinely expedited for sale to Iran, according to OFAC. The regulations have a
specific definition of “food” that can be licensed for sale to Iran, which excludes
alcohol, cigarettes, gum, or fertilizer.16
 Humanitarian and Related Services. Donations by U.S. residents directly to
Iranians (such as packages of food, toys, clothes, etc.) are not prohibited, but
donations through relief organizations broadly require those organizations’
obtaining a specific OFAC license. On September 10, 2013, the Department of
the Treasury eliminated licensing requirements for relief organizations to: (1)
provide to Iran services for health projects, disaster relief, wildlife conservation;
(2) to conduct human rights projects there; or (3) undertake activities related to
sports matches and events. The amended policy also allowed importation from
Iran of services related to sporting activities, including sponsorship of players,
coaching, referees, and training. In some cases, such as the earthquake in Bam in
2003 and the earthquake in northwestern Iran in August 2012, OFAC has issued
blanket temporary general licensing for relief organizations to work in Iran.
 Payment Methods, Trade Financing, and Financing Guarantees. U.S. importers
are allowed to pay Iranian exporters, but the payment cannot go directly to
Iranian banks, and must instead pass through third-country banks. In accordance
with the ITRs’ provisions that transactions that are incidental to an approved
transaction are allowed, financing (“letter of credit”) for approved transactions
are normally approved, but the financing must not come from an Iranian bank.
Title IX of the Trade Sanctions Reform and Export Enhancement Act of 2000
(P.L. 106-387) bans the use of official credit guarantees (such as the Ex-Im Bank)
for food and medical sales to Iran and other countries on the U.S. terrorism list,
except Cuba, although allowing for a presidential waiver to permit such credit
guarantees. The Ex-Im Bank is prohibited from guaranteeing any loans to Iran
because of Iran’s continued inclusion on the terrorism list, and the JCPOA did
not commit the United States to provide credit guarantees for Iran.
Application to Foreign Subsidiaries of U.S. Firms
The ITRs do not ban subsidiaries of U.S. firms from dealing with Iran, as long as the subsidiary is
not “controlled” by the parent company. Most foreign subsidiaries are legally considered foreign
persons subject to the laws of the country in which the subsidiaries are incorporated. Section 218
of the Iran Threat Reduction and Syrian Human Rights Act (ITRSHRA, P.L. 112-158) holds

15 https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20161222.aspx?platform=hootsuite.
16 https://www.treasury.gov/resource-center/sanctions/Programs/Documents/gl_food_exports.pdf.
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“controlled” foreign subsidiaries of U.S. companies to the same standards as U.S. parent firms,
defining a controlled subsidiary as (1) one that is more than 50% owned by the U.S. parent; (2)
one in which the parent firm holds a majority on the Board of Directors of the subsidiary; or (3)
one in which the parent firm directs the operations of the subsidiary. There is no waiver provision.
JCPOA Regulations and Reversal. To implement the JCPOA, the United States licensed
“controlled” foreign subsidiaries to conduct transactions with Iran that are permissible under
JCPOA (almost all forms of civilian trade). The Obama Administration asserted that the President
has authority under IEEPA to license transactions with Iran, the ITRSHRA notwithstanding. This
was implemented with the Treasury Department’s issuance of “General License H: Authorizing
Certain Transactions Relating to Foreign Entities Owned or Controlled by a United States
Person.”17 With the Trump Administration reimposition of sanctions, the licensing policy
(“Statement of Licensing Policy,” SLP) returned to pre-JCPOA status on November 5, 2018.
Trade Ban Easing and Termination
Termination: Section 401 of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
(CISADA, P.L. 111-195) provides for the President to terminate the trade ban if the Administration certifies to
Congress that Iran no longer satisfies the requirements to be designated as a state sponsor of terrorism and that
Iran has ceased pursuing and has dismantled its nuclear, biological, and chemical weapons and ballistic missiles and
related launch technology. Alternatively, the trade ban provision in CISADA could be repealed by congressional
action.
Waiver Authority: Section 103(b)(vi) of CISADA allows the President to license exports to Iran if he
determines that doing so is in the national interest of the United States. There is no similar provision in CISADA
to ease the ban on U.S. imports from Iran. The State and Treasury Department guidance issued on
Implementation Day asserts that the statement of licensing policy fulfills the requirements of Section 103 of
CISADA.
Sanctions on Iran’s Energy Sector
Status: Energy sanctions waived for JCPOA, back in effect November 5, 2018
In 1996, Congress and the executive branch began a long process of pressuring Iran’s vital energy
sector in order to deny Iran the financial resources to support terrorist organizations and other
armed factions or to further its nuclear and WMD programs. Iran’s oil sector is as old as the
petroleum industry itself (early 20th century), and Iran’s onshore oil fields are in need of
substantial investment. Iran has 136.3 billion barrels of proven oil reserves, the third largest after
Saudi Arabia and Canada. Iran has large natural gas resources (940 trillion cubic feet), exceeded
only by Russia. However, Iran’s gas export sector is still emerging—most of Iran’s gas is injected
into its oil fields to boost their production. The energy sector still generates about 20% of Iran’s
GDP and as much as 30% of government revenue.
The Iran Sanctions Act
This sections includes sanctions triggers under the Act that were added by laws enacted
subsequent to the original version.
The Iran Sanctions Act (ISA) has been a pivotal component of U.S. sanctions against Iran’s
energy sector. Since its enactment in 1996, ISA’s provisions have been expanded and extended to
other Iranian industries. ISA sought to thwart Iran’s 1995 opening of the sector to foreign

17 https://www.treasury.gov/resource-center/sanctions/Programs/Documents/implement_guide_jcpoa.pdf.
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investment in late 1995 through a “buy-back” program in which foreign firms gradually recoup
their investments as oil and gas is produced. It was first enacted as the Iran and Libya Sanctions
Act (ILSA, P.L. 104-172, signed on August 5, 1996) but was later retitled the Iran Sanctions Act
after it terminated with respect to Libya in 2006. ISA was the first major “extra-territorial
sanction” on Iran—a sanction that authorizes U.S. penalties against third country firms.
Key Sanctions “Triggers” Under ISA
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. The
triggers, as added by amendments over time, are detailed below:
Trigger 1 (Original Trigger): “Investment” To Develop Iran’s Oil and Gas Fields
The core trigger of ISA when first enacted was a requirement that the President sanction
companies (entities, persons) that make an “investment”18 of more than $20 million19 in one year
in Iran’s energy sector.20 The definition of “investment” in ISA (§14 [9]) includes not only equity
and royalty arrangements but any contract that includes “responsibility for the development of
petroleum resources” of Iran. The definition includes additions to existing investment (added by
P.L. 107-24) and pipelines to or through Iran and contracts to lead the construction, upgrading, or
expansions of energy projects (added by CISADA).
Trigger 2: Sales of WMD and Related Technologies, Advanced Conventional
Weaponry, and Participation in Uranium Mining Ventures
This provision of ISA was not waived under the JCPOA.
The Iran Freedom Support Act (P.L. 109-293, signed September 30, 2006) added Section 5(b)(1)
of ISA, subjecting to ISA sanctions firms or persons determined to have sold to Iran (1)
“chemical, biological, or nuclear weapons or related technologies” or (2) “destabilizing numbers
and types” of advanced conventional weapons. Sanctions can be applied if the exporter knew (or
had cause to know) that the end-user of the item was Iran. The definitions do not specifically
include ballistic or cruise missiles, but those weapons could be considered “related technologies”
or, potentially, a “destabilizing number and type” of advanced conventional weapon.
The Iran Threat Reduction and Syria Human Rights Act (ITRSHRA, P.L. 112-158, signed August
10, 2012) created Section 5(b)(2) of ISA subjecting to sanctions entities determined by the
Administration to participate in a joint venture with Iran relating to the mining, production, or
transportation of uranium.
Implementation: No ISA sanctions have been imposed on any entities under these provisions.

18 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.
19 Under §4(d) of the original act, for Iran, the threshold dropped to $20 million, from $40 million, one year after
enactment, when U.S. allies did not join a multilateral sanctions regime against Iran. P.L. 111-195 explicitly sets the
threshold investment level at $20 million. For Libya, the threshold was $40 million, and transactions subject to
sanctions included export to Libya of technology banned by Pan Am 103-related Security Council Resolutions 748
(March 31, 1992) and 883 (November 11, 1993).
20 The original ISA definition of energy sector included oil and natural gas, and CISADA added to that definition
liquefied natural gas (LNG), oil or LNG tankers, and products to make or transport pipelines that transport oil or LNG.
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Trigger 3: Sales of Gasoline to Iran
Section 102(a) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
(CISADA, P.L. 111-195, signed July 1, 2010) amended Section 5 of ISA to exploit Iran’s
dependency on imported gasoline (40% dependency at that time). It followed legislation such as
P.L. 111-85 that prohibited the use of U.S. funds to fill the Strategic Petroleum Reserve with
products from firms that sell gasoline to Iran; and P.L. 111-117 that denied Ex-Im Bank credits to
any firm that sold gasoline or related equipment to Iran. The section subjects the following to
sanctions:
 Sales to Iran of over $1 million worth (or $5 million in a one year period) of
gasoline and related aviation and other fuels. (Fuel oil, a petroleum by-product, is
not included in the definition of refined petroleum.)
 Sales to Iran of equipment or services (same dollar threshold as above) which
would help Iran make or import gasoline. Examples include equipment and
services for Iran’s oil refineries or port operations.
Trigger 4: Provision of Equipment or Services for Oil, Gas, and
Petrochemicals Production
Section 201 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHA, P.L.
112-158, signed August 10, 2012) codified an Executive Order, 13590 (November 21, 2011), by
adding Section 5(a)(5 and 6) to ISA sanctioning firms that
 provide to Iran $1 million or more (or $5 million in a one-year period) worth of
goods or services that Iran could use to maintain or enhance its oil and gas sector.
This subjects to sanctions, for example, transactions with Iran by global oil
services firms and the sale to Iran of energy industry equipment such as drills,
pumps, vacuums, oil rigs, and like equipment.
 provide to Iran $250,000 (or $1 million in a one year period) worth of goods or
services that Iran could use to maintain or expand its production of petrochemical
products.21 This provision was not altered by the JPA.
Trigger 5: Transporting Iranian Crude Oil
Section 201 of the ITRSHRA amends ISA by sanctioning entities the Administration determines
 owned a vessel that was used to transport Iranian crude oil. The section also
authorizes but does not require the President, subject to regulations, to prohibit a
ship from putting to port in the United States for two years, if it is owned by a
person sanctioned under this provision (adds Section 5[a][7] to ISA). This
sanction does not apply in cases of transporting oil to countries that have
received exemptions under P.L. 112-81 (discussed below).
 participated in a joint oil and gas development venture with Iran, outside Iran, if
that venture was established after January 1, 2002. The effective date exempts
energy ventures in the Caspian Sea, such as the Shah Deniz oil field there (adds
Section 5[a][4] to ISA).

21 A definition of chemicals and products considered “petrochemical products” is found in a Policy Guidance
statement. See Federal Register, November 13, 2012, http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-
27642.pdf.
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Iran Threat Reduction and Syria Human Rights Act (ITRSHRA): ISA Sanctions
for insuring Iranian oil entities, purchasing Iranian bonds, or engaging in
transactions with the IRGC
Separate provisions of the ITRSHR Act—which do not amend ISA—require the application of
ISA sanctions (5 out of the 12 sanctions on the ISA sanctions menu) on any entity that
 provides insurance or reinsurance for the National Iranian Oil Company (NIOC)
or the National Iranian Tanker Company (NITC) (Section 212).
 purchases or facilitates the issuance of sovereign debt of the government of Iran,
including Iranian government bonds (Section 213). This sanction went back into
effect on August 6, 2018 (90-day wind-down period).
 assists or engages in a significant transaction with the IRGC or any of its
sanctioned entities or affiliates. (Section 302). This section of ITRSHRA was not
waived to implement the JCPOA.
Implementation. Section 312 of ITRSHRA required an Administration determination, within 45
days of enactment (by September 24, 2012) whether NIOC and NITC are IRGC agents or
affiliates. The determination would subject financial transactions with NIOC and NITC to
sanctions under CISADA (prohibition on opening U.S.-based accounts). On September 24, 2012,
the Department of the Treasury determined that NIOC and NITC are affiliates of the IRGC. On
November 8, 2012, the Department of the Treasury named NIOC as a proliferation entity under
Executive Order 13382—a designation that, in accordance with Section 104 of CISADA, bars
any foreign bank determined to have dealt directly with NIOC (including with a NIOC bank
account in a foreign country) from opening or maintaining a U.S.-based account.
Sanctions on dealings with NIOC and NITC were waived in accordance with the interim nuclear
deal and the JCPOA, and designations of these entities under Executive Order 13382 were
rescinded in accordance with the JCPOA. These entities were “relisted” again on November 5,
2018.
Executive Order 13622/13846: Sanctions on the Purchase of Iranian Crude Oil
and Petrochemical Products, and Dealings in Iranian Bank Notes
Status: Revoked (by E.O. 13716) but was put back into effect by E.O. 13846 of August 6, 2018
Executive Order 13622 (July 30, 2012) imposed specified sanctions on the ISA sanctions menu,
and bars banks from the U.S. financial system, for the following activities (E.O. 13622 did not
amend ISA itself):
 the purchase of oil, other petroleum, or petrochemical products from Iran.22 The
sanction was reinstated by E.O. 13846, and took effect on November 7, 2018.
 transactions with the National Iranian Oil Company (NIOC) or Naftiran
Intertrade Company (NICO) (180-day wind-down period).

22 A definition of what chemicals and products are considered “petroleum products” for the purposes of the order are in
the policy guidance issued November 13, 2012, http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-27642.pdf.
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E.O. 13622 also blocked U.S.-based property of entities determined to have
 assisted or provided goods or services to NIOC, NICO, the Central Bank of
Iran. This sanction was reinstated by E.O. 13846, effective as of November
7, 2018.
 assisted the government of Iran in the purchase of U.S. bank notes or
precious metals, precious stones, or jewels. (The provision for precious
stones or jewels was added to this order by E.O. 16345 below.). This sanction
was reinstated by E.O. 13846, effective as of August 7, 2018.
E.O. 13622 sanctions do not apply if the parent country of the entity has received an oil
importation exception under Section 1245 of P.L. 112-81, discussed below. An exception also is
provided for projects that bring gas from Azerbaijan to Europe and Turkey, if such project was
initiated prior to the issuance of the order.
Mandate and Time Frame to Investigate ISA Violations
In the original version of ISA, there was no firm requirement, and no time limit, for the
Administration to investigate potential violations and determine that a firm has violated ISA’s
provisions. The Iran Freedom Support Act (P.L. 109-293, signed September 30, 2006) added a
provision calling for, but not requiring, a 180-day time limit for a violation determination.23
CISADA (Section 102[g][5]) mandated that the Administration begin an investigation of potential
ISA violations when there is “credible information” about a potential violation, and made
mandatory the 180-day time limit for a determination of violation.
The Iran Threat Reduction and Syria Human Rights Act (P.L. 112-158) defines the “credible
information” needed to begin an investigation of a violation to include a corporate announcement
or corporate filing to its shareholders that it has undertaken transactions with Iran that are
potentially sanctionable under ISA. It also says the President may (not mandatory) use as credible
information reports from the Government Accountability Office and the Congressional Research
Service. In addition, Section 219 of ITRSHRA requires that an investigation of an ISA violation
begin if a company reports in its filings to the Securities and Exchange Commission (SEC) that it
has knowingly engaged in activities that would violate ISA (or Section 104 of CISADA or
transactions with entities designated under E.O 13224 or 13382, see below).
ISA Sanctions Menu
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. The Iran Freedom Support Act added three new possible sanctions and required the
imposition of at least three out of the nine against violators. CISADA added three more sanctions to the ISA
menu and required imposition of at least 5 out of the 12 sanctions. Executive Orders 13590 and 13622 provide for
exactly the same penalties as those in ISA. The 12 available sanctions against the sanctioned entity, from which the
Secretary of State or the Treasury can select, are as follows:
1. denial of Export-Import Bank loans, credits, or credit guarantees for U.S. exports to the sanctioned entity
(original ISA)
2. denial of licenses for the U.S. export of military or militarily useful technology to the entity (original ISA)
3. denial of U.S. bank loans exceeding $10 million in one year to the entity (original ISA)
4. if the entity is a financial institution, a prohibition on its service as a primary dealer in U.S. government bonds;
and/or a prohibition on its serving as a repository for U.S. government funds (each counts as one sanction)

23 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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(original ISA)
5. prohibition on U.S. government procurement from the entity (original ISA)
6. prohibitions in transactions in foreign exchange by the entity (added by CISADA)
7. prohibition on any credit or payments between the entity and any U.S. financial institution (added by CISADA)
8. prohibition of the sanctioned entity from acquiring, holding, using, or trading any U.S.-based property which the
sanctioned entity has a (financial) interest in (added by CISADA)
9. restriction on imports from the sanctioned entity, in accordance with the International Emergency Economic
Powers Act (IEEPA; 50 U.S.C. 1701) (original ISA)
10. a ban on a U.S. person from investing in or purchasing significant amounts of equity or debt instruments of a
sanctioned person (added by ITRSHRA)
11. exclusion from the United States of corporate officers or controlling shareholders of a sanctioned firm (added
by ITRSHRA)
12. imposition of any of the ISA sanctions on principal offices of a sanctioned firm (added by ITRSHRA).
Mandatory Sanction: Prohibition on Contracts with the U.S. Government CISADA (§102[b]) added a requirement
in ISA that companies, as a condition of obtaining a U.S. government contract, certify to the relevant U.S.
government agency that the firm—and any companies it owns or controls—are not violating ISA. Regulations to
implement this requirement were issued on September 29, 2010.
Executive Order 13574 of May 23, 2011 and E.O. 13628 of October 9, 2012, specify which sanctions
are to be imposed. E.O. 13574 stipulated that, when an entity is sanctioned under Section 5 of ISA, the
penalties to be imposed are numbers 3, 6, 7, 8, and 9, above. E.O. 13628 updated that specification to also include
ISA sanctions numbers 11 and 12. The orders also clarify that it is the responsibility of the Department of the
Treasury to implement those ISA sanctions that involve the financial sectors. E.O. 13574 and 13628 were revoked
by E.O. 13716 on Implementation Day, in accordance with the JCPOA. They were reinstated, and superseded, by E.O.
13846 of August 6, 2018, which mandated that, when ISA sanctions are to be imposed, that the sanctions include
ISA sanctions numbers 3,6,7,8,9,10, and 12.
Oversight
Several mechanisms for Congress to oversee whether the Administration is investigating ISA
violations were added by ITRSHRA. Section 223 of that law required a Government
Accountability Office report, within 120 days of enactment, and another such report a year later,
on companies that have undertaken specified activities with Iran that might constitute violations
of ISA. Section 224 amended a reporting requirement in Section 110(b) of CISADA by requiring
an Administration report to Congress every 180 days on investment in Iran’s energy sector, joint
ventures with Iran, and estimates of Iran’s imports and exports of petroleum products. The GAO
reports have been issued; there is no information available on whether the required
Administration reports have been issued as well.
Interpretations of ISA and Related Laws
The sections below provide information on how some key ISA provisions have been interpreted
and implemented.
Application to Energy Pipelines
ISA’s definition of “investment” that is subject to sanctions has been consistently interpreted by
successive Administrations to include construction of energy pipelines to or through Iran. Such
pipelines are deemed to help Iran develop its petroleum (oil and natural gas) sector. This
interpretation was reinforced by amendments to ISA in CISADA, which specifically included in
the definition of petroleum resources “products used to construct or maintain pipelines used to
transport oil or liquefied natural gas.” In March 2012, then-Secretary of State Clinton made clear
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that the Obama Administration interprets the provision to be applicable from the beginning of
pipeline construction.24
Application to Crude Oil Purchases/Shipments
ISA does not sanction purchasing crude oil from Iran, but other laws, such as the Iran Freedom
and Counterproliferation Act (IFCA, discussed below) and executive orders, do. No U.S. sanction
requires any country or person to actually seize, intercept, inspect on the high seas, or impound
any Iranian ship suspected of carrying oil or other cargo subject to sanctions.
However, as discussed further elsewhere in this paper, as of August 2019, the Trump
Administration has begun using various terrorism-related provisions to some Iranian oil
shipments. The Administration has argued that the shipments were organized by and for the
benefit of Iran’s Islamic Revolutionary Guard Corps (IRGC). On September 4, 2019, the Treasury
Department’s Office of Foreign Assets Control (OFAC) updated its sanctions guidance to state
that “bunkering services” (port operational support) for Iranian oil shipments could subject firms
and individuals involved in such support to U.S. sanctions.
Application to Purchases from Iran of Natural Gas
ISA and other laws, such as IFCA, exclude from sanction purchases of natural gas from Iran or
natural gas transactions with Iran. However: construction of gas pipelines involving Iran is
subject to ISA sanctions.
Exception for Shah Deniz and other Gas Export Projects
The effective dates of U.S. sanctions laws and orders exclude long-standing joint natural gas
projects that involve some Iranian firms—particularly the Shah Deniz natural gas field and
related pipelines in the Caspian Sea. These projects involve a consortium in which Iran’s Naftiran
Intertrade Company (NICO) holds a passive 10% share, and includes BP, Azerbaijan’s natural gas
firm SOCAR, Russia’s Lukoil, and other firms. NICO was sanctioned under ISA and other
provisions (until JCPOA Implementation Day), but an OFAC factsheet of November 28, 2012,
stated that the Shah Deniz consortium, as a whole, is not determined to be “a person owned or
controlled by” the government of Iran and transactions with the consortium are permissible.
Application to Iranian Liquefied Natural Gas Development
The original version of ISA did not apply to the development by Iran of a liquefied natural gas
(LNG) export capability. 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. CISADA specifically
included LNG in the ISA definition of petroleum resources and therefore made subject to
sanctions LNG investment in Iran, supply of LNG tankers to Iran, and construction of pipelines
linking to Iran.
Application to Private Financing but Not Official Credit Guarantee Agencies
The definitions of investment and other activity that can be sanctioned under ISA include
financing for investment in Iran’s energy sector, or for sales of gasoline and refinery-related

24 http://dawn.com/2012/03/01/tough-us-warning-on-iran-gas-pipeline/.
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equipment and services. Therefore, banks and other financial institutions that assist energy
investment and refining and gasoline procurement activities could be sanctioned under ISA.
However, the definitions of financial institutions are interpreted not to apply to official credit
guarantee agencies—such as France’s COFACE and Germany’s Hermes. These credit guarantee
agencies are arms of their parent governments, and ISA does not provide for sanctioning
governments or their agencies.
Implementation of Energy-Related Iran Sanctions
Entities sanctioned under the executive orders or laws cited in this section are listed in the tables
at the end of this report. As noted, some of the orders cited provide for blocking U.S.-based assets
of the entities designated for sanctions. OFAC has not announced the blocking of any U.S.-based
property of the sanctioned entities, likely indicating that those entities sanctioned do not have a
presence in the United States.
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ISA Waiver, Exemptions, and Sunset Provisions
The President can waive ISA sanctions in several ways—general, country-specific, or company-specific.
General Waiver. Under Section 4(c)(1)(a), the President can waive (for six months at a time) the requirement to
investigate violations every six (6) months. To implement the JCPOA, this waiver was exercised by the Obama
Administration (the latest on January 18, 2017), and was last renewed by the Trump Administration on January 12,
2018.
Country-Specific Waiver. Under Section 4(c)(1)(B), the President can waive ISA sanctions (for 12 months at a time)
of all companies whose governments are determined to be “closely cooperating with the United States in
multilateral efforts to prevent Iran from” acquiring WMD or acquiring advanced conventional weapons. The
President must also certify that the waiver is vital to the national security interests of the United States.
Company-Specific Waiver. Under Section 9(c), the President can waive ISA sanctions (for one year at a time) on any
company for which the President determines that the waiver is “essential to the national security interests of the
United States.” This waiver was used in 1998 to avoid penalizing Total, Gazprom, and Petronas for an Iran
investment.
Once ISA snaps back into effect, some governments reportedly might seek the country-specific or country-specific
waivers to avoid penalties on their companies that invested in Iran while U.S. sanctions were waived.
ISA (§5[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 is not required to prevent procurement of
essential spare parts or component parts.
“Special Rule” Exempting Firms That End Their Business with Iran
Under a provision added by CISADA (§102[g][5]), ISA provides a means—a so-called “special rule”—for firms to
avoid ISA sanctions by pledging to verifiably end their business with Iran and such business with Iran in the future.
Under the special rule, which has been invoked on several occasions, as discussed below, the Administration is not
required to impose sanctions against a firm that makes such pledges. However, firms are allowed several years, in
some cases, to wind down existing business in Iran, in part because the buy-back program used by Iran pays
energy firms back their investment over time, making it highly costly for them to suddenly end operations in Iran.
Administration Termination Process and Requirements
The Administration can immediately terminate all ISA provisions if the Administration certifies that Iran:
(1) has ceased its efforts to acquire WMD; (2) has been removed from the U.S. list of state sponsors of terrorism;
and (3) no longer “poses a significant threat” to U.S. national security and U.S. allies.25
This termination provision, and the sunset provision discussed below, does not apply to those laws that apply ISA
sanctions without specifically amending ISA. The executive orders and laws that apply ISA sanctions to specified
violators but without amending ISA itself can be revoked by a superseding executive order or congressional action
that amends or repeals the provisions involved.
Sunset and Other Expiration Provisions
ISA was scheduled to sunset on December 31, 2016, as provided for by CISADA. This followed prior sunset
extensions to December 31, 2011 (by P.L. 109-293); December 31, 2006 (P.L. 107-24, August 3, 2001); and
August 5, 2001 (original law). In December 2016, P.L. 114-277 extended the law, as is, until December 31, 2026.
P.L. 107-24 also required an Administration report on ISA’s effectiveness within 24 to 30 months of enactment,
with the report to include an administration recommendation whether ISA be repealed. That report was
submitted to Congress in January 2004, and did not recommend that ISA be repealed.

25 This termination requirement added by P.L. 109-293 formally removed Libya from the act. Application of the act to
Libya terminated on April 23, 2004, with a determination that Libya had fulfilled U.N. requirements.
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Iran Oil Export Reduction Sanctions: Section 1245 of the FY2012
NDAA Sanctioning Transactions with Iran’s Central Bank
Status: Back into effect November 5, 2018, and exceptions ended
In 2011, Congress sought to reduce Iran’s exportation of oil by imposing sanctions on the
mechanisms that importers use to pay Iran for oil. The Obama Administration asserted that such
legislation could lead to a rise in oil prices and harm U.S. relations with Iran’s oil customers, and
President Obama, in his signing statement on the bill, indicated he would implement the provision
so as not to damage U.S. relations with partner countries.
The law imposed penalties on transactions with Iran’s Central Bank. Section 1245 of the FY2012
National Defense Authorization Act (NDAA, P.L. 112-81, signed on December 31, 2011):
 Requires the President to prevent a foreign bank from opening an account in the
United States—or impose strict limitations on existing U.S. accounts—if that
bank is determined to have conducted a “significant financial transaction” with
Iran’s Central Bank or with any sanctioned Iranian bank.
 The provision applies to a foreign central bank only if the transaction with Iran’s
Central Bank is to pay for oil purchases.
 Significant Reduction Exception (SRE): The law provides incentive for Iran’s oil
buyers to cut purchases of Iranian oil by providing for an exception (exemption)
for the banks of any country determined to have “significantly reduced” its
purchases of oil from Iran. The SRE exception is reviewed every 180 days and,
to maintain the exception, countries are required to reduce their oil buys from
Iran, relative to the previous 180-day period. (ITRSHRA amended Section 1245
such that any country that completely ceased purchasing oil from Iran entirely
would retain an exception.) The law lacks a precise definition of “significant
reduction” of oil purchases, but the Obama Administration adopted a standard set
in a January 2012 letter by several Senators to then-Treasury Secretary Geithner
setting that definition at an 18% purchase reduction based on total paid for the
Iranian oil (not just volume reduction).26 The banks of countries that are given
an SRE may continue to conduct any transactions with the Central Bank
(not just for oil) or with any sanctioned Iranian bank.
 Sanctions on transactions for oil apply only if the President certifies to Congress
every 90 days, based on a report by the Energy Information Administration, that
the oil market is adequately supplied, and, an Administration determination every
180 days that there is a sufficient supply of oil worldwide to permit countries to
reduce purchases from Iran. The required EIA reports and Administration
determinations have been issued at the prescribed intervals, even during the
period when the law was in a state of waiver.
 Humanitarian Exception. Paragraph (2) of Section 1245 exempts transactions
with Iran’s Central Bank that are for “the sale of agricultural commodities, food,
medicine, or medical devices to Iran” from sanctions.

26 Text of letter from Senators Mark Kirk and Robert Menendez to Secretary Geithner, January 19, 2012.
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Implementation/SREs Issued and Ended
The Obama Administration used the FY2012 NDAA to pressure Iran without causing economic
difficulty to U.S. allies, other Iran policy partners, or the global oil market. The table below on
major Iranian oil customers indicates cuts made by major customers compared to 2011.
 In March 20, 2012, Japan received an SRE.
 In September 2012, following a July 2012 EU Iran oil embargo, 10 EU countries
(Belgium, Czech Republic, France, Germany, Greece, Italy, the Netherlands,
Poland, Spain, and Britain) received the SRE because they ended purchases
pursuant to the EU Iran oil purchase embargo of July 1, 2012. Seventeen EU
countries were not granted the SRE because they were not buying Iran’s oil and
could not “significantly reduce” buys from Iran.
 In December 2012, the following countries/jurisdictions received the SRE:
China, India, Malaysia, South Africa, South Korea, Singapore, Sri Lanka, Turkey,
and Taiwan.
Reactivation on November 5, 2018, and Exceptions Granted then Ended
The January 2016 waivers issued to implement the JCPOA suspended the requirement for a
country to cut oil purchases from Iran in order to maintain their exceptions, and Iran’s historic oil
customers quickly resumed buying Iranian oil. The provision went back into effect on November
5, 2018.27 On June 26, 2018, a senior State Department official, in a background briefing, stated
that department officials, in meetings with officials of countries that import Iranian oil, were
urging these countries to cease buying Iranian oil entirely, but Administration officials later
indicated that requests for exceptions would be evaluated based on the ease of substituting for
Iranian oil, country-specific needs, and the need for global oil market stability.
 On November 5, 2018, the following eight countries received the first SRE grants
available under reimposed U.S. sanctions,: China, India, Italy, Greece, Japan,
South Korea, Taiwan, and Turkey. The SREs expired on May 2, 2019.
 On April 22, 2019, the State Department announced that no more SREs would be
granted after their expiration at 12:00 AM on May 2, 2019.28 The Administration
indicated that the global oil market is well supplied enough to permit the
decision, which is intended to “apply maximum pressure on the Iranian regime
until its leaders change their destructive behavior, respect the rights of the Iranian
people, and return to the negotiating table.” The announcement indicated that
U.S. officials have had discussions with Saudi Arabia and the UAE to ensure that
the global oil market remains well supplied. Iran’s oil exports subsequent to the
SRE expirations is depicted in the table below.

27 Department of State. Background Briefing on President Trump’s Decision to Withdraw from the JCPOA. May 8,
2018.
28 https://www.state.gov/decision-on-imports-of-iranian-oil/.
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Waiver and Termination Provisions
The law provides for the President to waive the sanctions for 120 days, renewable for successive 120-day periods,
if the President determines that doing so is in the national security interest. Outright repeal or amendment of this
law would require congressional action.
This provision was waived to implement the JPA (to allow Iran’s oil customers to maintain purchases level at 1.1
million barrels per day) and again to implement the JCPOA (to remove any ceiling on Iran’s exports of oil).
Waivers to Implement the JCPOA
The provision (Section 1245(d)(5)) was waived on January 18, 2017, just before the Obama Administration left office. The
Trump Administration renewed the waiver on May 18, 2017, on September 14, 2017, and on January 12, 2018. This law
went back into effect on November 5, 2018 (180-day wind-down period).
Iran Foreign Bank Account “Restriction” Provision
Status: Back in Effect on November 5, 2018
The ability of Iran to repatriate hard currency—U.S. dollars are the primary form of payment for
oil—to its Central Bank was impeded by a provision of the ITRSHRA which went into effect on
February 6, 2013 (180 days after enactment). Section 504 of the ITRSHRA amended Section
1245 of the FY2012 NDAA (adding “clause ii” to Paragraph D[1]) by requiring that any funds
paid to Iran as a result of exempted transactions (oil purchases, for example) be credited to an
account located in the country with primary jurisdiction over the foreign bank making the
transaction.
This provision essentially prevents Iran from repatriating to its Central Bank any hard currency
Iran held in foreign banks around the world. Most of Iran’s funds held abroad are in banks located
in Iran’s main oil customers. The provision largely compels Iran to buy the products of the oil
customer countries. Some press reports refer to this arrangement as an “escrow account,” but
State Department officials describe the arrangement as “restricted” accounts.
Waiver for Bank Account Restriction
The waiver provision that applies to the sanctions imposed under the FY2012 NDAA (P.L. 112-81) applies to this
Iran foreign bank account restriction provision. A waiver period of six months is permitted.
To implement the JPA, a waiver was issued under P.L. 112-81 (Section 212 and 213) to allow Iran to receive some
hard currency from ongoing oil sales in eight installments during the JPA period. Iran remained unable under the
JPA to remove hard currency from existing accounts abroad. As of Implementation Day, the restriction was
waived completely, enabling Iran to gain access to hard currency from ongoing purchases of its oil.
Waivers to Implement the JCPOA
Sections 212(d)(10 and 2134(b)(1) of ITRSHRA were waived by the Obama Administration on January 18, 2017. The
waiver was last renewed on January 12, 2018. Its provisions went back into effect on November 5, 2018.
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Table 1. Iran Crude Oil Sales
(average daily volumes, in barrels per day)
JPA period
At U.S.
At SRE
July 2019
average
JCPOA Exit
Determination
(post-SRE
Country/Bloc
2011
(2014-2016)
(May ‘18)
(Oct. ‘18)
termination)
European Union
(particularly
600,000
negligible
520,000 +
100,000
0
Italy, Spain,
Greece)
China
550,000
410,000
700,000
838,000
230,000
Japan
325,000
190,000
133,000
0
0
India
320,000
190,000
620,000
354,000
0
South Korea
230,000
130,000
100,000
0
0
Turkey
200,000
120,000
200,000
161,000
0
South Africa
80,000
negligible
negligible
0
0
Other Asia
(Malaysia, Sri
90,000
negligible
negligible

0
Lanka,
Indonesia)
Taiwan
35,000
10,000
67,000
0
0
Singapore
20,000
negligible
negligible
33,000
0
Syria
0
negligible
33,000
96.000
0
Other/Unknown
(Iraq and UAE
55,000
negligible
100,000
21,000
65,000
swaps, other)
Total (mbd)
2.5
1.06
2.45
1.60
0.295
Sources: Bloomberg News, Reuters and other press articles. Information on actual Iranian exports is often
preliminary, incomplete, and inaccurate, and this table therefore contains figures from at least one month prior.
Figures might not reflect actual deliveries due to reported activities by Iran and various oil customers to conceal
purchases or avoid tracking of oil tankers. Figures do not include purchases of condensates, which are light
petroleum liquids that are associated with oil and natural gas production. South Korea was a large customer for
Iranian condensates and, as of August 2018, it cut its purchases of that product from Iran to zero.
Note: mbd = million barrels per day.
Sanctions on Auto Production and Minerals Sectors
Successive Administrations have expanded sanctions, primarily by executive order, on several
significant nonoil industries and sectors of Iran’s economy. The targeted sectors include Iran’s
automotive production sector, which is Iran’s second-largest industry (after energy), and its
mineral exports, which account for about 10% of Iran’s export earnings.
Executive Order 13645/13846: Iran’s Automotive Sector, Rial
Trading, and Precious Stones
JCPOA Status: Revoked (by E.O 13716) but most provisions below went back into effect under
E.O. 13846 of August 6, 2018.
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Executive Order 13645 of June 3, 2013, as superseded by 13846 of August 6, 2018:
 Imposes ISA sanctions on firms that supply goods or services to Iran’s
automotive (cars, trucks, buses, motorcycles, and related parts) sector, and blocks
foreign banks from the U.S. market if they finance transactions with Iran’s
automotive sector.
 Blocks U.S.-based property and prohibits U.S. bank accounts for foreign banks
that conduct transactions in Iran’s currency, the rial, or hold rial accounts. This
provision mostly affected banks in countries bordering or near Iran. The order
applies also to “a derivative, swap, future, forward, or other similar contract
whose value is based on the exchange rate of the Iranian rial.” If Iran implements
plans to develop a digital currency, or cryptocurrency, backed by or tied to rials,
it would appear that the order also applies to that digital currency.
 Expand the application of Executive Order 13622 (above) to helping Iran acquire
precious stones or jewels (see above).
 Block U.S.-based property of a person that conducts transactions with an Iranian
entity listed as a Specially Designated National (SDN) or Blocked Person. SDNs
were “relisted” on November 5, 2018.
Executive Order 13871 on Iran’s Minerals and Metals Sectors
On May 8, 2019, President Trump issued Executive Order 13871 sanctioning transactions with
Iran’s key minerals and industrial commodities. The White House announcement stated that Iran
earns 10% of its total export revenues from sales of the minerals and metals sanctioned under the
order.29 The order does the following:
 blocks U.S.-based property of any entity that conducts a significant transaction
for the “sale, supply, or transfer to Iran” of goods or services, or the transport or
marketing, of the iron, steel, aluminum, and copper sectors of Iran;
 authorizes the Secretary of the Treasury to bar from the U.S. financial system any
foreign bank that conducts or facilitates a financial transaction for steel, steel
products, copper, or copper products from Iran;
 bars the entry into the United States of any person sanctioned under the order.
Sanctions on Weapons of Mass Destruction,
Missiles, and Conventional Arms Transfers
Status: No sanctions in this section eased to implement JCPOA
Several laws and executive orders seek to bar Iran from obtaining U.S. or other technology that
can be used for weapons of mass destruction (WMD) programs. Sanctions on Iran’s exportation
of arms are discussed in the sections above on sanctions for Iran’s support for terrorist groups.

29 https://www.whitehouse.gov/briefings-statements/statement-president-donald-j-trump-regarding-imposing-sanctions-
respect-iron-steel-aluminum-copper-sectors-iran/.
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Iran-Iraq Arms Nonproliferation Act and Iraq Sanctions Act
The Iran-Iraq Arms Nonproliferation Act (Title XIV of the FY1993 National Defense
Authorization Act, P.L. 102-484, signed in October 1992) imposes a number of sanctions on
foreign entities that supply Iran with WMD technology or “destabilizing numbers and types of
advanced conventional weapons.”30
Advanced conventional weapons are defined as
(1) such long-range precision-guided munitions, fuel air explosives, cruise missiles, low
observability aircraft, other radar evading aircraft, advanced military aircraft, military satellites,
electromagnetic weapons, and laser weapons as the President determines destabilize the military
balance or enhance the offensive capabilities in destabilizing ways;
(2) such advanced command, control, and communications systems, electronic warfare systems,
or intelligence collections systems as the President determines destabilize the military balance or
enhance offensive capabilities in destabilizing ways; and
(3) such other items or systems as the President may, by regulation, determine necessary for the
purposes of this title.
The definition is generally understood to include technology used to develop ballistic missiles.
Sanctions to be imposed: Sanctions imposed on violating entities include
 a ban, for two years, on U.S. government procurement from the entity;
 a ban, for two years, on licensing U.S. exports to that entity;
 authority, but not a requirement, to ban U.S. imports from the entity.
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 of a U.S. vote against international loans to it;
 a one-year suspension of U.S. coproduction agreements with the country;
 a one-year suspension of technical exchanges with the country in military or dual
use technology;
 a one-year ban on sales of U.S. arms to the country;
 an authorization to deny the country most-favored-nation trade status; and to ban
U.S. trade with the country.
Section 1603 of the act amended an earlier law, the Iraq Sanctions Act of 1990 (Section 586G(a)
of P.L. 101-513), to provide for a “presumption of denial” for all dual use exports to Iran
(including computer software).
Implementation
A number of entities were sanctioned under the act in the 1990s, as shown in the tables at the end
of this paper. None of the designations remain active, because the sanctions have limited duration.

30 The act originally only applied to advanced conventional weapons. The extension to WMD, defined as chemical,
biological, or nuclear weapons-related technology was added by the FY1996 National Defense Authorization Act (P.L.
104-106).
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Waiver
Section 1606 of the act provides a presidential waiver for its provisions, and for sanctions imposed pursuant to the
Iraq Sanctions Act of 1990, if the President determines that it is “essential to the national interest.”
Banning Aid to Countries that Aid or Arm Terrorism List States:
Anti-Terrorism and Effective Death Penalty Act of 1996
Another law reinforces the authority of the President to sanction governments that provide aid or
sell arms to Iran (and other terrorism list countries). Under Sections 620G and 620H of the
Foreign Assistance Act, as added by the Anti-Terrorism and Effective Death Penalty Act of 1996
(Sections 325 and 326 of P.L. 104-132), the President is required to withhold foreign aid from any
country that provides to a terrorism list country financial assistance or arms. Waiver authority is
provided. Section 321 of that act also makes it a criminal offense for U.S. persons to conduct
financial transactions with terrorism list governments.
Implementation
No foreign assistance cuts or other penalties under this law have been announced.
Proliferation-Related Provision of the Iran Sanctions Act
As noted above, Section 5(b)(1) of ISA subjects to ISA sanctions firms or persons determined to
have sold to Iran (1) technology useful for weapons of mass destruction (WMD) or (2)
“destabilizing numbers and types” of advanced conventional weapons. This, and Section 5(b)(2)
pertaining to joint ventures to mine uranium, are the only provisions of ISA that were not waived
to implement the JCPOA.
Implementation. As noted earlier, no sanctions under this section have been imposed.
Iran-North Korea-Syria Nonproliferation Act
The Iran Nonproliferation Act (P.L. 106-178, signed in March 2000) is now called the Iran-North
Korea-Syria Nonproliferation Act (INKSNA) after amendments applying its provisions to North
Korea and to Syria. It authorizes sanctions—for two years unless renewed—on foreign persons
(individuals or corporations, not governments) that are determined in a report by the
Administration to have assisted Iran’s WMD programs. Sanctions imposed include (1) a
prohibition on U.S. exportation of arms and dual use items to the sanctioned entity; and (2) a ban
on U.S. government procurement and of imports to the United States from the sanctioned entity
under Executive Order 12938 (of November 14, 1994). INKSNA also banned U.S. extraordinary
payments to the Russian Aviation and Space Agency in connection with the international space
station unless the President certified that the agency had not transferred any WMD or missile
technology to Iran within the year prior.31

31 The provision contains certain exceptions to ensure the safety of astronauts, but it nonetheless threatened to limit
U.S. access to the international space station after April 2006, when Russia started charging the United States for
transportation on its Soyuz spacecraft. Legislation in the 109th Congress (S. 1713, P.L. 109-112) amended the provision
in order to facilitate continued U.S. access and extended INA sanctions provisions to Syria.
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Implementation
Entities that have been sanctioned under this law are listed in the tables at the end of the report.
Designations more than two years old are no longer active. The JCPOA required the United States
to suspend INKSNA sanctions against “the acquisition of nuclear-related commodities and
services for nuclear activities contemplated in the JCPOA,” but no INKSNA sanctions were
altered during that time.
Waiver and Termination
Section 4 gives the President the authority to not impose sanctions if the President justifies that decision to
Congress. Section 5 provides for exemptions from sanctions if certain conditions are met, particularly that the
government with jurisdiction over the entity cooperating to stop future such transfers to Iran.
Termination of this law would require congressional action.
Executive Order 13382 on Proliferation-Supporting Entities
Status: Order Remained in Force, but Numerous Entities “Delisted”
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.
Implementation
The numerous Iranian or Iran-related entities sanctioned under the order for are listed in the tables
at the end of this report. Entities delisted and which were to be delisted in accordance with the
JCPOA (in October 2023) are in italics and boldface type, respectively. Virtually all entities
delisted to implement the JCPOA were relisted on November 5, 2018.
Arms Transfer and Missile Sanctions: The Countering America’s
Adversaries through Sanctions Act (CAATSA, P.L. 115-44)
The CAATSA law, signed on August 2, 2017, mandates sanctions on arms sales to Iran and on
entities that “materially contribute” to Iran’s ballistic missile program.
 Section 104 references implementation of E.O. 13382, which sanctions entities
determined by the Administration to be assisting Iran’s ballistic missile program.
The section mandates that the Administration impose the same sanctions as in
E.O. 13382 on any activity that materially contributes to Iran’s ballistic missile
program or any system capable of delivering WMD. The section also requires an
Administration report every 180 days on persons (beginning on January 29,
2018) contributing to Iran’s ballistic missile program in the preceding 180 days.
 Section 107 mandates imposition of sanctions (the same sanctions as those
contained in E.O. 13382) on any person that the President determines has sold or
transferred to or from Iran, or for the use in or benefit of Iran: the weapons
systems specified as banned for transfer to or from Iran in U.N. Security Council
Resolution 2231. These include most major combat systems such as tanks,
armored vehicles, warships, missiles, combat aircraft, and attack helicopters. The
provision goes somewhat beyond prior law that mandates sanctions mainly on
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sales to Iran of “destabilizing numbers and types of advanced conventional
weapons.” The imposition of sanctions is not required if the President certifies
that a weapons transfer is in the national security of the United States; that Iran
no longer poses a significant threat to the United States or U.S. allies; and that
the Iranian government no longer satisfies the requirements for designation as a
state sponsor of terrorism.
Implementation
The CAATSA provisions have been implemented through additional designations for sanctions
(SDNs) under the executive orders referenced in CAATSA, primarily E.O. 13382.

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Sanctions on the Islamic Revolutionary Guard Corps (IRGC)
Numerous sanctions target Iran’s Islamic Revolutionary Guard Corps (IRGC), and none was waived or terminated
to implement the JCPOA. The IRGC plays a role in both internal and external defense, supports pro-Iranian
movements in the region, and owns or controls economic entities in Iran that account for as much as 20% of
Iran’s economic output. Many of the IRGC’s subordinate units, such as the IRGC Qods Force and the Basij militia,
have been designated for sanctions under various Executive Orders, as have corporate entities owned or
controlled by the IRGC, such as the large engineering firm Khatam ol-Anbia.

The IRGC has been named as a proliferation-supporting entity under Executive Order 13382, a human rights
abuser under E.O. 13553 and, in accordance with the Countering America’s Adversaries through Sanctions
Act (P.L. 115-44), it was named a terrorism-supporter under E.O. 13224 (October 13, 2017). The IRGC-
Qods Force (IRGC-QF), the unit of the IRGC that assists pro-Iranian movements abroad, is named as a
terrorism-supporting entity under Executive Order 13324 and a repressor of the Syrian people under E.O.
13572. Hundreds of IRGC-linked entities—companies, facilitators and financial partners, and commanders—
are designated for sanctions under those and other orders, as noted in the tables at the end of this report.

IFCA (Section 1244) mandates that any entity that knowingly conducts transactions with a designated Iranian
entity is subject to having its U.S.-based assets blocked.

ITRSHRA (Section 302) imposes at least 5 out of 12 ISA sanctions on persons that materially assist, with
financing or technology, the IRGC, or assist or engage in “significant” transactions with any of its affiliates that
are sanctioned under Executive Order 13382, 13224, or similar executive orders—or which are determined
to be affiliates of the IRGC. Section 302 did not amend ISA.

ITRSHRA (Section 311) requires a certification by a contractor to the U.S. government that it is not
knowingly engaging in a significant transaction with the IRGC, or any of its agents or affiliates that have been
sanctioned under several executive orders discussed below. A contract may be terminated if it is determined
that the company’s certification of compliance was false.

ITRSHRA (Section 301) requires the President to identify “officials, agents, or affiliates” of the IRGC and to
impose sanctions in accordance with Executive Order 13382 or 13224. Some of these designations, including
of National Iranian Oil Company (NIOC), were made by the Treasury Department on November 8, 2012.

ITRSHRA (Section 303) requires the imposition of sanctions on agencies of foreign governments that
provide technical or financial support, or goods and services to sanctioned (under U.S. executive orders or
U.N. resolutions) members or affiliates of the IRGC. Sanctions include a ban on U.S. assistance or credits for
that foreign government agency, a ban on defense sales to it, a ban on U.S. arms sales to it, and a ban on
exports to it of controlled U.S. technology.

Section 104 of CISADA sanctions foreign banks that conduct significant transactions with the IRGC or any of
its agents or affiliates that are sanctioned under any executive order. It also sanctions any entity that assists
Iran’s Central Bank efforts to help the IRGC acquire WMD or support international terrorism.

In October 2018, 20 economic entities, including a steel company and acid and zinc mining firms, were
sanctioned under E.O 13224 for providing revenue to the Basij militia, an arm of the IRGC.

On April 8, 2019, the Trump Administration named the IRGC as a Foreign Terrorist Organization (FTO)
under Section 219 of the Immigration and Nationality Act (8 U.S.C. 819). In addition to the sanctions above,
the FTO designation provides for criminal penalties for U.S. persons or any bank that knowingly provides
“material support” to an FTO (ex. donations, facilitation of its activities).

On September 4, 2019, U.S. officials announced that they are using the State Dept. “Rewards for Justice”
program that provides reward money for information about potential terrorist plots for Iran. The reward
monies are to be used to disrupt Iran’s oil shipments and obtain information on the IRGC’s financial
operations. The basis for the Administration use of that program, as well as related sanctions designations in
August and September 2019, was an asserted linkage between the IRGC and Iran’s oil exportation.

Foreign Aid Restrictions for Named Suppliers of Iran
Some past foreign aid appropriations have withheld U.S. assistance to the Russian Federation
unless it terminates technical assistance to Iran’s nuclear and ballistic missiles programs. The
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provision applied to the fiscal year for which foreign aid is appropriated. Because U.S. aid to
Russia generally has not gone to the Russian government, little or no funding was withheld as a
result of the provision. The JCPOA makes no reference to any U.S. commitments to waive this
sanction or to request that Congress not enact such a provision.
Sanctions on “Countries of Diversion Concern”
Title III of CISADA established authorities to sanction countries that allow U.S. technology that
Iran could use in its nuclear and WMD programs to be re-exported or diverted to Iran. Section
303 of CISADA authorizes the President to designate a country as a “Destination of Diversion
Concern” if that country allows substantial diversion of goods, services, or technologies
characterized in Section 302 of that law to Iranian end-users or Iranian intermediaries. The
technologies specified include any goods that could contribute to Iran’s nuclear or WMD
programs, as well as goods listed on various U.S. controlled-technology lists such as the
Commerce Control List or Munitions List. For any country designated as a country of diversion
concern, there would be prohibition of denial for licenses of U.S. exports to that country of the
goods that were being re-exported or diverted to Iran.
Implementation: To date, no country has been designated a “Country of Diversion Concern.”
Some countries adopted or enforced anti-proliferation laws apparently to avoid designation.

Waiver and Termination
Waiver: The President may waive sanctions on countries designated as of Diversion Concern for 12 months, and
additional 12-month periods, pursuant to certification that the country is taking steps to prevent diversions and
re-exports.
Termination: The designation terminates on the date the President certifies to Congress that the country has
adequately strengthened its export controls to prevent such diversion and re-exports to Iran in the future. The
JCPOA makes no reference to waiving or terminating this sanction.
Financial/Banking Sanctions
U.S. efforts to shut Iran out of the international banking system were a key component of the
2010-2016 international sanctions regime.
Targeted Financial Measures
Status: Suspended during JCPOA, now superseded by other sanctions
During 2006-2016, the Department of the Treasury used long-standing authorities to persuade
foreign banks to cease dealing with Iran, in part by briefing them on Iran’s use of the international
financial system to fund terrorist groups and acquire weapons-related technology. According to a
GAO report of February 2013, the Department of the Treasury made overtures to 145 banks in 60
countries, including several visits to banks and officials in the UAE, and convinced at least 80
foreign banks to cease handling financial transactions with Iranian banks. Upon implementation
of the JCPOA, the Treasury Department largely dropped this initiative, and instead largely sought
to encourage foreign banks to conduct normal transactions with Iran.
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Ban on Iranian Access to the U.S. Financial System/Use of Dollars
Status: Remains in Force
There is no blanket ban on foreign banks or persons paying Iran for goods using U.S. dollars. But,
U.S. regulations (ITRs, C.F.R. Section 560.516) ban Iran from direct access to the U.S. financial
system. The regulations allow U.S. banks to send funds (including U.S. dollars) to Iran for
allowed (licensed) transactions. However, the U.S. dollars cannot be directly transferred to an
Iranian bank, but must instead be channeled through an intermediary financial institution, such as
a European bank. Section 560.510 specifically allows for U.S. payments to Iran to settle or pay
judgments to Iran, such as those reached in connection with the U.S.-Iran Claims Tribunal,
discussed above. However, the prohibition on dealing directly with Iranian banks still applies.
On November 6, 2008, the Department of the Treasury broadened restrictions on Iran’s access to
the U.S. financial system by barring U.S. banks from handling any transactions with foreign
banks that are handling transactions on behalf of an Iranian bank (“U-turn transactions”).32 This
means a foreign bank or person that pays Iran for goods in U.S. dollars cannot access the U.S.
financial system (through a U.S. correspondent account, which most foreign banks have) to
acquire dollars for any transaction involving Iran. This ban remained in effect under the JCPOA
implementation, and Iran argued that these U.S. restrictions deter European and other banks from
reentering the Iran market, as discussed later in this report.
Recent Developments
Then-Treasury Secretary Lew in March and April 2016 suggested the Obama Administration was
considering licensing transactions by foreign (non-Iranian) clearinghouses to acquire dollars that
might facilitate transactions with Iran, without providing Iran with dollars directly.33 However,
doing so was not required by the JCPOA and the Administration declined to take that step.
Instead, the Obama Administration encouraged bankers to reenter the Iran market without fear of
being sanctioned. The Trump Administration has not, at any time, expressed support for allowing
Iran greater access to dollars. The reimposition of U.S. sanctions has further reduced the
willingness and ability of foreign firms to use dollars in transactions with Iran.
Punishments/Fines Implemented against Some Banks.
The Department of the Treasury and other U.S. authorities have announced financial settlements
with various banks that violated U.S. regulations in transactions related to Iran (and other
countries such as Sudan, Syria, and Cuba). The amounts were reportedly determined, at least in
part, by the value, number, and duration of illicit transactions conducted, and the strength of the
evidence collected by U.S. regulators.34 (As noted above, the FY2016 Consolidated
Appropriation, P.L. 114-113, provided for use of the proceeds of the settlements above to pay
compensation to victims of Iranian terrorism.)

32 For text of the OFAC ruling barring U-Turn transactions, see https://www.treasury.gov/resource-center/sanctions/
Documents/fr73_66541.pdf.
33 See Katherine Bauer. “Potential U.S. Clarification of Financial Sanctions Regulations.” April 5, 2016.
http://www.washingtoninstitute.org/policy-analysis/view/potential-u.s.-clarification-of-financial-sanctions-regulations.
34 Analyst conversations with U.S. banking and sanctions experts. 2010-2015.
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Table 2. Major Settlements/Fines Paid by Banks for Violations
Amount
Bank
Date
Paid
Violation
UBS (Switzerland)
2004
$100 million
Unauthorized movement of U.S. dollars to
Iran and others
ABN Amro (Netherlands)
December 2005
$80 million
Failing to fully report financial transactions
involving Bank Melli
Credit Suisse (Switzerland)
December 2009
$536 million
Illicitly processing Iranian transactions with
U.S. banks
ING (Netherlands)
June 2012
$619 million
Concealing movement of billions of dollars
through the U.S. financial system for Iranian
and Cuban clients.
Standard Chartered (UK)
August 2012
$340 million
Settlement paid to New York State for
processing transactions on behalf of Iran
Clearstream (Luxembourg) January 2014
$152 million
Helping Iran evade U.S. banking restrictions
Bank of Moscow (Russia)
January 2014
$9.5 million
Illicitly allowing Bank Melli to access the U.S.
financial system
BNP Paribas
June 2014
$9 billion
Amount forfeited for helping Iran (and
Sudan and Cuba) violate U.S. sanction.
Standard Chartered (UK)
April 2019
$639 million
Dubai branch of Standard Chartered
processed Iran-related transactions to or
through Standard Chartered branch in New
York.
Unicredit AG (Germany,
April 2019
$1.3 billion
For illicitly processing transactions through
Austria, Italy)
the U.S. financial system on behalf of Islamic
Republic of Iran Shipping Lines (IRISL)
Source: Various press reports.
CISADA: Sanctioning Foreign Banks That Conduct Transactions
with Sanctioned Iranian Entities
Status: Remained in force after JCPOA, but Iranian banks “delisted.” Delisted
banks will be “relisted” as of November 5, 2018.
The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) was a key
piece of legislation intended to limit Iran’s access to the international financial system and to
reduce the ability of Iran’s import-export community (referred to in Iran as the “bazaar
merchants” or “bazaaris”) from obtaining “letters of credit” (trade financing) to buy or sell
goods. The Department of the Treasury determines what is a “significant” financial transaction.
CISADA’s key provision—Section 104—requires the Secretary of the Treasury to forbid U.S.
banks from opening new “correspondent accounts” or “payable-through accounts” (or force the
cancellation of existing such accounts) for35

35 Foreign banks that do not have operations in the United States typically establish correspondent accounts or payable-
through accounts with U.S. banks as a means of accessing the U.S. financial system.
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 any foreign bank that transactions business with an entity that is sanctioned by
Executive Order 13224 or 13382 (terrorism and proliferation activities,
respectively). These orders are discussed above. A full list of such entities is at
the end of this report, and entities “delisted” are in italics.
 any foreign bank determined to have facilitated Iran’s efforts to acquire WMD or
delivery systems or provide support to groups named as Foreign Terrorist
Organizations (FTOs) by the United States.
 any foreign bank that facilitates “the activities of” an entity designated under by
U.N. Security Council resolutions that sanction Iran.
 any foreign bank that transacts business with the IRGC or any of its affiliates
designated under any U.S. Iran-related executive order.
In addition: Section 1244(d) of the Iran Freedom and Counterproliferation Act, IFCA, applies the
CISADA sanctions to any foreign bank that does business with Iran’s enery, shipping, and
shipbuilding sectors, including with NIOC, NITC, and IRISL. The provision was not an
amendment to CISADA itself. The provision was waived to implement the JCPOA, but was
reinstated to full implementation as of November 5, 2018.
Implementation
Some sanctions have been imposed under Section 104 of CISADA. On July 31, 2012, the United
States sanctioned the Bank of Kunlun in China and the Elaf Islamic Bank in Iraq under Section
104 of CISADA. On May 17, 2013, the Department of the Treasury lifted sanctions on Elaf
Islamic Bank in Iraq, asserting that the bank had reduced its exposure to the Iranian financial
sector and stopped providing services to the Export Development Bank of Iran.
Waiver and Termination
Under Section 401(a) of CISADA, the Section 104 sanctions provisions would terminate 30 days after the
President certifies to Congress that Iran (1) has met the requirements for removal from the terrorism list, AND
(2) has ceased pursuit, acquisition, or development of, and verifiably dismantled its nuclear weapons and other
WMD programs.
The Secretary of the Treasury may waive sanctions under Section 104, with the waiver taking effect 30 days after
the Secretary determines that a waiver is necessary to the national interest and submits a report to Congress
describing the reason for that determination.
As noted, Section 104 was not waived to implement the JCPOA, but many entities with which transactions would
have triggered sanctions under Section 104 have been “delisted” in accordance with the JCPOA. These entities
are to be relisted as Specially Designated Nationals (SDNs) and therefore subject to secondary sanctioning by
November 5, 2018.
Iran Designated a Money-Laundering Jurisdiction/FATF
Status: Central Bank Remained Designated Under this Section during JCPOA
On November 21, 2011, the Obama Administration identified Iran as a “jurisdiction of primary
money laundering concern”36 under Section 311 of the USA Patriot Act (31 U.S.C. 5318A), based
on a determination that Iran’s financial system, including the Central Bank, constitutes a threat to
governments or financial institutions that do business with Iran’s banks. The designation imposed

36 http://www.treasury.gov/press-center/press-releases/Pages/tg1367.aspx.
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additional requirements on U.S. banks to ensure against improper Iranian access to the U.S.
financial system.
In October 2018, the Treasury Department Financial Crimes Enforcement Network (FINCEN)
issued a warning to U.S. banks to guard against likely Iranian efforts to evade U.S. financial
sanctions. Earlier, in January 1, 2013, OFAC issued an Advisory to highlight Iran’s use of
hawalas (traditional informal banking and money exchanges) in the Middle East and South Asia
region to circumvent U.S. financial sanctions. Because the involvement of an Iranian client is
often opaque, banks have sometimes inadvertently processed hawala transactions involving
Iranians.
FATF
The Administration has stated that its regulations on Iran with respect to money laundering and
terrorism financing are intended, in part, to implement the recommendations of the Financial
Action Task Force (FATF)—a multilateral standard-setting body for anti-money laundering and
combating the financing of terrorism (AML/CFT). In 2016, the FATF characterized Iran as a
“high-risk and non-cooperative jurisdiction” with respect to AMF/CFT issues.37 On June 24,
2016, the FATF welcomed an “Action Plan” filed by Iran to address its strategic AML/CFT
deficiencies and decided to suspend, for one year, “countermeasures”—mostly voluntary
recommendations of increased due diligence with respect to Iran transactions—pending an
assessment of Iran’s implementation of its Action Plan. The FATF continued the suspension of
countermeasures in 2017 and February 2018.38
On October 19, 2018, the FATF stated that Iran had not completed legislation to adopt
international standards. On February 22, 2019, the FATF stated that countermeasures remained
suspended but that “If by June 2019, Iran does not enact the remaining legislation in line with
FATF Standards, then the FATF will require increased supervisory examination for branches and
subsidiaries of financial institutions based in Iran.”
In June 2019, the FATF stated that Iran still had not adequately criminalized terrorist financing,
including by removing the exemption for designated groups “attempting to end foreign
occupation, colonialism and racism”; identified and frozen terrorist assets in line with the relevant
United Nations Security Council resolutions; or ensured an adequate and enforceable customer
due diligence regime. The FATF continued the suspension of counter-measures, but called on
members to require increased supervisory examination for branches and subsidiaries of financial
institutions based in Iran, in line with the February 2019 Public Statement.39
Use of the SWIFT System
Section 220 of the ITRSHRA required reports on electronic payments systems, such as the
Brussels-based SWIFT (Society of Worldwide Interbank Financial Telecommunications), that do
business with Iran. That law also authorizes—but neither it nor any other U.S. law or executive
order mandates—sanctions against SWIFT or against electronic payments systems. Still, many
transactions with Iran are subject to U.S. sanctions, no matter the payment mechanism.

37 http://www.fatf-gafi.org/publications/high-riskandnon-cooperativejurisdictions/documents/public-statement-
february-2016.html.
38 http://www.fatf-gafi.org/publications/high-riskandnon-cooperativejurisdictions/documents/public-statement-june-
2017.html.
39 June 2019 FATF statement is at http://www.fatf-gafi.org/countries/d-i/iran/documents/public-statement-june-
2019.html.
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link to page 47 link to page 47 Iran Sanctions

Cross-Cutting Secondary Sanctions: The Iran
Freedom and Counter-Proliferation Act (IFCA)
Status: Waived to implement JCPOA; back into effect in 2018
The National Defense Authorization Act for FY2013 (H.R. 4310, P.L. 112-239, signed January 2,
2013)—Subtitle D, The Iran Freedom and Counter-Proliferation Act (IFCA), sanctions a wide
swath of Iran’s economy, touching several sectors. Its provisions on Iran’s human rights record
are discussed in the section on “Measures to Sanction Human Rights Abuses/Promote Civil
Society.”
 Section 1244 of IFCA mandates the blocking of U.S.-based property of any entity
(Iranian or non-Iranian) that provides goods, services, or other support to any
Iranian entity designated by the Treasury Department as a “specially designated
national” (SDN). The tables at the end of this report show that hundreds of
Iranian entities are designated as SDNs under various executive orders. The
Iranian entities designated for civilian economic activity were “delisted” to
implement the JCPOA, but will be relisted on November 5, 2018.
 Section 1247 of IFCA prohibits from operating in the United States any bank that
knowingly facilitates a financial transaction on behalf of an Iranian SDN. The
section also specifically sanctions foreign banks that facilitate payment to Iran
for natural gas unless the funds owed to Iran for the gas are placed in a local
account. The section provides for a waiver for a period of 180 days.
Several sections of IFCA impose ISA sanctions on entities determined to have engaged in
specified transactions below. (The provisions apply ISA sanctions but do not amend ISA.).
 Energy, Shipbuilding, and Shipping Sector, and Iranian Port Operations. Section
1244: (1) blocks the U.S.-based assets; and (2) mandates the imposition of five
out of 12 ISA sanctions on entities that provide financial, material, technological,
or other support, or provide goods or services to Iran’s energy, shipbuilding, and
shipping sectors, or port operations in Iran. The sanctions do not apply when such
transactions involved purchases of Iranian oil by countries that have exemptions
under P.L. 112-81, or to the purchase of natural gas from Iran. This section went
back into effect as of November 5, 2018). The blocking of U.S.-based assets is
implemented by E.O. 13846 of August 6, 2018.
 Dealings in Precious Metals or Materials for Iran’s Missile, Nuclear, or Military
Programs. Section 1245 imposes 5 out of the 12 sanctions on the ISA menu on
entities that provide precious metals to Iran (including gold) or semi-finished
metals or software for integrating industrial processes. The section affected
foreign firms that transferred these items or other precious metals to Iran in
exchange for oil or any other product. Section 1245 also applies those sanctions
to the supply to Iran of any material determined to be used in connection with
Iran’s nuclear, missile, or military programs. The section also mandates the
exclusion from the U.S. financial system of any foreign bank that facilitates any
of the stipulated transactions. There is no exception to this sanction for countries
exempted under P.L. 112-81. This section went back into effect on August 7,
2018).
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 Insurance for Related Activities. Section 1246 imposes five out of 12 sanctions
on the ISA menu on entities that provide underwriting services, insurance, or
reinsurance for any transactions sanctioned under any executive order on Iran,
ISA, CISADA, the Iran Threat Reduction Act, INKSNA, other IFCA provisions,
or any other Iran sanction, as well as to any Iranian SDN. (There is no exception
for countries exempted under P.L. 112-81.) This provision goes back into effect
after a 180-day wind-down period (by November 4, 2018).
 Exception for Afghanistan Reconstruction. Section 1244(f) of IFCA provides a
sanctions exemption for transactions that provide reconstruction assistance for or
further the economic development of Afghanistan. See JCPOA waivers below.
Implementation
On August 29, 2014, the State Department sanctioned UAE-based Goldentex FZE in accordance
with IFCA for providing support to Iran’s shipping sector. It was “delisted” from sanctions on
Implementation Day of the JCPOA.
On October 16, 2018, OFAC designated as terrorism-related entities several Iranian industrial
companies on the grounds that they provide the Basij security force with revenue to support its
operations in the Middle East. The designations, pursuant to E.O. 13224, mean that foreign firms
that transact business with these Iranian industrial firms could be subject to U.S. sanctions under
IFCA. The industrial firms—which were not previously designated and were therefore not
“relisted” as SDNs on November 5, 2018, were Technotar Engineering Company; Iran Tractor
Manufacturing Company; Iran’s Zinc Mines Development Company and several related zinc
producers; and Esfahan Mobarakeh Steel Company, the largest steel producer in the Middle East.
Waiver and Termination
Sections 1244 and 1245 of IFCA provide for a waiver of sanctions for 180 days, renewable for 180-day periods, if
such a waiver is determined to be vital to U.S. national security. These sections were waived in order to
implement the JPA. In addition, Section 5(a)(7) of ISA was waived to allow for certain transactions with NIOC and
NITC. Sections 1244(i), 1245(g), 1246(e), and 1247(f) of IFCA were waived to implement the JCPOA on January
18, 2017, and that waiver was last renewed on January 12, 2018. IFCA goes back into full effect as specified above.
Executive Order 13608 on Sanctions Evasion
Executive Order 13608 of May 1, 2012, gives the Department of the Treasury the ability to
identify and sanction (cutting them off from the U.S. market) foreign persons who help Iran (or
Syria) evade U.S. and multilateral sanctions.
Several persons and entities have been designated for sanctions, as shown in the tables at the end
of the report.
Sanctions on Iran’s Cyber and Transnational
Criminal Activities
Status: All in Force, including during JCPOA Period
The Trump Administration appears to be making increasing use of executive orders issued during
the Obama Administration to sanction Iranian entities determined to be engaged in malicious
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cyberactivities or in transnational crime. Iranian entities have attacked, or attempted to attack,
using cyberactivity, infrastructure in the United States, Saudi Arabia, and elsewhere. Iran’s ability
to conduct cyberattacks appears to be growing. Separately, the Justice Department has prosecuted
Iranian entities for such activity. The section below discusses Executive Order 13694 on
malicious cyberactivities and Executive Order 13581 on transnational crime.
Executive Order 13694
Executive Order 13694 (April 1, 2015) blocks U.S.-based property of foreign entities determined
to have engaged in cyber-enabled activities that (1) harm or compromise the provision of services
by computers or computer networks supporting in the critical infrastructure sector; (2)
compromise critical infrastructure; (3) disrupt computers or computer networks; or (4) cause
misappropriation of funds, trade secrets, personal identifiers, or financial information for financial
advantage or gain.
Executive Order 13581
Executive Order 13581 (July 25, 2011) blocks the U.S.-based property of entities determined (1)
to be a foreign person that constitutes a significant transnational criminal organization; (2) to have
materially assisted any person sanctioned under this order; or (3) to be owned or controlled by or
to have acted on behalf of a person sanctioned under the order.
Implementation of E.O. 13694 and 13581
Iran-related entities sanctioned under the orders are listed in the tables at the end of this report.
Divestment/State-Level Sanctions
Some U.S. laws require or call for divestment of shares of firms that conduct certain transactions
with Iran. A divestment-promotion provision was contained in CISADA, providing a “safe
harbor” for investment managers who sell shares of firms that invest in Iran’s energy sector at
levels that would trigger U.S. sanctions under the Iran Sanctions Act. As noted above, Section
219 of the ITRSHRA of 2012 requires companies to reports to the Securities and Exchange
Commission whether they or any corporate affiliate has engaged in any transactions with Iran that
could trigger sanctions under ISA, CISADA, and E.O 13382 and 13224.
Implementation: Numerous states have adopted laws, regulations, and policies to divest from—or
avoid state government business with—foreign companies that conduct certain transactions with
Iran. The JCPOA requires the United States to work with state and local governments to ensure
that state-level sanctions do not conflict with the sanctions relief provided by the federal
government under the JCPOA. Most states that have adopted Iran sanctions continue to enforce
those measures.
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Sanctions to Support Democracy and Human Rights
in Iran
Post-JCPOA Status: Virtually All Sanctions in This Section Remain in Effect.
No Entities “Delisted.”40
A trend in U.S. policy and legislation since the June 12, 2009, election-related uprising in Iran has
been to support the ability of the domestic opposition in Iran to communicate and to sanction
Iranian officials that commit human rights abuses. Sanctions on the IRGC represent one facet of
that trend because the IRGC is a key suppressive instrument. Individuals and entities designated
under the executive orders and provisions discussed below are listed in the tables at the end of
this report. For those provisions that ban visas to enter the United States, the State Department
interprets the provisions to apply to all members of the designated entity.41
Expanding Internet and Communications Freedoms
Some laws and Administration action focus 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, contained several provisions to increase U.S. broadcasting to Iran and to identify (in a report
to be submitted 180 days after enactment) companies that are selling Iran technology equipment
that it can use to suppress or monitor the internet usage of Iranians. The act authorized funds to
document Iranian human rights abuses since the June 2009 Iranian presidential election. Section
1241 required an Administration report by January 31, 2010, on U.S. enforcement of sanctions
against Iran and the effect of those sanctions on Iran.
Countering Censorship of the Internet: CISADA, E.O. 13606, and E.O. 13628
 Section 106 of CISADA prohibits U.S. government contracts with foreign
companies that sell technology that Iran could use to monitor or control Iranian
usage of the internet. The provisions were directed, in part, against Nokia
(Finland) and Siemens (Germany) for reportedly selling internet monitoring and
censorship technology to Iran in 2008.42 The provision was derived from the
Reduce Iranian Cyber-Suppression Act (111th Congress, S. 1475 and H.R. 3284).
 On April 23, 2012, President Obama issued an executive order (13606)
sanctioning persons who commit “Grave Human Rights Abuses by the
Governments of Iran and Syria via Information Technology (GHRAVITY).” The
order blocks the U.S.-based property and essentially bars U.S. entry and bans any
U.S. trade with persons and entities listed in an Annex and persons or entities
subsequently determined to be (1) operating any technology that allows the
Iranian (or Syrian) government to disrupt, monitor, or track computer usage by
citizens of those countries or assisting the two governments in such disruptions or

40 Sections 5-7 and 15 of Executive Order 13628 which have to do primarily with Iran’s energy sector, were revoked,
but the remaining sections, which concern human rights issues, remain in place.
41 U.S. Department of the Treasury, Office of Public Affairs, Treasury Sanctions Iranian Security Forces for Human
Rights Abuses, June 9, 2011.
42 Christopher Rhoads, “Iran’s Web Spying Aided by Western Technology,” Wall Street Journal, June 22, 2009.
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monitoring; or (2) selling to Iran (or Syria) any technology that enables those
governments to carry out such actions.
 Section 403 of the ITRSHRA sanctions (visa ban, U.S.-based property blocked)
persons/firms determined to have engaged in censorship in Iran, limited access to
media, or—for example, a foreign satellite service provider—supported Iranian
government jamming or frequency manipulation. On October 9, 2012, the
President issued Executive Order 13628 implementing Section 403 by blocking
the property of persons/firms determined to have committed the censorship,
limited free expression, or assisted in jamming communications. The order also
specifies the sanctions authorities of the Department of State and of the Treasury.
Laws and Actions to Promote Internet Communications by Iranians
 On March 8, 2010, OFAC amended the Iran Transactions Regulations to allow
for a general license for providing free mass market software to Iranians. The
ruling incorporated major features of the Iran Digital Empowerment Act (H.R.
4301 in the 111th Congress). The OFAC determination required a waiver of the
provision of the Iran-Iraq Arms Nonproliferation Act (Section 1606 waiver
provision) discussed above.
 Section 103(b)(2) of CISADA exempts from the U.S. export ban on Iran
equipment to help Iranians communicate and use the internet.
 On March 20, 2012, the Department of the Treasury amended U.S.-Iran trade
regulations to permit several additional types of software and information
technology products to be exported to Iran under general license, provided the
products were available at no cost to the user.43 The items included personal
communications, personal data storage, browsers, plug-ins, document readers,
and free mobile applications related to personal communications.
 On May 30, 2013, the Department of the Treasury amended the trade regulations
further to allow for the sale, on a cash basis (no financing), to Iran of equipment
that Iranians can use to communicate (e.g., cellphones, laptops, satellite internet,
website hosting, and related products and services).
Measures to Sanction Human Rights Abuses/Promote Civil Society
Some legislation has sought to sanction regime officials involved in suppressing the domestic
opposition in Iran or in human rights abuses more generally. Much of this legislation centers on
amendments to Section 105 of CISADA.
 Sanctions against Iranian Human Rights Abusers (CISADA and E.O. 13553).
Section 105 of CISADA bans travel and freezes the U.S.-based assets of those
Iranians determined to be human rights abusers. On September 29, 2010,
pursuant to Section 105, President Obama issued Executive Order 13553
providing for CISADA sanctions against Iranians determined to be responsible
for or complicit in post-2009 Iran election human rights abuses. Section 105
terminates if the President certifies to Congress that Iran has (1) unconditionally
released all political prisoners detained in the aftermath of the June 2009
uprising; (2) ceased its practices of violence, unlawful detention, torture, and

43 Fact Sheet: Treasury Issues Interpretive Guidance and Statement of Licensing Policy on Internet Freedom in Iran,
March 20, 2012.
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abuse of citizens who were engaged in peaceful protest; (3) fully investigated
abuses of political activists that occurred after the uprising; and (4) committed to
and is making progress toward establishing an independent judiciary and
respecting human rights.
 Expansion of Section 105 by the Countering America’s Adversaries through
Sanctions Act (CAATSA, P.L. 115-44). CAATSA expanded Section 105 of
CISADA by authorizing (but not mandating) sanctions on Iranian human rights
abuses generally—not limited to those connected to the June 2009 uprising. The
CAATSA provisions defines as sanctionable: extrajudicial killings, torture, or
other gross violations of internationally recognized human rights against Iranians
who seek to expose illegal activity by officials or to defend or promote human
rights and freedoms in Iran. The persons to be sanctioned are those named in a
report provided 90 days after CAATSA enactment (by October 31, 2017) and
annually thereafter. Additional designations of Iranian human rights abusers
under E.O. 13533 were made by an October 31, 2017, deadline in CAATSA.
 Sanctions on Sales of Anti-Riot Equipment. Section 402 of the ITRSHRA
amended Section 105 by adding provisions that sanction (visa ban, U.S. property
blocked) any person or company that sells the Iranian government goods or
technologies that it can use to commit human rights abuses against its people.
Such goods include firearms, rubber bullets, police batons, chemical or pepper
sprays, stun grenades, tear gas, water cannons, and like goods. In addition, ISA
sanctions are to be imposed on any person determined to be selling such
equipment to the IRGC.
 Sanctions against Iranian Government Broadcasters/IRIB. Section 1248 of IFCA
(Subtitle D of P.L. 112-239) mandates inclusion of the Islamic Republic of Iran
Broadcasting (IRIB), the state broadcasting umbrella group, as a human rights
abuser. IRIB was designated as an SDN on February 6, 2013, under E.O. 13628
for limiting free expression in Iran. On February 14, 2014, the State Department
waived IFCA sanctions under Sections 1244, 1246, or 1247, on any entity that
provides satellite connectivity services to IRIB. The waiver has been renewed
each year since.
 Sanctions against Iranian Profiteers. Section 1249 of IFCA amends Section 105
by imposing sanctions on any person determined to have engaged in corruption
or to have diverted or misappropriated humanitarian goods or funds for such
goods for the Iranian people. The measure is intended to sanction Iranian
profiteers who are, for example, using official connections to corner the market
for vital medicines. This provision, which remains in forces, essentially codifies a
similar provision of Executive Order 13645.
 Separate Visa Bans. On July 8, 2011, the State Department imposed visa
restrictions on 50 Iranian officials for participating in political repression in Iran,
but it did not name those banned on the grounds that visa records are
confidential. The action was taken under the authorities of Section 212(a)(3)(C)
of the Immigration and Nationality Act, which renders inadmissible to the United
States a foreign person whose activities could have serious consequences for the
United States. On May 30, 2013, the State Department announced it had imposed
visa restrictions on an additional 60 Iranian officials on similar grounds.44

44 http://www.state.gov/r/pa/prs/ps/2013/05/210102.htm.
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 High Level Iranian Visits. There are certain exemptions in the case of high level
Iranian visits to attend U.N. meetings in New York. The U.N. Participation Act
(P.L. 79-264) provides for U.S. participation in the United Nations and as host
nation of U.N. headquarters in New York, and visas are routinely issued to heads
of state and their aides attending these meetings. In September 2012, the State
Department refused visas for 20 members of Iranian President Ahmadinejad’s
traveling party on the grounds of past involvement in terrorism or human rights
abuses. Still, in line with U.S. obligations under the act, then-President
Ahmadinejad was allowed to fly to the United States on Iran Air, even though
Iran Air was at the time a U.S.-sanctioned entity, and his plane reportedly was
allowed to park at Andrews Air Force base.
Sanctions on Iran’s Leadership
The Trump Administration has imposed sanctions on some members of Iran’s civilian leadership.
The Administration has named some Iranian officials as SDNs under various executive orders, as
shown in the table at the end of the report. As noted throughout, any Iranian official that is named
an SDN is subject to a freezing of their U.S.-based property and there are secondary sanctions
(noted throughout) on third parties that deal with those entities. Section 103(b)(3) of CISADA
also provides for the freezing of assets of any “family member or associate acting for on behalf of
the person” that is named as an SDN.
Executive Order 13876
On June 24, 2019, in the context of heightened U.S.-Iran tensions, President Trump issued
Executive Order 13876, targeting the assets of Supreme Leader Ali Khamene’i and his top
associates. Still, the degree to which Khamene’i’s or his associates’ assets intersect with the
global financial or commercial community is likely modest, making the effect of the order
probably limited. The order
 Blocks the U.S.-based property or assets of the Supreme Leader and his office,
any Iranian appointed by him to an official position, or any person that materially
assists the Supreme Leader or his office.
 Bars from the U.S. financial system any bank determined to have conducted or
facilitated a financial transaction with a Supreme Leader-related or Supreme
Leader-appointed official.
U.N. Sanctions
U.N. sanctions on Iran, enacted by the Security Council under Article 41 of Chapter VII of the
U.N. Charter,45 applied to all U.N. member states. During 2006-2008, three U.N. Security
Council resolutions—1737, 1747, and 1803—imposed sanctions on Iran’s nuclear program and
weapons of mass destruction (WMD) infrastructure. Resolution 1929, adopted on June 9, 2010,
was key for its assertion that major sectors of the Iranian economy support Iran’s nuclear
program—giving U.N. member states authorization to sanction civilian sectors of Iran’s

45 Security Council resolutions that reference Chapter VII of the U.N. Charter represent actions taken with respect to
threats to international peace and acts of aggression. Article 41 of that Chapter, in general, provides for enforcement of
the resolution in question through economic and diplomatic sanctions, but not through military action.
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economy. It also imposed strict limitations on Iran’s development of ballistic missiles and imports
and exports of arms.
Resolution 2231 and U.N. Sanctions Eased
U.N. Security Council Resolution 2231 of July 20, 2015
 endorsed the JCPOA and superseded all prior Iran-related resolutions as of
Implementation Day (January 16, 2016).
 lifted all U.N. sanctions discussed above. The Resolution did not continue the
mandate of the “the panel of experts” and the panel ended its operations.
 “calls on” Iran not to develop ballistic missiles “designed to be capable” of
delivering a nuclear weapon for a maximum of eight years from Adoption Day
(October 18, 2015). The restriction expires on October 18, 2023. And, 2231 is far
less restrictive on Iran’s missile program than is Resolution 1929. No specific
sanctions are mandated in the Resolution if Iran conducted missile tests
inconsistent with the Resolution. The JCPOA did not impose any specific
missile-related requirements.
 requires Security Council approval for Iran to export arms or to purchase any
arms (major combat systems named in the Resolution) for a maximum of five
years from Adoption Day (until October 18, 2020). The JCPOA does not impose
arms requirements.
The U.S. withdrawal from the JCPOA did not change the status of Resolution 2231.
Iran Compliance Status
Until August 2019, U.N. and International Atomic Energy Agency reports after the JCPOA began
implementation stated that Iran was complying with its nuclear obligations under the JCPOA.
That assessment was corroborated by U.S. intelligence leaders in January 29, 2019, testimony
before the Senate Select Committee on Intelligence.46 Modest violations that Iran has undertaken
as of mid-2019, which Iran asserts is because it is not getting the benefits of sanctions relief in
light of Trump Administration policy, have been noted in IAEA reports as of August 2019.
U.N. reports on Iranian compliance with Resolution 223147 have noted assertions by several U.N.
Security Council members, including the United States, that Iranian missile tests have been
inconsistent with the Resolution. U.S. officials have called some of Iran’s launches of its
Khorramshahr missile as violations of the Resolution. The reports required by Resolution 2231,
as well as those required by other Resolutions pertaining to various regional crises, such as that in
Yemen, also note apparent violations of the Resolution 2231 restrictions on Iran’s exportation of
arms. The Security Council is responsible for prescribing penalties on Iran for violations, and no
U.N. Security Council actions have been taken against Iran for these violations to date.

46 https://www.dni.gov/index.php/newsroom/congressional-testimonies/item/1947-statement-for-the-record-worldwide-
threat-assessment-of-the-us-intelligence-community.
47 The report is reprinted in, Iran Watch, at http://www.iranwatch.org/library/multilateral-organizations/united-nations/
un-secretary-general/third-report-secretary-general-implementation-security-council-resolution-2231.
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U.N. List of Sanctioned Entities
Under Paragraph 6(c) of Annex B of Resolution 2231, entities sanctioned by the previous Iran-
related Resolutions would continue to be sanctioned until Transition Day (October 2023—eight
years from Adoption Day). One notable person for which U.N. sanctions will end on Transition
Day is IRGC-QF commander Qasem Soleimani. However, some entities (named in an attachment
to the Annex) were immediately “delisted” on Implementation Day—mostly persons and entities
connected to permitted aspects of Iran’s nuclear program and its civilian economy. According to
press reports, two entities not on the attachment list, Bank Sepah and Bank Sepah International
PLC, also were delisted on Implementation Day by separate Security Council action.48 Paragraph
6(c) provides for the Security Council to be able to delist a listed entity at any time, as well as to
add new entities to the sanctions list. Delisted entities are in italics in the table of U.N.-listed
sanctioned entities at the end of the report.
Table 3. Summary of Provisions of U.N. Resolutions on Iran Nuclear Program
(1737, 1747, 1803, 1929, and 2231)
Resolution 2231 superseded all the previous Iran resolutions
Resolution 1737 required Iran to suspend uranium enrichment, to suspend construction of the heavy-water
reactor at Arak, ratify the “Additional Protocol” to Iran’s IAEA Safeguards Agreement. (1737)
Assets frozen of Iranian persons and entities named in annexes to the resolutions, and countries required to ban
the travel of named Iranians. (Initial list in Resolution 1737, and additional designations in subsequent resolutions).
Transfer to Iran of nuclear, missile, and dual use items to Iran prohibited, except for use in light-water reactors
(1737 and 1747). Resolution 2231 delegates to a Joint Commission the authority to approve Iran’s applications to
purchase dual-use items.
Resolution 1747 prohibited Iran from exporting arms. Resolution 2231 requires Iran to obtain Security Council
approval to export arms for a maximum of five years.
Resolution 1929 prohibited Iran from investing abroad in uranium mining, related nuclear technologies or nuclear
capable ballistic missile technology, and prohibits Iran from developing/testing, nuclear-capable ballistic missiles.
1929 mandated that countries not export major combat systems to Iran, but did not bar sales of missiles that are
not on the U.N. Registry of Conventional Arms. Resolution 2231 makes arms sales to Iran and exportation of
arms from Iran subject to approval by the U.N. Security Council, for a maximum of five years from Adoption Day
(until October 2020).
1929 called for restraint on transactions with Iranian banks, particularly Bank Melli and Bank Saderat.
Resolution called for “Vigilance” (but not a ban) on making international lending to Iran and providing trade credits
and other financing.
Resolution 1929 called on countries to inspect cargoes carried by Iran Air Cargo and Islamic Republic of Iran
Shipping Lines—or by any ships in national or international waters—if there are indications they carry cargo
banned for carriage to Iran. Searches in international waters would require concurrence of the country where the
ship is registered. Resolution 2231 requires U.N. member states to continue to enforce all remaining restrictions
on shipment of banned items to Iran.
Prior to JCPOA implementation, a Sanctions Committee, composed of the 15 members of the Security Council,
monitored implementation of all Iran sanctions and collected and disseminated information on Iranian violations
and other entities involved in banned activities. A “panel of experts” was empowered by Resolution 1929 to assist
the U.N. sanctions committee in implementing the resolution and previous Iran resolutions, and to suggest ways to
be more effective.
Source: Text of U.N. Security Council resolutions 1737, 1747, 1803, 1929, and 2231. http://www.un.org.

48 http://www.wsj.com/articles/u-s-signed-secret-document-to-lift-u-n-sanctions-on-iranian-banks-1475193723.
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Sanctions Application under Nuclear Agreements
The following sections discuss sanctions relief provided under the November 2013 interim
nuclear agreement (JPA) and, particularly, the JCPOA.
Sanctions Eased by the JPA
U.S. officials said that the JPA provided “limited, temporary, targeted, and reversible” easing of
international sanctions. Under the JPA (in effect January 20, 2014-January 16, 2016)49
 Iran’s oil customers were not required reduce their oil purchases from Iran
because SREs were issued for Section 1245(d)(1) of the National Defense
Authorization Act for FY2012 (P.L. 112-81) and waivers of Section 1244c(1) of
IFCA were provided. Waivers of ITRSHRA and ISA provisions were issued to
permit transactions with NIOC. The European Union amended its regulations to
allow shipping insurers to provide insurance for ships carrying oil from Iran.50
 A waiver of Section 1245(d)(1) of IFCA allowed Iran to receive directly $700
million per month in hard currency from oil sales and $65 million per month to
make tuition payments for Iranian students abroad (paid directly to the schools).
 Executive Orders 13622 and 13645 and several provisions of U.S.-Iran trade
regulations were suspended. Several sections of IFCA were waived to enable Iran
to sell petrochemicals and trade in gold and other precious metals, and to conduct
transactions with foreign firms involved in Iran’s automotive manufacturing.
 Executive Order 13382 provisions and certain provisions of U.S.-Iran trade
regulations were suspended for equipment sales to Iran Air. The United States
licensed some safety-related repairs and inspections for certain Iranian airlines
and issued a new “Statement of Licensing Policy” to enable U.S. aircraft
manufacturers to sell equipment to Iranian airlines.
 The JPA required that the P5+1 “not impose new nuclear-related sanctions.”51
Sanctions Easing under the JCPOA and U.S. Reimposition
Under the JCPOA, sanctions relief occurred at Implementation Day (January 16, 2016), following
IAEA certification that Iran had completed stipulated core nuclear tasks. U.S. secondary sanctions
were waived or terminated, but most sanctions on direct U.S.-Iran trade. The secondary sanctions
eased during JCPOA implementation included:52 (1) sanctions that limited Iran’s exportation of
oil and sanction foreign sales to Iran of gasoline and energy sector equipment, and which limit
foreign investment in Iran’s energy sector; (2) financial sector sanctions; and (3) sanctions on
Iran’s auto sector and trading in the rial. The EU lifted its ban on purchases of oil and gas from
Iran; and Iranian banks were readmitted to the SWIFT electronic payments system. All U.N.
sanctions were lifted.

49 The Administration sanctions suspensions and waivers are detailed at http://www.state.gov/p/nea/rls/220049.htm.
50 Daniel Fineren, “Iran Nuclear Deal Shipping Insurance Element May Help Oil Sales,” Reuters, November 24, 2013.
51 White House Office of the Press Secretary. “Fact Sheet: First Step Understandings Regarding the Islamic Republic of
Iran’s Nuclear Program,” November 23, 2013.
52 http://iranmatters.belfercenter.org/blog/translation-iranian-factsheet-nuclear-negotiations; and author conversations
with a wide range of Administration officials, think tank, and other experts, in Washington, DC, 2015.
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All of the U.S. sanctions that were eased went back into effect by November 5, 2018, in
accordance with the U.S. withdrawal from the JCPOA. The Administration has stated that the
purpose of reimposing the sanctions is to deny Iran the revenue with which to conduct regional
malign activities and advance its missile, nuclear, and conventional weapons programs.
The sanctions that went back into effect on August 7, 2018 (90-day wind-down period), were on
 the purchase or acquisition of U.S. bank notes by Iran;
 Iran’s trade in gold and other precious metals;
 transactions in the Iranian rial;
 activities relating to Iran’s issuing of sovereign debt;
 transactions with Iran in graphite, aluminum, steel, coal, and industrial software;
 importation of Iranian luxury goods to the United States; and
 the sale to Iran of passenger aircraft (and aircraft with substantial U.S. content).
The sanctions that went back into effect on November 5, 2018, were on
 petroleum-related transactions with Iran.
 port operators and energy, shipping, and shipbuilding sectors; and
 transactions by foreign banks with Iran’s Central Banks (including the provision
that restricts Iran’s access to hard currency held in banks abroad).
U.S. Laws and Executive Orders Affected by the JCPOA53
The laws below were waived to implement the JCPOA.
 Iran Sanctions Act. The blanket energy/economic-related provisions of the ISA of
P.L. 104-172, as amended. (Section 4(c)(1)(A) waiver provision.) The WMD-
related provision of ISA was not waived.
 FY2012 NDAA. Section 1245(d) of the National Defense Authorization Act for
FY2012 (P.L. 112-81) imposing sanctions on foreign banks of countries that do
not reduce Iran oil imports.
 Iran Threat Reduction and Syria Human Rights Act (P.L. 112-158). Sections 212
and 213—the economy-related provisions of the act. Human rights-related
provisions were not waived.
 Iran Freedom and Counter-proliferation Act. Sections 1244, 1245, 1246, and
1247 of the Act (Subtitle D of P.L. 112-239) were waived.
 Executive Orders: 13574, 13590, 13622, 13645, and Sections 5-7 and 15 of
Executive Order 13628 were revoked outright by Executive Order 13716.54 The
orders were reimposed and superseded on August 6, 2018, by Executive Order
13846.
 The core provision of CISADA (P.L. 111-195) that sanctions foreign banks was
not waived to implement the JCPOA, but most listed Iranian banks were

53 http://www.politico.com/story/2015/07/full-text-iran-deal-120080.html.
54 For more information on these Executive Orders and their provisions, see CRS Report RS20871, Iran Sanctions, by
Kenneth Katzman; and CRS Report R43311, Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions, by
Dianne E. Rennack.
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“delisted” to implement the JCPOA, thereby mooting this CISADA provision.
All delisted Iranian banks were relisted on November 5, 2018.
 The United States delisted the specified Iranian economic entities and
personalities listed in Attachment III of the JCPOA, including the National
Iranian Oil Company (NIOC), various Iranian banks, and many energy and
shipping-related institutions. That step enabled foreign companies/banks to
resume transactions with those entities without risking being penalized by the
United States. The tables at the end of the report depict in italics those entities
delisted. Entities that were to be delisted on “Transition Day” (October 2023) are
in bold type. The Administration relisted these entities for secondary sanctions,
with selected exceptions (such as the AEOI and 23 subsidiaries), on November 5,
2018. The continued de-listing of the nuclear entities was in order to allow
European and other U.S. partners to continue providing civilian nuclear
assistance to Iran as permitted under the JCPOA.
 The JCPOA required the U.S. Administration, by “Transition Day,” to request
that Congress lift virtually all of the sanctions that were suspended under the
JCPOA. No outcome of such a request is mandated. Mooted by U.S. withdrawal.
 The JCPOA requires U.N. sanctions on persons and entities still designated for
U.N. sanctions to terminate on Transition Day (October 2023, eight years after
Adoption Day). All U.N. sanctions are to terminate by “Termination Day”
(October 2025, ten years after Adoption Day).
Exceptions and Waivers Provided by the Trump Administration
Even though it has reimposed all U.S. sanctions on Iran, the Trump Administration has issued
some exceptions that are provided for under the various U.S. sanctions laws:
 As noted above, on November 5, 2018, eight countries were given the SRE to
enable them to continue transactions with Iran’s Central Bank and to purchase
Iranian oil. On April 22, the Administration announced termination of the SREs
as of their expiration on May 2, 2019.
 On May 3, the Administration ended two waivers under IFCA that enabled
foreign entities to remove Iran’s LEU that exceeds the 300kg allowed stockpile,
and to buy Iran’s heavy water that exceeded the limits on that product. The
waiver limitations also prohibit the expansion of the Bushehr civilian nuclear
power reactor. Five other waivers that enable other work with the JCPOA-
permitted aspects of Iran’s nuclear program were extended in August 2019, for
another 90 days.
 The Administration has waived Section 1247(e) of IFCA to enable Iraq to
continue paying for purchases of natural gas from Iran. The waiver term can be
as long as 180 days, but the Administration has been providing 90-day waivers.
 The Administration has issued the permitted IFCA exception for Afghan
reconstruction to enable India to continue work at Iran’s Chahbahar Port. A U.S.
State Department official told Afghan leaders in mid-May 2019 that the
exception would continue.
 The Administration has renewed the licenses of certain firms to enable them to
continue developing the Rhum gas field in the North Sea that Iran partly owns.
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U.S. Sanctions that Remained in Place during JCPOA and Since
The JCPOA did not commit the United States to suspend U.S. sanctions on Iran for terrorism or
human rights abuses, on foreign arms sales to Iran or sales of proliferation-sensitive technology
such as ballistic missile technology, or on U.S.-Iran direct trade (with the selected exceptions
discussed above). The sanctions below remained in place during JCPOA implementation:
 E.O. 12959, the ban on U.S. trade with and investment in Iran;
 E.O. 13224 sanctioning terrorism entities, any sanctions related to Iran’s
designation as a state sponsor or terrorism, and any other terrorism-related
sanctions. The JCPOA does not commit the United States to revoke Iran’s
placement on the terrorism list;
 E.O. 13382 sanctioning entities for proliferation;
 the Iran-Iraq Arms Non-Proliferation Act;
 the Iran-North Korea-Syria Non-Proliferation Act (INKSNA);55
 the section of ISA that sanctions WMD- and arms-related transactions with Iran;
 E.O. 13438 on Iran’s interference in Iraq and E.O. 13572 on repression in Syria;
 Executive Orders (E.O. 13606 and E.O. 13628) and the provisions of CISADA,
ITRSHRA, and IFCA that pertain to human rights or democratic change in Iran;
 all sanctions on the IRGC, military, proliferation-related, and human rights- and
terrorism-related entities, which were not “delisted” from sanctions;
 Treasury Department regulations barring Iran from access to the U.S. financial
system. Foreign banks can pay Iran in dollars if they use only an existing dollar
supply; the Treasury Department revised its guidance in October 2016 to stress
that such transactions are permitted.56
Other Mechanisms to “Snap-Back” Sanctions on Iran
Sanctions might have been reimposed by congressional action in accordance with President
Trump’s withholding of certification of Iranian compliance with the JCPOA, under the Iran
Nuclear Agreement Review Act (INARA, P.L. 114-17). Certification was withheld in October
2017 and January and April of 2018, but Congress did not act to reimpose sanctions that were
suspended.57
The JCPOA (paragraph 36 and 37) contains a mechanism for the “snap back” of U.N. sanctions if
Iran does not satisfactorily resolve a compliance dispute. According to the JCPOA (and
Resolution 2231), the United States (or any veto-wielding member of the U.N. Security Council)
would have been able to block a U.N. Security Council resolution that would continue the lifting
of U.N. sanctions despite Iran’s refusal to resolve the dispute. In that case “... the provisions of
the old U.N. Security Council resolutions would be reimposed, unless the U.N. Security Council
decides otherwise.” The United States is no longer a participant in the JCPOA, and the snap-back

55 The JCPA does commit the United States to terminate sanctions with respect to some entities designated for
sanctions under INKSNA.
56 https://www.treasury.gov/resource-center/sanctions/Programs/Documents/jcpoa_faqs.pdf.
57 For more information on this option, see CRS Report R44942, U.S. Decision to Cease Implementing the Iran
Nuclear Agreement, by Kenneth Katzman, Paul K. Kerr, and Valerie Heitshusen.
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link to page 81 Iran Sanctions

mechanisms of the JCPOA can be formally initiated by current participants through the Joint
Commission, on which the United States no longer sits.
International Implementation and Compliance58
During 2010-2016, converging international views on Iran’s expanding nuclear program
produced global consensus to pressure Iran through sanctions. Some countries asserted that
imposing global sanctions would head off unwanted U.S. or other military action against Iran,
whereas others cooperated with sanctions primarily in order to preserve their close relationships
with the United States. All the JCPOA parties publicly opposed the U.S. decision to exit the
JCPOA and have sought to continue to provide the JCPOA’s economic benefits to Iran. A
comparison between U.S., U.N., and EU sanctions against Iran is contained in Table A-1 below.
Broader issues of Iran’s foreign relations can be found in CRS Report R44017, Iran’s Foreign
and Defense Policies, by Kenneth Katzman.
European Union (EU)
After the passage of Resolution 1929 in June 2010, European Union (EU) sanctions on Iran
became nearly as extensive as those of the United States. This contrasted with the 1990s, when
the EU countries refused to join the 1995 U.S. trade and investment ban on Iran and agreed to
reschedule $16 billion in Iranian debt bilaterally. In July 2002, Iran’s Islamic regime tapped
international capital markets for the first time, selling $500 million in bonds to European banks
and, during 2002-2005, there were negotiations between the EU and Iran on a “Trade and
Cooperation Agreement” (TCA) that would have benefitted Iranian exports to the EU countries.59
Under the JCPOA, EU sanctions that were imposed in 2012, were lifted, including the following:
 the ban on oil and gas imports from Iran.
 a ban on insurance for shipping oil or petrochemicals from Iran and a freeze on
the assets of several Iranian firms involved in shipping.
 a ban on trade with Iran in gold, precious metals, diamonds, and petrochemicals.
 a freeze of the assets of Iran’s Central Bank (except for approved civilian trade).
 a ban on transactions between European and all Iranian banks and on short-term
export credits, guarantees, and insurance.
 a ban on exports to Iran of graphite, semi-finished metals, industrial software,
shipbuilding technology, oil storage capabilities, and flagging or classification
services for Iranian tankers and cargo vessels.
 a large number of entities that had been sanctioned by EU Council decisions and
regulations over the years were “delisted” by the EU on Implementation Day.
The following EU sanctions remained in place:
 an embargo on sales to Iran of arms, missile technology, other proliferation-
sensitive items, and gear for internal repression.

58 Note: CRS has no mandate or capability to “judge” compliance of any country with U.S. or other sanctions against
Iran. This section is intended to analyze some major trends in third country cooperation with U.S. sanctions.
59 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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 a ban on Iranian persons and entities designated for human rights abuses or
supporting terrorism from visiting EU countries, and a freeze on their EU-based
assets (see Table C-1below).
EU Divestment in Concert with Reimposition of U.S. Sanctions
The EU countries have not reimposed sanctions on Iran and instead have sought to preserve the
JCPOA by maintaining economic relations with Iran. However, to avoid risk to their positions in
the large U.S. market, many large European firms have ceased Iran-related transactions or exited
the Iran market entirely, as discussed below.60
 Cars. Renault and Citroen of France suspended their post-JCPOA $1 billion
investments in a joint venture with two Iranian firms to boost Renault’s car
production capacity in Iran to 350,000 cars per year. On August 6, 2018, Daimler
(manufacturer of Mercedes Benz autos) announced it was suspending its
activities in Iran.
 Buses. Scania of Sweden, which is owned by Volkswagen of Germany,
established a factory in Iran to supply the country with 1,350 buses, but it is not
clear whether this venture is still operating. Volvo halted truck assembly in Iran
as of late 2018.
 Other Industry. German industrial giant Siemens signed an agreement in March
2016 with Iranian firm Mapna to transfer technology to produce gas turbines in
Iran, and other contracts to upgrade Iran’s railways. Siemens said in late 2018
that it would pursue no new Iranian business. Italy’s Danieli industrial
conglomerates and Gruppo Ventura have exited the Iranian market.
 Banking. Several banks have announced since the U.S. JCPOA exit a cessation of
transactions with Iran: DZ Bank and Allianz of Germany; Oberbank of Austria;
and Banque Wormser Freres of France. In July 2018, at U.S. request, Germany’s
central bank (Deutsche Bundesbank) introduced a rule change that blocked Iran’s
withdrawal of $400 million in cash from the Europaische-Iranische Handlesbank
(EIH). EIH is reportedly at least partly owned by Iran and has often partnered on
transactions with the Bundesbank. (EIH was “de-listed” from sanctions by the
United States to implement the JCPOA, but was relisted on November 5, 2018.)61
 Energy. No EU state has bought Iranian oil since U.S. energy sanctions went
back into effect in November 2018, even though Italy and Greece were given
SRE sanctions exemptions from November 5, 2018, until May 2, 2019.
Regarding energy investments: Total SA has exited a nearly $5 billion energy
investment in South Pars gas field, and it is transferring its stake to its joint
venture partner, China National Petroleum Corporation. As noted above,
European countries have reduced their purchases of Iranian oil. OMV of Austria
has announced it would halt energy development work. Norway’s Saga Energy
(Norway is not in the EU) signed a $3 billion deal to build solar power plants in
Iran, and Italy’s FS signed a $1.4 billion agreement to build a high speed railway
between Qom and Arak. These deals are still active.
 Shipping. Hapag-Lloyd of Germany and Denmark’s AP Moller-Maersk have
ceased shipping services to Iran.

60 “Iran Nuclear Deal: The EU’s Billion-Dollar Deals at Risk,” BBC News, May 11, 2018.
61 Germany’s Central Bank Imposes Rule to Stop Cash Delivery to Tehran. Jerusalem Post, August 6, 2018.
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 Telecommunications. Germany telecommunications firm Deutsche Telekom
announced in September 2018 that it would end its business in Iran.
 Flights. Although air service is not subject to U.S. sanctions, Air France and
British Air announced in September 2018 that they would cease service to Iran
due to lack of demand.
 Rhum Gas Field. One project, the Rhum gas field in the North Sea that is partly
owned by Iranian Oil Company (a subsidiary of NIOC), has been able to
continue operating. In part because the field supplies about 5% of Britain’s
demand for natural gas, in October 2018, the Trump Administration renewed the
license of BP and Serica Energy to continue providing goods and services to the
field, despite the Iranian involvement in the project.62
European Special Purpose Vehicle/INSTEX and Credit Line Proposal
The EU countries continue to try to preserve the JCPOA in the face of the Trump
Administration’s maximum pressure policy on Iran. On August 6, 2018, a 1996 EU “blocking
statute” that seeks to protect EU firms from reimposed U.S. sanctions took effect. In September
2018, EU countries announced a small amount ($20 million) of development assistance to Iran.
To try to circumvent U.S. sanctions, in September 2018, Germany, France, and Britain, joined by
Russia and China, as well as Iran, endorsed the creation of a “special purpose vehicle” (SPV) that
would facilitate trade with Iran by avoiding dollar-denominated transactions or other exposure to
the U.S. market. In a January 31, 2019, joint statement, France, Britain, and Germany announced
the formal registration of the SPV, named the “Instrument for Supporting Trade Exchanges”
(INSTEX). It is based in France, with German governance, and financial support from the three
governments. Its initial focus is the non-sanctionable sectors most essential to Iran, including
medicines, medical devices, and food, but it might eventually expand to oil and other products.63
In April 2019, Iran set up the required counterparty—the “Special Trade and Finance Instrument”
(STFI).
Senior U.S. officials criticized INSTEX as an outright attempt to undermine U.S. sanctions
against Iran. Indicative of U.S. pressure on the EU not to begin INSTEX operations, on May 7,
2019, Treasury Department Under Secretary for Terrorism and Financial Intelligence Sigal
Mandelker said that INSTEX is unlikely to fulfill EU pledges to prevent INSTEX from being
used by Iran to launder money or fund terrorism. The U.S. concerns about INSTEX might be a
product, at least in part, of the alleged involvement of some U.S.-sanctioned Iranian banks in
Iran’s STFI, and U.S. officials reportedly are considering sanctioning this entity.64 INSTEX has
begun processing but has not completed any transactions, and senior Iranian officials have
criticized INSTEX as ineffective and failing to satisfy Iranian demands to receive the economic
benefits of the JCPOA. As a major incentive discussed publicly at the August 2019 G-7 summit in
Biarritz, France, French President Emmanuel Macron is leading a drive to provide a $15 billion
credit line for Iran to purchase goods through INSTEX, with the credit line to be secured by
future Iranian oil deliveries—in exchange for Iran’s returning to full compliance with the JCPOA.
The proposal apparently is subject to U.S. concurrence, although it is not clear that any U.S.
sanctions would apply to such a credit line, whose funds would go to European exporters, not to

62 “U.S. Grants BP, Serica License to Run Iran-Owned North Sea Field.” Reuters, October 9, 2018.
63 https://www.gov.uk/government/news/joint-statement-on-the-new-mechanism-to-facilitate-trade-with-iran.
64 https://www.fdd.org/analysis/2019/05/16/sanctions-alert-irans-new-financial-channel-with-europe-is-linked-to-
sanctioned-entities/.
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Iran’s Central Bank or any Iranian bank. Although President Trump appeared open to the plan at
the G-7 summit, U.S. officials have since signaled opposition to the credit line proposal while
noting that the proposal has not been finalized.65
EU Antiterrorism and Anti-proliferation Actions
While attempting to preserve civilian economic engagement with Iran, the European countries
have sought to support U.S. efforts to counter Iran’s terrorism and proliferation activities.
 In December 2018, Albania expelled Iran’s ambassador and one other Iranian
diplomat for involvement in a terrorism plot that was thwarted.
 In January 2019, the EU added Iran’s intelligence service (MOIS) and two
intelligence operatives to its terrorism-related sanctions list in response to
allegations of Iranian terrorism plotting in Europe.
 Germany followed that move by denying landing rights to Iran’s Mahan Air,
which the United States has designated as a terrorism supporting entity.
SWIFT Electronic Payments System
The management of the Brussels-based Swift electronic payments system has sought to balance
financial risks with the policies of the EU governments. In March 2012, SWIFT acceded to an EU
request to expel 14 EU-sanctioned Iranian banks.66 Some Iranian banks were still able to conduct
electronic transactions with the European Central Bank via the “Target II” system. Even though
the EU has not reimposed sanctions on Iran in concert with the Trump Administration, SWIFT’s
board is independent and, in order to avoid risk of U.S. penalties, in late 2018, the system again
disconnected the Iranian banks that were “relisted” for U.S. sanctions.
China and Russia
Russia and China, two permanent members of the U.N. Security Council and parties to the
JCPOA, historically have imposed only those sanctions required by Security Council resolutions.
Both governments opposed the U.S. withdrawal from the JCPOA.
Russia
Increasingly close politically primarily on the issue of the conflict in Syria, Iran and Russia have
discussed expanding energy and trade cooperation, but there is little hard data on implementation
of any agreements. The two countries reportedly agreed on broad energy development deals
during President Putin’s visit to Tehran in late October 2017, with an estimated investment value
of up to $30 billion. In December 2018, Iran signed a free trade deal with the Russia-led
“Eurasian Economic Union,” suggesting Russian intent to potentially circumvent U.S. sanctions
on Iran. Russia has reportedly offered Iranian ships access to its ports to deliver oil as a means of
avoiding U.S. efforts to sanction Iranian oil sales.67
In April 2015, Russia lifted its own restriction on delivering the S-300 air defense system that it
sold Iran in 2007 but refused to deliver after Resolution 1929 was adopted—even though that

65 Trump Administration cool to French plan for $15 billion Iranian credit line: officials. Reuters, September 4, 2019;
Press briefing by Ambassador Brian Hook. September 4, 2019.
66 Avi Jorish, “Despite Sanctions, Iran’s Money Flow Continues,” Wall Street Journal, June 25, 2013.
67 Crimea Invites Iran to Use Its Ports as a U.S. Sanctions Workaround – Official. Moscow Times, September 2, 2019.
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Resolution technically did not bar supply of that defensive system. In April 2016, Russia began
delivering the five S-300 batteries. Iran’s Defense Minister visited Russia in February 2016 to
discuss possible future purchases of major combat systems, presumably to be consummated after
the U.N. arms import ban on Iran expires in October 2020.
China
China is a major factor in the effectiveness of any sanctions regime on Iran because China
remains Iran’s largest oil customer. During 2012-2016, China was instrumental in reducing Iran’s
total oil exports because it cut its buys from Iran to about 435,000 barrels per day from its 2011
average of 600,000 barrels per day. The State Department asserted that, because China was the
largest buyer of Iranian oil, percentage cuts by China had a large impact in reducing Iran’s oil
sales by volume and China merited an SRE. After sanctions were lifted in early 2016, China
increased its purchases of Iranian oil beyond 2011 levels. Iran’s automotive sector obtains a
significant proportion of its parts from China, including from China-based Geelran and Chery
companies.
Since the reimposition of U.S. sanctions, China has reduced its oil imports from Iran, but it
remains the largest single buyer (see Table 1). The Administration gave China a SRE sanctions
exception on November 5, 2018. China continues to import at least some Iranian oil despite the
ending of the SRE as of May 2, 2019, in large part on the expectation that the Trump
Administration will be hesitant to impose actual sanctions on Chinese banks for continuing to
engage with Iran on oil payments. However, on July 23, 2019, the Administration did sanction
(under IFCA) a small Chinese firm, Zhuhai Zhenrong Company Ltd., for buying oil from Iran.68
Prior to the expiration of the SREs, China had stockpiled 20 million barrels of Iranian oil at its
Dalian port,69 and importation of that oil might avoid customs checkpoints and not be counted in
major oil industry assessments of China imports of Iranian oil.
China also remains a large investor in Iran. Several Chinese energy firms that invested in Iran’s
energy sector put those projects on hold in 2012, but resumed work after sanctions were eased in
2016 and continued that work despite the reimposition of U.S. sanctions. China’s President Xi
Jinping visited Iran and other Middle East countries in the immediate aftermath of the JCPOA,
and he has stated that Iran is a vital link in an effort to extend its economic influence westward
through its “One Belt, One Road” initiative. Chinese firms and entrepreneurs are integrating Iran
into this vision by modernizing Iran’s rail and other infrastructure, particularly where that
infrastructure links to that of neighboring countries, including the Sultanate of Oman, funded by
loans from China.70 In August 2019, Iran and China expanded their 2016 25 year deal for China
investments in Iran to total: $280 billion to be invested in Iran’s oil, gas, and petrochemical
sectors, and $120 billion in upgrading Iran’s transport and manufacturing infrastructure.71
However, U.S. sanctions complicate Iran-China economic ties. China’s Kunlun Bank—an
affiliate of China’s energy company CNPC and which was sanctioned under CISADA in 2012 as
the main channel for money flows between the two countries—reportedly stopped accepting Euro

68 “The United States to Impose Sanctions on Chinese Firm Zhuhai Zhenrong Company Limited for Purchasing Oil
from Iran. Department of State. July 22, 2019.
69 “Boxed In: $1 billion of Iranian Crude Sits at China’s Dalian Port. Reuters. May 1, 2019.
70 Thomas Erdbrink. “China’s Push to Link East and West Puts Iran at ‘Center of Everything.’” New York Times, July
25, 2017.
71 China and Iran Flesh Out Strategic Partnership. Petroleum Economist, September 3, 2019.
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and then China currency-denominated payments from Iran in November 2018.72 Existing Iranian
accounts at the bank presumably can still be used to pay for Iranian imports from China. Iran is
reluctant to tap; an Iran-China hard currency escrow account, with an estimated value of about
$20 billion, to pay for China’s infrastructure projects in Iran, such as the long Niayesh Tunnel.
In April 2018, the Commerce Department (Bureau of Industry and Security, BIS, which
administers Export Administration Regulations) issued a denial of export privileges action against
China-based ZTE Corporation and its affiliates. The action was taken on the grounds that ZTE
did not uphold the terms of March 2017 settlement agreement with BIS over ZTE’s shipment of
prohibited U.S. telecommunications technology to Iran (and North Korea). On March 27, 2019,
OFAC announced a $1.9 million settlement with a Chinese subsidiary of the U.S. Black and
Decker tool company for unauthorized exports of tools and parts to Iran.73
Japan/Korean Peninsula/Other East Asia
During 2010-2016, Japan and South Korea enforced sanctions on Iran similar to those imposed
by the United States and the EU. Both countries cut imports of Iranian oil sharply after 2011, and
banks in the two countries restricted Iran’s ability to repatriate the foreign exchange assets Iran
held in their banks. From 2016-2018, both countries increased importation of Iranian oil, and Iran
was able to access funds in banks in both countries.
Both countries—and their companies—have historically been unwilling to undertake transactions
with Iran that could violate U.S. sanctions, and firms in both countries have exited the Iran
market. Both countries reduced their Iranian oil purchases to zero in October 2018 and both
countries received SRE sanctions exceptions on November 5. In early 2019, Japan imported some
Iranian oil importation in early 2019, and South Korea purchased about 200,000 barrels per day
of Iranian condensates. Upon expiration of its SRE in May 2019, South Korea sought, but was
denied, Administration concurrence to continue to import Iranian condensates (a petroleum
product sometimes considered as crude oil), on which South Korea depends. South Korea is
replacing Iranian condensates supplies with those of Qatar and Australia.
Japan exports to Iran significant amounts of chemical and rubber products, as well as consumer
electronics. South Korean firms have been active in energy infrastructure construction in Iran,
and its exports to Iran are mainly iron, steel, consumer electronics, and appliances—meaning that
South Korea could be affected significantly by the May 2019 executive order sanctioning
transactions with Iran’s minerals and metals sector.
The following firms have announced their postures following the U.S. exit from the JCPOA:
 Daelim of South Korea terminated a $2 billion contract to expand an Iranian oil
refinery. In late October, Hyundai cancelled a $500 million contract to build a
petrochemical plant in Iran, citing “financing difficulties.”
 Car companies Mazda and Toyota of Japan and Hyundai of South Korea have
suspended joint ventures to produce cars in Iran.
 Among banks, South Korea’s Woori Bank and Industrial Bank of Korea are
complying with U.S. sanctions. Woori Bank is using an Iran Central Bank

72 “As U.S. Sanctions Loom, China’s Bank of Kunlun to Stop Receiving Iran Payments—Sources.” Reuters, October
23, 2018.
73 OFAC Crystallizes Expectations for Sanctions Compliance. April 1, 2019.
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account held there to process payments only for South Korean humanitarian
goods sold to Iran.74 Nomura Holdings of Japan has taken a similar position.
 The South Korean conglomerate POSCO withdrew from a 2016 deal to build a
steel plant in Iran’s free trade zone at the port of Chahbahar.
North Korea
North Korea, like Iran, has been subject to significant international sanctions. North Korea has
never pledged to abide by international sanctions against Iran, and it reportedly cooperates with
Iran on a wide range of WMD-related ventures, particularly the development of ballistic missiles.
A portion of the oil that China buys from Iran (and from other suppliers) is reportedly sent to
North Korea, but it is not known if North Korea buys any Iranian oil directly. The potential for
North Korea to try to buy Iranian oil illicitly increased in the wake of the adoption in September
2017 of U.N. Security Council sanctions that limit North Korea’s importation of oil, but there are
no publicly known indications that it is doing so. While serving as Iran’s president in 1989, the
current Supreme Leader, Ayatollah Ali Khamene’i, visited North Korea. North Korea’s then-
titular head of state attended President Rouhani’s second inauguration in August 2017, and signed
various technical cooperation agreements of unspecified scope.75
Taiwan and Singapore
Taiwan has generally been a small buyer of Iranian oil. It resumed imports of Iranian oil after
sanctions were eased in 2016. Taiwan received an SRE as of November 5, 2018, but has bought
no Iranian oil since late 2018.
Singapore has been a small buyer of Iranian oil. It has not bought any Iranian oil since U.S.
sanctions went back into effect in 2018.
South Asia
India
India cites U.N. Security Council resolutions as justification for its stances on Iran. During 2011-
2016, with U.N. sanctions in force on Iran, India’s private sector assessed Iran as a “controversial
market”—a term describing reputational and financial risk. India’s central bank ceased using a
Tehran-based regional body, the Asian Clearing Union, to handle transactions with Iran, and the
two countries agreed to settle half of India’s oil buys from Iran in India’s currency, the rupee. Iran
used the rupee accounts to buy India’s wheat, pharmaceuticals, rice, sugar, soybeans, auto parts,
and other products.
India reduced its imports of Iranian oil substantially after 2011, in the process incurring
significant costs to retrofit refineries that were handling Iranian crude. However, after sanctions
were eased in 2016, India’s oil imports from Iran increased to as much as 800,000 bpd in July
2018—well above 2011 levels. Indian firms resumed work that had been ended or slowed during
2012-2016. India also paid Iran the $6.5 billion it owed for oil purchased during 2012-2016.76

74 Author conversations with South Korean officials. 2019.
75 https://www.thedailybeast.com/north-koreas-deadly-partnership-with-iran.
76 “India Seeks to Pay $6.5 Billion to Iran for Oil Imports.” Economic Times of India. May 16, 2016.
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India’s cooperation with reimposed U.S. sanctions since 2018 is mixed, in part because no U.N.
sanctions have been reimposed.77In June 2018, the two countries again agreed to use rupee
accounts for their bilateral trade. After India’s SRE, last granted in November 2018, expired in
May 2019, it was widely expected that India and Iran would work out alternative payment
arrangements under which India will continue importing at least some Iranian oil. Indian officials
said in May 2019 that India would comply with U.S. sanctions and find alternative suppliers, and
India’s import of Iranian oil have been zero since the end of April 2019.
In 2015, India and Iran agreed that India would help develop Iran’s Chahbahar port that would
enable India to trade with Afghanistan unimpeded by Pakistan. With sanctions lifted, the project
no longer entails risk to Indian firms involved. In May 2016, Indian Prime Minister Narendra
Modi visited Iran and signed an agreement to invest $500 million to develop the port and related
infrastructure. As noted above, the Administration has utilized the “Afghanistan reconstruction”
exception under Section 1244(f) of IFCA to allow for firms to continue developing it.
Construction at the port is proceeding, but India reportedly has reduced the pace and scope of
construction work on the port in light of the complications that U.S. sanctions place on
conducting business with Iran.78
Pakistan
One test of Pakistan’s compliance with sanctions was a pipeline project that would carry Iranian
gas to Pakistan—a project that U.S. officials on several occasions stated would be subject to ISA
sanctions. Despite that threat, agreement on the $7 billion project was finalized on June 12, 2010,
and construction was formally inaugurated in a ceremony attended by the Presidents of both
countries on March 11, 2013. Iran reportedly completed the pipeline on its side of the border.
China’s announcement in April 2015 of a $3 billion investment in the project seemed to remove
financial hurdles to the line’s completion, and the JCPOA removed sanctions impediments to the
project.79 However, during President Hassan Rouhani’s visit to Pakistan in March 2016, Pakistan
still did not commit to complete the line, and observers note that there are few indications of
progress on the project. In 2009, India dissociated itself from the project over concerns about the
security of the pipeline, the location at which the gas would be transferred to India, pricing of the
gas, and tariffs.
Turkey/South Caucasus
Iran has substantial economic relations with Turkey and the countries of the South Caucasus.
Turkey
During periods when U.S. sanctions did not apply, Turkey bought about 40% of its oil from Iran.
Turkey reduced purchases of Iranian oil during 2012-2016, but its buys returned to 2011 levels
after sanctions on Iran were eased in 2016. Turkey received an SRE sanctions exemption on
November 5, 2018, and its officials strongly indicated in April 2019 that Turkey expected to
receive another SRE as of the May 2, 2019, expiration. Turkey’s insistence on being allowed to
buy Iranian oil without fear of U.S. penalty—as well as its overall dependence on Iranian oil—
underpin a decision by Turkey to continue buying at least some Iranian oil.

77 CRS conversations with Indian officials and U.S. experts on India. 2017-18.
78 https://thewire.in/diplomacy/chabahar-us-iran-ties-india.
79 Asia Times, March 21, 2014, http://www.atimes.com/atimes/South_Asia/SOU-02-210314.html.
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Turkey, which buys about 6% of its total gas imports from Iran, is Iran’s main gas customer via a
pipeline built in 1997, which at first was used for a swap arrangement under which gas from
Turkmenistan was exported to Turkey. Direct Iranian gas exports to Turkey through the line
began in 2001, but no ISA sanctions were imposed on the grounds that the gas supplies were
crucial to Turkey’s energy security. Prior to the October 2012 EU ban on gas purchases from Iran,
this pipeline was a conduit for Iranian gas exports to Europe (primarily Bulgaria and Greece).
Pre-JCPOA, in response to press reports that Turkey’s Halkbank was settling Turkey’s payments
to Iran for energy with gold, U.S. officials testified on May 15, 2013, that the gold going from
Turkey to Iran consists mainly of Iranian private citizens’ purchases of Turkish gold to hedge
against the value of the rial. A U.S. criminal case involved a dual Turkish-Iranian gold dealer,
Reza Zarrab, arrested in the United States in 2016 for allegedly violating U.S. sanctions
prohibiting helping Iran deal in precious metals. In November 2016, the U.S. Attorney for New
York’s Southern District indicted several individuals for using money services businesses in
Turkey and in the UAE for conspiring to conceal from U.S. banks transactions on behalf of and
for the benefit of sanctioned Iranian entities, including Mahan Air.80 On January 6, 2014, the
Commerce Department blocked a Turkey-based firm (3K Aviation Consulting and Logistics)
from re-exporting two U.S.-made jet engines to Iran’s Pouya Airline.81
Caucasus and Caspian Sea
The rich energy reserves of the Caspian Sea create challenges for U.S. efforts to deny Iran
financial resources. The Clinton and George W. Bush Administrations cited potential ISA
sanctions to deter oil pipeline routes involving Iran—thereby successfully promoting an the
alternate route from Azerbaijan (Baku) to Turkey (Ceyhan), which became operational in 2005.
Section 6 of Executive Order 13622 exempts from sanctions any pipelines that bring gas from
Azerbaijan to Europe and Turkey.
Agreements reached in 2018 between Russia and the Caspian Sea states on the legal division of
the sea could spawn new energy development in the Caspian. Iran’s energy firms will
undoubtedly become partners in eventual joint ventures to develop the Caspian’s resources.
Iran and Azerbaijan have in recent years tried to downplay political differences for joint economic
benefit, and they have been discussing joint energy and infrastructure projects among themselves
and with other powers, including Russia. Iran and Armenia—Azerbaijan’s adversary—have long
enjoyed extensive economic relations: Armenia is Iran’s largest gas customer, after Turkey. In
May 2009, Iran and Armenia inaugurated a natural gas pipeline between the two, built by
Gazprom of Russia. No determination of ISA sanctions was issued. Armenia has said its banking
controls are strong and that Iran is unable to process transactions illicitly through Armenia’s
banks.82 However, observers in the South Caucasus assert that Iran has used Armenian banks
operating in the Armenia-occupied Nagorno-Karabakh territory to circumvent international
financial sanctions.83

80 https://www.justice.gov/usao-sdny/pr/manhattan-united-states-attorney-announces-superseding-indictment-charging-
turkish-and.
81 “US Acts to Block Turkish Firm from Sending GE Engines to Iran,” Reuters, January 6, 2014.
82 Louis Charbonneau, “Iran Looks to Armenia to Skirt Banking Sanctions,” Reuters, August 21, 2012.
83 Information provided to the author by regional observers. October 2013.
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Persian Gulf States and Iraq84
The Gulf Cooperation Council states (GCC: Saudi Arabia, UAE, Qatar, Kuwait, Bahrain, and
Oman) are oil exporters and close allies of the United States. As Iranian oil exports decreased
after 2012, the Gulf states supplied the global oil market with additional oil. Since the U.S. exit
from the JCPOA, U.S. officials have worked with Gulf oil exporters to ensure that the global oil
market is well supplied even as Iranian oil exports fall. And the State Department’s SRE
announcement on April 22, 2019, indicated that the Administration is looking to Saudi Arabia and
the UAE, in particular, to keep the global oil market well supplied after SREs end on May 2,
2019. Still, in order not to antagonize Iran, the Gulf countries maintain relatively normal trade
with Iran. Some Gulf-based shipping companies, such as United Arab Shipping Company
reportedly continued to pay port loading fees to such sanctioned IRGC-controlled port operators
as Tidewater.85
The UAE has attracted U.S. scrutiny because of the large presence of Iranian firms there, and
several UAE-based firms have been sanctioned, as noted in the tables at the end of the report.
U.S. officials praised the UAE’s March 1, 2012, ban on transactions with Iran by Dubai-based
Noor Islamic Bank, which Iran reportedly used to process oil payments. Some Iranian gas
condensates (120,000 barrels per day) were imported by Emirates National Oil Company
(ENOC) and refined mostly into jet fuel. Subsequent to the May 8, 2018, U.S. exit from the
JCPOA, ENOC officials said they were trying to find alternative supplies of the hydrocarbon
products it buys from Iran.86 The Wall Street Journal reported on September 8, 2019 that the UAE
had recently taken delivery of some Iranian oil and that some of Iran’s petrochemical sales have
been routed through the UAE.87
Iran and several of the Gulf states have had discussions on various energy and related projects,
but few have materialized because of broad regional disputes between Iran and the Gulf states.
Qatar and Iran share the large gas field in the Gulf waters between them, and their economic
relations have become closer in light of the isolation of Qatar by three of its GCC neighbors,
Saudi Arabia, UAE, and Bahrain.
Iran and Oman have active economic relations. Iran and Oman have an active joint venture to
expand Oman’s Al Duqm port, which is envisioned as a major hub for regional trade. Among the
projects that have not materialized are a Kuwait-Iran 350-mile pipeline that would bring Iranian
gas to Kuwait, and venture under which Bahrain would purchase Iranian gas. Omani banks, some
of which operate in Iran, were used to implement some of the financial arrangements of the JPA
and JCPOA.88 As a consequence, a total of $5.7 billion in Iranian funds had built up in Oman’s
Bank Muscat by the time of implementation of the JCPOA in January 2016. In its efforts to easily
access these funds, Iran obtained from the Office of Foreign Assets Control (OFAC) of the
Treasury Department a February 2016 special license to convert the funds (held as Omani rials) to
dollars as a means of easily converting the funds into Euros. Iran ultimately used a different

84 The CRS Report RL32048, Iran: Internal Politics and U.S. Policy and Options, by Kenneth Katzman, discusses the
relations between Iran and other Middle Eastern states.
85 Mark Wallace, “Closing U.S. Ports to Iran-Tainted Shipping. Op-ed,” Wall Street Journal, March 15, 2013.
86 Some Top Oil Buyers Are Thinking about Shunning Iran Oil, op. cit.
87 As U.S. Cracks Down on Iran’s Oil Sales, It Calls out an Ally. Wall Street Journal, September 8, 2019.
88 Omani banks had a waiver from U.S. sanctions laws to permit transferring those funds to Iran’s Central Bank, in
accordance with Section 1245(d)(5) of the National Defense Authorization Act for Fiscal Year 2012 (P.L. 112-81). For
text of the waiver, see a June 17, 2015, letter from Assistant Secretary of State for Legislative Affairs Julia Frifield to
Senate Foreign Relations Committee Chairman Bob Corker, containing text of the “determination of waiver.”
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mechanism to access the funds as hard currency, but the special license issuance resulted in a
May 2018 review by the majority of the Senate Permanent Subcommittee on Investigation to
assess whether that license was consistent with U.S. regulations.89
Iraq
Iraq’s attempts to remain close to its influential neighbor, Iran, have complicated Iraq’s efforts to
rebuild its economy yet avoid running afoul of the United States and U.S. sanctions on Iran. As
noted above, in 2012, the United States sanctioned an Iraqi bank that was a key channel for Iraqi
payments to Iran, but lifted those sanctions when the bank reduced that business. Iraq presented
the United States with a sanctions-related dilemma in July 2013, when it signed an agreement
with Iran to buy 850 million cubic feet per day of natural gas through a joint pipeline that enters
Iraq at Diyala province and would supply several power plants. No sanctions were imposed on
the arrangement, which was agreed while applicable sanctions were in effect. In May 2015, the
Treasury Department sanctioned Iraq’s Al Naser Airlines for helping Mahan Air (sanctioned
entity) acquire nine aircraft.90
The Trump Administration reportedly is seeking to accommodate Iraq’s need for Iranian
electricity supplies and other economic interactions. The Administration has given Iraq waiver
permission—apparently under Section 1247 of IFCA—to buy the Iranian natural gas that runs
Iraq’s power plants. That section provides for waivers of up to 180 days, but press reports
indicate that the Administration has limited the waiver period to 90-day increments.91 Iranian
arms exports to Shia militias in Iraq remain prohibited by Resolution 2231, but no U.N. sanctions
on that activity have been imposed to date. As of October 2018, Iraq reportedly has discontinued
crude oil swaps with Iran—about 50,000 barrels per day—in which Iranian oil flowed to the
Kirkuk refinery and Iran supplied oil to Iraq’s terminals in the Persian Gulf.
Syria and Lebanon
Iran has extensive economic relations with both Syria and Lebanon, countries where Iran asserts
that core interests are at stake. The compliance of Syrian or Lebanese banks and other institutions
with international sanctions against Iran was limited even during 2012-2015. Iran reportedly uses
banks in Lebanon to skirt financial sanctions, according to a wide range of observers, and these
banks are among the conduits for Iran to provide financial assistance to Hezbollah as well as to
the regime of Syrian President Bashar Al Assad.
In January 2017, Iran and Syria signed a series of economic agreements giving Iranian firms
increased access to Syria’s mining, agriculture, and telecommunications sectors, as well as
management of a Syrian port.92 In July, UK authorities diverted an Iranian tanker delivering oil to
Syria, which constituted a violation of EU sanctions on Syria but was not a violation of any EU
sanctions on Iran. The ship reportedly delivered the oil to Syria in early September after its
release by Gibraltar in late August.

89 “Obama Misled Congress, Tried and Failed to Give Iran Secret Access to US Banks Before the Deal.” Business
Insider, June 6, 2018; Permanent Subcommittee on Investigations of the U.S. Senate. Majority Report. “Review of U.S.
Treasury Department’s License to Convert Iranian Assets Using the U.S. Financial System.” May 2018.
90 Eli Lak, “Iran Sanctions Collapsing Already,” Bloomberg News, May 11, 2015.
91 “U.S. Grants Iraq Sanctions Relief in Bid to Boost Business Deals,” Wall Street Journal, December 21, 2018.
92 Iran Signs Phone, Gas Deals with Syria. Agence France Presse, January 17, 2017.
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World Bank and WTO
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. No new international financial institution loans have been approved to Iran since 2005,
including under the World Bank’s “Global Environmental Facility” (GEF) that had slated more
than $7.5 million in loans for Iran to dispose of harmful chemicals.93 Any new loans are unlikely
given the reimposition of all U.S. sanctions in 2018 and U.S. opposition to them for Iran.
Earlier, 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, contributing to a temporary halt in new bank lending to Iran. But, 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.
WTO Accession
An issue related to sanctions is Iran’s request to join the World Trade Organization (WTO). Iran
began accession talks in 2006 after the George W. Bush Administration dropped its objection to
Iran’s application as part of an effort to incentivize Iran to reach an interim nuclear agreement.
The lifting of sanctions presumably paves the way for talks to accelerate, but the accession
process generally takes many years. Accession generally takes place by consensus of existing
WTO members. Iran’s accession might be complicated by the requirement that existing members
trade with other members; as noted above, the U.S. ban on trade with Iran remains in force. The
Trump Administration does not advocate Iran’s admission to that convention.
Effectiveness of Sanctions on Iranian Behavior
The question “are sanctions on Iran ‘working’?”—a question Secretary of State Pompeo
answered in the affirmative in August 201994—can be assessed based on an analysis of the goals
of the sanctions. The following sections assess the effectiveness of Iran sanctions according to a
number of criteria.
Effect on Iran’s Nuclear Program and Strategic Capabilities
The international sanctions regime of 2011-2016 is widely credited with increasing Iran’s
willingness to accept the JCPOA’s restraints on Iran’s nuclear program. Hassan Rouhani was
elected president of Iran in June 2013 in part because of his stated commitment to achieving an
easing of sanctions and ending Iran’s international isolation. Still, the long-term effects of
sanctions are uncertain: the intelligence community assesses that it “does not know” whether Iran
plans to eventually develop a nuclear weapon.95

93 Barbara Slavin, “Obama Administration Holds Up Environmental Grants to Iran,” Al Monitor, June 23, 2014.
94 https://www.youtube.com/watch?v=RTcZg13i-2Q
95 “Worldwide Threat Assessment of the U.S. Intelligence Community.” Testimony before the Senate Select
Committee on Intelligence. May 11, 2017. This language was not contained in the 2018 version of the testimony.
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The Trump Administration asserts that its campaign of “maximum pressure” on Iran,
implemented mainly through sanctions, will cause Iran negotiate a revised JCPOA that would
cover not only Iran’s nuclear program but also its missile program and its regional malign
activities. However, Iran has not entered into such negotiations with the United States, to date.
Sanctions in force during 2011-2016 did not prevent Iran from advancing its nuclear program.
And, even though U.S. and EU sanctions remained on Iran’s missile programs after the JCPOA
was implemented, U.S. intelligence officials have testified that Iran continues to expand the scale,
reach, and sophistication of its ballistic missile arsenal. Still, Iran’s nuclear and missile programs
might have advanced faster were sanctions not imposed.96
Sanctions have prevented Iran from buying significant amounts of major combat systems since
the early 1990s, although Iran has acquired some defensive systems that were not specifically
banned by Resolution 2231. Russia delivered the S-300 air defense system in April 2016. And,
Iran’s indigenous arms industry has grown over the past two decades.97 U.S. intelligence directors
testified in January 2019 that Iran continues to field increasingly lethal weapons systems,
including more advanced naval mines and ballistic missiles, small submarines, armed UAVs
(unmanned aerial vehicles), coastal defense cruise missile batteries, attack craft, and anti-ship
ballistic missiles.98
Effects on Iran’s Regional Influence
Neither the imposition, lifting, nor reimposition of strict sanctions has appeared to affect Iran’s
regional behavior. Iran intervened extensively in Syria, Iraq, and Yemen during the 2011-2016
period when sanctions had a significant adverse effect on Iran’s economy. Iran has remained
engaged in these regional conflicts since sanctions were eased in early 2016, including delivering
weapons to pro-Iranian parties in these conflicts.
Some recent reports indicate that sanctions on Iran are adversely affecting Hezbollah’s finances to
the point where the party has had to appeal for donations, cut expenses, request donations, and
delay or reduce payments to its fighters.99 An alternate explanation is that Iran is adjusting its
expenditures in the Syria conflict to the reduced activity on the battlefield there. Administration
officials assert that the apparent Hezbollah financial difficulties is evidence that its “maximum
pressure” campaign on Iran is working.100
In explaining its decision to withdraw from the JCPOA, the Trump Administration asserted that
the easing of sanctions during 2016-18 caused Iran to expand its regional activities. President
Trump stated that Iran’s defense budget had increased 40% during that time. He stated on August
6, 2018, that “Since the deal [JCPOA] was reached, Iran’s aggression has only increased. The
regime has used the windfall of newly accessible funds it received under the JCPOA to build
nuclear-capable missiles, fund terrorism, and fuel conflict across the Middle East and beyond....
The reimposition of nuclear-related sanctions through today’s actions further intensifies pressure
on Tehran to change its conduct.”101 However, it can be argued that Iran’s regional activities were

96 Speech by National Security Adviser Tom Donilon at the Brookings Institution, November 22, 2011.
97 Department of Defense, Annual Report of Military Power of Iran, April 2012.
98 Worldwide Threat Assessment of the U.S. Intelligence Community, January 29, 2019.
99 “Sanctions on Iran are Hitting Hezbollah,” Washington Post, May 19, 2019.
100 Testimony of Ambassador Brian Hook before the Subcommittee on the Middle East, North Africa, and International
Terrorism of the House Foreign Affairs Committee. June 19, 2019.
101 Statement from the President on the Reimposition of United States Sanctions with Respect to Iran. August 6, 2018.
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not facilitated by the easing of sanctions but rather by the opportunities to expand its influence
that were provided by Iran by the region’s conflicts.
Oversight. In terms of congressional oversight, a provision of the FY2016 Consolidated
Appropriation (P.L. 114-113) required an Administration report to Congress on how Iran has used
the financial benefits of sanctions relief. And, a provision of the Iran Nuclear Agreement Review
Act (P.L. 114-17) requires that a semiannual report on Iran’s compliance with the JCPOA include
information on any Iranian use of funds to support acts of terrorism.
Political Effects
No U.S. Administration has asserted that the objective of U.S. sanctions on Iran is to bring about
the change of Iran’s regime. However, sanctions, by many accounts, did contribute to some
political change in Iran by fostering the election and reelection of the relatively moderate Rouhani
as Iran’s president. Many Iranians welcomed the JCPOA in 2015 because of its promise of relief
from sanctions. The Trump Administration’s reimposition of JCPOA sanctions and addition of
new sanctions have arguably undermined Iran’s moderate leaders, including Rouhani,
contributing to Iran’s decision in mid-2019 to undertake selected violations of the JCPOA. There
is no indication that Rouhani’s position is threatened, but IRGC and other hardliners, who control
domestic security and the judiciary, have criticized Rouhani for remaining in the JCPOA despite
the U.S. exit. In February 2019, apparently under pressure from hardliners, Foreign Minister
Mohammad Javad Zarif announced his resignation, but Rouhani—apparently as a challenge to
the hardliners—did not accept the resignation and reinstated him.
Some assert that the sanctions are sustaining the periodic unrest that has erupted in Iran since late
2017. In 2018 and thus far in 2019, labor strikes and unrest among women protesting the strict
public dress code have continued, although not at a level that appears to threaten the regime.
Other protests occurred over flooding in the southwest in March-April 2019, but again not to the
level where the regime was threatened. Still, some protesters complain that the country’s money
is being spent on regional interventions rather than on the domestic economy.
Economic Effects
The U.S. sanctions enacted since 2011, when fully implemented, take a substantial toll on Iran’s
economy.
 GDP and Employment Trends. During the 2011-2016 sanctions period, Iran’s
economy contracted approximately 20% over the period, and the unemployment
rate rose to about 20% by 2014, with many Iranians working unpaid or partially
paid. The 2016 lifting of sanctions enabled Iran to achieve 7% annual growth
during 2016-2018.102 With the reimposition of U.S. sanctions in mid-2018, the
World Bank estimates Iran’s economy will decline by about 5% during March
2019-March 2020—a sharper decline than was projected in late 2018.103
 Oil Exports. During the 2011-2016 sanctions period, Iran’s crude oil sales fell
from 2.5 mbd in 2011 to about 1.1 mbd by 2014. The JCPOA sanctions relief
enabled Iran to increase its oil exports to 2011 levels, but the reimposition of U.S.
sanctions—including termination of the SREs—has driven Iran’s oil exports to

102 “Foreign Investors Flock to Iran as U.S. Firms Watch on the Sidelines.” Wall Street Journal, March 27, 2017.
103 Forecast Says Sharp Drop in Iran’s Economic Growth Rate. Radio Farda, September 2, 2018. World Bank: Iran
Likely to Suffer Worse Recession Than Previously Thought. VOA News, June 2, 2019.
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about 300,000 barrels per day for August 2019. Iran is therefore losing at least
$50 billion in revenue compared to 2017.
 Banking. Global banks mostly left the Iranian market during 2011-2016 because
of international sanctions. Banks hesitated to reenter the Iran market after the
2016 easing of sanctions because of (1) reported concerns that the United States
might still sanction their transactions with Iran; (2) a lack of transparency in
Iran’s financial sector; (3) lingering concerns over past financial penalties for
processing Iran-related transactions in the U.S. financial system; and (4) extra
costs and procedures caused by the inability to process Iran-related transactions
through the U.S. financial system and/or easily use dollars in Iran-related
transactions. Those banks that did reenter the Iran market in 2016 have exited
again or limited their transactions with Iran as a consequence of the U.S.
reimposition of sanctions.
 Shipping Insurance. Iran was able after 2016 to obtain shipping insurance as a
result of U.S. waivers given to numerous insurers, as discussed above. However,
as of August 7, 2018, U.S.-based shipping reinsurers no longer have active U.S.
waivers, and Iran has been compelled to self-insure most of its shipments.
 Accessibility of Hard Currency Assets Held Abroad. The 2011-2016 sanctions
regime prevented Iran from accessing the hard currency it was being paid for its
oil. By January 2016, Iran’s hard currency reserves held in foreign banks stood at
about $115 billion.104 Iranian officials stated in February 2016 that sanctions
relief had allowed them to access the funds, and it could move the funds via
renewed access to the SWIFT electronic payments system. Of this amount, about
$60 billion was due to creditors such as China or to repay nonperforming loans
extended to Iranian energy companies working in Iran’s immediate
neighborhood. After 2016, Iran kept most of its reserves abroad for cash
management and to pay for imports, but Iran’s foreign reserves are again
restricted by reimposed U.S. sanctions. The current total value of Iran’s hard
currency assets abroad is not known from public sources.
 Currency Decline. Sanctions caused the value of the rial on unofficial markets to
decline about 60% from January 2012 until the 2013, when the election of
Rouhani stabilized the rial at about 35,000 to the dollar. The reimposition of U.S.
sanctions in 2018 caused the rial’s value to plummet to 150,000 to the dollar by
the November 5, 2018. It is only slightly stronger than that as of mid-2019 (about
135,000 to the dollar).105 The downturn has made it difficult for Iranian
merchants to import goods or properly price merchandise, and the government
has banned the importation of 1,400 goods to preserve hard currency.
 Inflation. The drop in value of the currency caused inflation to accelerate during
2011-2013 to a rate of about 60%—a higher figure than that acknowledged by
Iran’s Central Bank. As sanctions were eased, inflation slowed to the single digits
by June 2016, meeting the Central Bank’s stated goal.106 Turmoil surrounding the
U.S. exit from the JCPOA caused inflation to increase to about 15% by late June
2018, and further to nearly 40%, by the end of 2018.107

104 CRS conversation with Department of the Treasury officials. July 2015.
105 ABC News, June 17, 2019.
106 “A Year after Iran Deal, Oil Flows but the Money’s Stuck,” op. cit.
107 https://tradingeconomics.com/iran/inflation-cpi. Administration Factsheet, April 2019.
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 Industrial/Auto Production and Sales. Iran’s light-medium manufacturing sector
was expanding prior to 2011, but its dependence on imported parts left the sector
vulnerable to sanctions that reduced the availability of import financing. Iran’s
vehicle production fell by about 60% from 2011 to 2013. The auto sector, and
manufacturing overall, rebounded after sanctions were lifted in 2016, but
declined again following the U.S. exit from the JCPOA. Researchers at Iran’s
parliament estimated in September 2018 that auto production would decline 45%
by March 2019, and other industrial production would drop by 5%.108
 U.S.-Iran Trade. U.S.-Iran trade remains negligible. In 2015, the last full year
before JCPOA implementation, the United States sold $281 million in goods to
Iran and imported $10 million worth of Iranian products. The slight relaxation of
the U.S. import ban stemming from the JCPOA likely accounts for the significant
increase in imports from Iran in 2016 to $86 million. U.S. imports from Iran were
about $63 million in 2017 and about that same amount in 2018. U.S. exports to
Iran remained low for all of 2016 and 2017 ($172 million and $137 million,
respectively) but spiked to $440 million for 2018.
Iran’s Economic Coping Strategies
Iran had some success mitigating the economic effect of sanctions.
 Export Diversification. Over the past 10 years, Iran has promoted sales of nonoil
products such as minerals, cement, urea fertilizer, and other agricultural and basic
industrial goods. Such “non-oil” exports now generate much of the revenue that
funds Iran’s imports.109 This diversification might have been a factor in the
Trump Administration decision in May 2019 to sanction Iran’s mineral and
metals sector. Iran also has promoted the sale of high value oil products such as
petrochemicals, earning about $4.7 billion in revenue from them by 2016.110
 Reallocation of Investment Funds and Import Substitution. Sanctions compelled
some Iranian manufacturers to increase domestic production of some goods as
substitutes for imports. This trend has been hailed by Iranian economists and
Supreme Leader Khamene’i, who supports building a “resistance economy” that
is less dependent on imports and foreign investment.
 Partial Privatization/IRGC in the Economy. Since 2010, portions of Iran’s state-
owned enterprises have been transferred to the control of quasi-governmental
entities, including cleric-fun foundations (bonyads), holding companies, or
investment groups. Based on data from the Iranian Privatization Organization,
there are about 120 such entities that account for a significant proportion of
Iran’s GDP.111 Although estimates vary widely, the IRGC’s corporate affiliates
are commonly assessed as controlling at least 20% of Iran’s economy, although
there is little available information on the degree of IRGC-affiliated ownership
stakes.112 Rouhani has sought to push the IRGC out of Iran’s economy through
divestment, but with limited success.

108 Radio Farda, op. cit.
109 Testimony of Patrick Clawson before the Senate Banking Committee. January 21, 2015.
110 “Iran Reaps Less Cash from Eased Sanctions Than Predicted,” op. cit.
111 Kevan Harris, “Iran’s Political Economy Under and After the Sanctions,” Washington Post blogs, April 23, 2015.
112 https://www.thenational.ae/world/us-sanctions-on-revolutionary-guards-causes-iran-investment-rethink-1.733028.
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 Subsidy Reductions. President Ahmadinejad (2005-2013) reduced generous
subsidies while temporarily compensating families with small cash payments.
Gasoline prices were raised to levels similar to those in other regional countries,
and far above the subsidized price of 40 cents per gallon. Rouhani has continued
to reduce subsidies, including by raising gasoline and staple food prices further
and limiting the cash payments to only poor families. Rouhani also has improved
collections of taxes and of price increases for electricity and natural gas
utilities.113
 Import Restrictions/Currency Controls. To conserve hard currency, Iran has at
times reduced the supply of hard currency to importers of luxury goods, such as
cars or cellphones, in order to maintain hard currency supplies to importers of
essential goods. These restrictions eased after sanctions were lifted in 2016 but
were reimposed in 2018 to deal with economic unrest and the falling value of the
rial.
Figure 1. Economic Indicators

Sources: IMF 2019, U.S. Energy Information Administration, OPEC.

113 Patrick Clawson testimony, January 21, 2015, op. cit.
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Effect on Energy Sector Development
The Iran Sanctions Act (ISA) was enacted in large part to reduce Iran’s oil and gas production
capacity over the longer term by denying Iran the outside technology and investment to maintain
or increase production. U.S. officials estimated in 2011 that Iran had lost $60 billion in
investment in the sector as numerous major firms pulled out of Iran. Iran says it needs $130
billion-$145 billion in new investment by 2020 to keep oil production capacity from falling.114
Further development of the large South Pars gas field alone requires $100 billion.115 Table B-1 at
the end of this report discusses various Iranian oil and gas fields and the fate of post-1999
investments in them.
During 2012-2016, there was little development activity at Iran’s various oil and gas development
sites, as energy firms sought to avoid sanctions. Some foreign investors resold their equity stakes
to Iranian companies. However, the Iranian firms are not as technically capable as the
international firms that have withdrawn. The lifting of sanctions in 2016 lured at least some
foreign investors back into the sector, encouraged by Iran’s more generous investment terms
under a concept called the “Iran Petroleum Contract.” That contract gives investing companies
the rights to a set percentage of Iran’s oil reserves for 20-25 years.116 Iran signed a number of new
agreements with international energy firms since mid-2016 but, as noted, major energy firms have
begun to divest in response to the U.S. exit from the JCPOA.
Sanctions relief also opened opportunities for Iran to resume developing its gas sector. Iran has
been using its gas development primarily to reinject into its oil fields rather than to export,
although Iran exports about 3.6 trillion cubic feet of gas, primarily to Turkey and Armenia.
Sanctions have rendered Iran unable to develop a liquefied natural gas (LNG) export business. It
was reported in March 2017 that the Philippine National Oil Company is seeking to build a 2-
million-ton LNG plant in Iran, suggesting that patent issues do not necessarily preclude Iran from
pursuing LNG.
With respect to gasoline, the enactment of the CISADA law targeting sales of gasoline to Iran had
a measurable effect. Several suppliers stopped selling gasoline to Iran once enactment appeared
likely, and others ceased supplying Iran after enactment. Gasoline deliveries to Iran fell from
about 120,000 barrels per day before CISADA to about 30,000 barrels per day immediately
thereafter, although importation later increased to about 50,000 barrels per day. Iran expanded
several of its refineries and, in 2017, Iranian officials said Iran had become largely self-sufficient
in gasoline production.
Human Rights-Related Effects
It is difficult to draw any direct relationship between sanctions and Iran’s human rights practices.
Recent human rights reports by the State Department and the U.N. Special Rapporteur on Iran’s
human rights practices assess that there has been only modest improvement in Iran’s practices in
recent years, particularly relaxation of enforcement of the public dress code for women. The
altered policies cannot necessarily be attributed to sanctions pressure or sanctions relief, although
some might argue that sanctions-induced economic dissatisfaction has emboldened Iranians to
protest and to compel the government to relax some restrictions.

114 Khajehpour presentation at CSIS, op. cit.
115 “Iran Faces Steep Climb to Join Gas Superpowers by 2017,” International Oil Daily, April 29, 2014.
116 Thomas Erdbrink. “New Iran Battle Brews over Foreign Oil Titans.” New York Times, February 1, 2016.
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Since at least 2012, foreign firms have generally refrained from selling the Iranian government
equipment to monitor or censor social media use. Such firms include German
telecommunications firm Siemens, Chinese internet infrastructure firm Huawei, and South
African firm MTN Group. In October 2012, Eutelsat, a significant provider of satellite service to
Iran’s state broadcasting establishment, ended that relationship after the EU sanctioned the then
head of the Islamic Republic of Iran Broadcasting (IRIB), Ezzatollah Zarghami. However, the
regime retains the ability to monitor and censor social media use.
Humanitarian Effects
During 2012-2016, sanctions produced significant humanitarian-related effects, particularly in
limiting the population’s ability to obtain expensive Western-made medicines, such as
chemotherapy drugs. Some of the scarcity was caused by banks’ refusal to finance such sales,
even though doing so was not subject to any sanctions. Some observers say the Iranian
government exaggerated reports of medicine shortages to generate opposition to the sanctions.
Other accounts say that Iranians, particularly those with connections to the government, took
advantage of medicine shortages by cornering the import market for key medicines. These
shortages resurfaced in 2018 following the reimposition of sanctions by the Trump
Administration. For example, reports indicate that the reimposition of U.S. sanctions may be
inhibiting the flow of humanitarian goods to the Iranian people and reportedly contributing to
shortages in medicine to treat ailments such as multiple sclerosis and cancer.117 Other reports
indicate that Cargill, Bunge, and other global food traders have halted supplying Iran because of
the absence of trade financing.118 And, Iranian officials and some international relief groups have
complained that U.S. sanctions inhibited the ability to provide relief to flooding victims in
southwestern Iran in March-April 2019.
EU officials have called on the United States to produce a “white list” that would “give clear
guidelines about what channels European banks and companies should follow to conduct
legitimate [humanitarian] transactions with Iran without fear of future penalties.”119 Iranian
officials have also accused U.S. sanctions of hampering international relief efforts for victims of
vast areas of flooding in southwestern Iran in the spring of 2019.
Other reports say that pollution in Tehran and other big cities is made worse by sanctions because
Iran produces gasoline itself with methods that cause more impurities than imported gasoline. As
noted above, Iran’s efforts to deal with environmental hazards and problems might be hindered
by denial of World Bank lending for that purpose.
In the aviation sector, some Iranian pilots complained publicly that U.S. sanctions caused Iran’s
passenger airline fleet to deteriorate to the point of jeopardizing safety. Since the U.S. trade ban
was imposed in 1995, 1,700 passengers and crew of Iranian aircraft have been killed in air
accidents, although it is not clear how many of the crashes, if any, were due to difficultly in
acquiring U.S. spare parts.120

117 https://www.washingtonpost.com/world/middle_east/fresh-sanctions-on-iran-are-already-choking-off-medicine-
imports-economists-say/2018/11/17/c94ce574-e763-11e8-8449-1ff263609a31_story.html;
https://www.bloomberg.com/news/articles/2018-11-21/trump-s-sanctions-are-proving-a-bitter-pill-for-iran-s-sick;
https://www.csmonitor.com/World/Middle-East/2018/1029/In-Iran-US-sanctions-are-being-felt-with-harsher-
measures-to-come.
118 “Global Traders Halt New Iran Food Deals as U.S. Sanctions Bite.” Reuters, December 21, 2018.
119 https://www.theguardian.com/world/2018/nov/02/iran-sanctions-us-european-humanitarian-supplies.
120 Thomas Erdbink, “Iran’s Aging Airliner Fleet Seen As Faltering Under U.S. Sanctions,” July 14, 2012.
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Air Safety
Sanctions relief ameliorated at least some of the humanitarian difficulties discussed above. In the
aviation sector, several sales of passenger aircraft have been announced, and licensed by the
Department of the Treasury, since Implementation Day. However, as noted, the licenses are being
revoked and deliveries will not proceed beyond November 2018.
 In February 2016, Iran Air—which was delisted from U.S. sanctions as of
Implementation Day—announced it would purchase 118 Airbus commercial
aircraft at an estimated value of $27 billion. Airbus received an OFAC license
and three of the aircraft were delivered before the Treasury Department revoked
its export licenses for the planes.
 In December 2016, Boeing and Iran Air finalized an agreement for Boeing to sell
the airline 80 passenger aircraft and lease 29 others. Boeing received a specific
license for the transaction. The deal has a total estimated value of about $17
billion, with deliveries scheduled to start later in 2018. The Boeing sale is to
include 30 of the 777 model. None were delivered, and Boeing cancelled planned
deliveries to Iran after its export licenses were revoked.
 In April 2017, Iran’s Aseman Airlines signed a tentative agreement to buy at least
30 Boeing MAX passenger aircraft. No U.S. license for this sale was announced
prior to the U.S. exit from the JCPOA. The airline is owned by Iran’s civil
service pension fund but managed as a private company.
 In June 2017, Airbus agreed to tentative sales of 45 A320 aircraft to Iran’s
Airtour Airline, and of 28 A320 and A330 aircraft to Iran’s Zagros Airlines. No
U.S. license for the sale was announced prior to the U.S. exit from the JCPOA.
 ATR, owned by Airbus and Italy’s Leonardo, sold 20 aircraft to Iran Air. It
delivered eight aircraft by the time of the U.S. JCPOA exit. It reportedly has been
given temporary U.S. Treasury Department licenses to deliver another five after
the August 6, 2018, initial sanctions reimposition in which its U.S. export
licenses were to be revoked.
Post-JCPOA Sanctions Legislation
JCPOA oversight and implications, and broader issues of Iran’s behavior have been the subject of
legislation.
Key Legislation in the 114th Congress
The JCPOA states that as long as Iran fully complies with the JCPOA, the sanctions that were
suspended or lifted shall not be reimposed on other bases. The Obama Administration adhered to
that provision, but stipulated that some new sanctions that seek to limit Iran’s military power, its
human rights abuses, or its support for militant groups would not necessarily violate the JCPOA.
Iran Nuclear Agreement Review Act (P.L. 114-17)
The Iran Nuclear Agreement Review Act of 2015 (INARA, P.L. 114-17) provided for a 30- or 60-
day congressional review period after which Congress could pass legislation to approve or to
disapprove of the JCPOA, or do nothing. No such legislation of disapproval was enacted.
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There are several certification and reporting requirements under INARA, although most of them
no longer apply as a result of the Trump Administration withdrawal:
 Material Breach Report. The President must report a potentially significant
Iranian breach of the agreement within 10 days of acquiring credible information
of such. Within another 30 days, the President must determine whether this is a
material breach and whether Iran has cured the breach.
 Certification Report. The President is required to certify, every 90 days, that Iran
is “transparently, verifiably, and fully implementing” the agreement, and that Iran
has not taken any action to advance a nuclear weapons program. On October 13,
2017, the Administration declined to make that certification, on the grounds that
continued sanctions relief is not appropriate and proportionate to Iran’s measures
to terminate its illicit nuclear program (Section (d)(6)(iv)(I) of INARA).
 If a breach is reported, or if the President does not certify compliance, Congress
may initiate within 60 days “expedited consideration” of legislation that would
reimpose any Iran sanctions that the President had suspended through use of
waiver or other authority.
 Semiannual Report. INARA requires an Administration report every 180 days on
Iran’s nuclear program, including not only Iran’s compliance with its nuclear
commitments but also whether Iranian banks are involved in terrorism financing;
Iran’s ballistic missile advances; and whether Iran continues to support terrorism.
Visa Restriction
The FY2016 Consolidated Appropriation (P.L. 114-113) contained a provision amending the Visa
Waiver Program to require a visa to visit the United States for any person who has visited Iraq,
Syria, or any terrorism list country (Iran and Sudan are the two aside from Syria still listed) in the
previous five years. Iran argued that the provision represented a violation of at least the spirit of
the JCPOA by potentially deterring European businessmen from visiting Iran. The Obama
Administration issued a letter to Iran stating it would implement the provision in such a way as
not to not impinge on sanctions relief, and allowances for Iranian students studying in the United
States were made in the implementing regulations. Another provision of that law requires an
Administration report to Congress on how Iran has used the benefits of sanctions relief.
President Trump has issued and amended executive orders that, in general, prohibit Iranian
citizens (as well as citizens from several other countries) from entering the United States.
Iran Sanctions Act Extension
The 114th Congress acted to prevent ISA from expiring in its entirety on December 31, 2016. The
Iran Sanctions Extension Act (H.R. 6297), which extended ISA until December 31, 2026, without
any other changes, passed the House on November 15 by a vote of 419-1 and then passed the
Senate by 99-0. President Obama allowed the bill to become law without signing it (P.L. 114-
277), even though the Administration considered it unnecessary because the President retains
ample authority to reimpose sanctions on Iran. Iranian leaders called the extension a breach of the
JCPOA,121 but the JCPOA’s “Joint Commission” did not determine it breached the JCPOA.

121 An Iranian letter to the U.N. Security Council submitted July 20, 2015, indicates Iran’s view that “reintroduction or
reimposition, including through extension, of the sanctions and restrictive measures will constitute significant
nonperformance which would relieve Iran from its commitments in whole or in part.” Iran Letter to the President of the
U.N. Security Council, July 20, 2015, (S/2015/550).
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Reporting Requirement on Iran Missile Launches
The conference report on the FY2017 National Defense Authorization Act (P.L. 114-328)
contained a provision (Section 1226) requiring a quarterly report to Congress on Iran’s missile
launches the imposition of U.S. sanctions with respect to Iran’s ballistic missile launches until
December 31, 2019. The conference report on the FY2018 NDAA (P.L. 115-91) extended that
reporting requirement until December 31, 2022. The report is to include efforts to sanction
entities or individuals that assist those missile launches.
Other 114th Congress Legislation
 The Iran Policy Oversight Act (S. 2119) and the Iran Terror Finance
Transparency Act (H.R. 3662) would have added certification requirements for
the Administration to remove designations of Iranian entities sanctioned. The
House passed the latter bill but then vacated its vote.
 The IRGC Terrorist Designation Act (H.R. 3646/S. 2094) would have required a
report on whether the IRGC meets the criteria for designation as a Foreign
Terrorist Organization (FTO). The Obama Administration argued that the law that
set up the FTO designations (Section 219 of the Immigration and Nationality Act
[8 U.S.C. 1189]) applies such designations only to groups, rather than armed
forces of a nation-state (which the IRGC is).
 The IRGC Sanctions Act (H.R. 4257) would have required congressional action
to approve an Administration request to remove a country from the terrorism list
and would have required certification that any entity to be “delisted” from
sanctions is not a member, agent, affiliate, or owned by the IRGC.
 The Prohibiting Assistance to Nuclear Iran Act (H.R. 3273) would have
prohibited the use of U.S. funds to provide technical assistance to Iran’s nuclear
program—conflicting with the JCPOA’s call for peaceful nuclear cooperation
with Iran (Paragraph 32).
 The Justice for Victims of Iranian Terrorism Act (H.R. 3457/S. 2086) would have
prohibited the President from waiving U.S. sanctions until Iran completed paying
judgments issued for victims of Iranian terrorism. The House passed it on
October 1, 2015, by a vote of 251-173 despite Obama Administration opposition
to the bill as contrary to the JCPOA.122
 H.R. 3728 would have amended ITRSHRA to make mandatory sanctions against
electronic payments systems such as SWIFT if they were used by Iran.
 The Iran Ballistic Missile Sanctions Act of 2016 (S. 2725) would have required
that specified sectors of Iran’s economy (automotive, chemical, computer
science, construction, electronic, energy metallurgy, mining, petrochemical,
research, and telecommunications) be subject to U.S. sanctions, if those sectors
were determined to provide support for Iran’s ballistic missile program. A similar
bill, H.R. 5631, the Iran Accountability Act, which passed the House on July 14,
2016, by a vote of 246-179, would have removed some waiver authority for
certain provisions of several Iran sanctions laws and required sanctions on
sectors of Iran’s civilian economy determined to have supported Iran’s ballistic
missile program. The latter provision, as did S.2725, appeared to contradict the

122 For more information on the issue of judgments for victims of Iranian terrorism, see CRS Report RL31258, Suits
Against Terrorist States by Victims of Terrorism, by Jennifer K. Elsea.
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JCPOA. In the 115th Congress, S. 15 and key sections of S. 227 and H.R. 808
(Iran Nonnuclear Sanctions Act of 2017) mirror S. 2725.
 H.R. 4992, which passed the House on July 14, 2016, by a vote of 246-181, and
the related Countering Iranian Threats Act of 2016 (S. 3267), would have
required foreign banks and dollar clearinghouses to receive a U.S. license for any
dollar transactions involving Iran.
 H.R. 5119, which passed the House by a vote of 249-176, would have prohibited
the U.S. government from buying additional heavy water from Iran and appeared
intended to block additional U.S. purchases similar to one in April 2016 in which
the United States bought 32 metric tons from Iran at a cost of about $8.6 million.
 Several bills and amendments in the 114th Congress sought to block or impede
the sale of the Boeing aircraft to Iran by preventing the licensing, financing, or
Ex-Im Bank loan guarantees for the sale. These included H.R. 5715, H.R. 5711,
and several amendments to the House version of the FY2017 Financial Services
and General Government Appropriations Act (H.R. 5485). That act passed the
House on July 7, 2016, by a vote of 239-185, and H.R. 5711 passed by the House
on November 17, 2016, by a vote of 243-174. The Obama Administration
opposed the measures as JCPOA violations.
The Trump Administration and Major Iran Sanctions Legislation
Even before the Trump Administration pulled the United States out of the JCPOA, Congress
acted on or considered additional Iran sanctions legislation. The following Iran sanctions
legislation was enacted or considered in the 115th Congress.
The Countering America’s Adversaries through Sanctions Act of 2017
(CAATSA, P.L. 115-44)
S. 722, which initially contained only Iran-related sanctions, was reported out by the Senate
Foreign Relations Committee on May 25, 2017. After incorporating an amendment adding
sanctions on Russia, the bill was passed by the Senate on June 15, 2017, by a vote of 98-2. A
companion measure, H.R. 3203, was introduced in the House that was virtually identical to the
engrossed Senate version of S. 722. Following a reported agreement among House and Senate
leaders, H.R. 3364, with additional sanctions provisions related to North Korea, passed both
chambers by overwhelming margins. President Trump signed it into law on August 2, 2017 (P.L.
115-44), accompanied by a signing statement expressing reservations about the degree to which
provisions pertaining to Russia might conflict with the President’s constitutional authority.
Overall, CAATSA did not appear to conflict with the JCPOA insofar as it did not reimpose U.S.
secondary sanctions on Iran’s civilian economic sectors, and the JCPOA did not require the
United States to refrain from imposing additional sanctions on Iranian proliferation, human rights
abuses, terrorism, or the IRGC. Section 108 of CAATSA requires an Administration review of all
designated entities to assess whether such entities are contributing to Iran’s ballistic missile
program or contributing to Iranian support for international terrorism.
Legislation in the 115th Congress Not Enacted
 H.R. 1698. The Iran Ballistic Missiles and International Sanctions Enforcement
Act, passed the House on October 26, 2017, by a vote of 423-2. It would have
amended the remaining active (not waived) section of ISA (Section 5b) to clarify
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that assistance to Iran’s ballistic missile program is included as subject to
sanctions. The provision would have applied the sanctions to foreign
governments determined to be assisting Iran’s missile programs, and would have
applied several ISA sanctions to foreign entities, including foreign governments,
that sell to or import from Iran the major combat systems banned for sale to Iran
in Security Council Resolution 2231. This represents a more specific list of
banned items than the “destabilizing numbers and types” of weaponry the sale to
Iran of which can be sanctioned under ISA and several other U.S. laws discussed
above.
 H.R. 1638. On November 14, 2017, the House Financial Services Committee
ordered reported H.R. 1638, the Iranian Leadership Asset Transparency Act,
which would have required the Treasury Secretary to report to Congress on the
assets and equity interests held by named Iranian persons, including the Supreme
Leader, the President, various IRGC and other security commanders, and
members of various leadership bodies.
 H.R. 4324. The House Financial Services Committee also ordered reported on
November 14, 2017, the Strengthening Oversight of Iran’s Access to Finance
Act. The bill would have required Administration reports on whether financing of
Iranian commercial passenger aircraft purchases posed money-laundering or
terrorism risks or benefited Iranian persons involved in Iranian proliferation or
terrorism. Some argued that the bill might affect the willingness of the Treasury
Department to license aircraft sales to Iran, and in so doing potentially breach the
U.S. JCPOA commitment to sell such aircraft to Iran.123
 Following President Trump’s October 13, 2017, statement on Iran, then-Senate
Foreign Relations Committee Chairman Bob Corker and Senator Tom Cotton
released an outline of legislation that would reimpose waived U.S. sanctions if, at
any time—including after JCPOA restrictions expire—Iran breaches JCPOA-
stipulated restrictions. The bill draft, which was not introduced, included
sanctions triggers based on Iranian missile developments.
 H.R. 5132. The Iranian Revolutionary Guard Corps Economic Exclusion Act.
This bill mandated Administration reports on whether specified categories of
entities are owned or controlled by the IRGC, or conduct significant transactions
with the IRGC. The bill defined an entity as owned or controlled by the IRGC
even if the IRGC’s ownership interest is less than 50%—a lower standard than
the usual practice in which ownership is defined as at least 50%. The bill would
have required Administration investigation of several specified entities as
potentially owned or controlled by the IRGC, including several
telecommunications, mining, and machinery companies, and required a report on
whether the Iran Airports Company violates E.O. 13224 by facilitating flight
operations by Mahan Air, which is a designated SDN under E.O. 13224. Whereas
the bill’s provisions did not mandate any sanctions on entities characterized
within, the bill appeared to establish a process under which the Administration
could name as SDNs entities in Iran’s civilian economic sectors, including civil
aviation.

123 Author conversations with experts in Washington, DC, November, 2017, and various press reports.
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 H.R. 6751. The Banking Transparency for Sanctioned Persons Act of 2018,
would have required reporting to Congress on any license given to a bank to
provide financial services to a state sponsor of terrorism.
 H.R. 4591, S. 3431, and H.R. 4238. Several bills would have essentially codified
Executive Order 13438 by requiring the blocking of U.S.-based property and
preventing U.S. visas for persons determined to be threatening the stability of
Iraq—legislation apparently directed at Iran’s Shiite militia allies in Iraq. The
latter two bills specifically mentioned the Iraqi groups As’aib Ahl Al Haq and
Harakat Hizballah Al Nujabi as entities that the Administration should so
sanction. H.R. 4591 passed the House on November 27, 2018.
116th Congress
Because the Trump Administration has exited the JCPOA, there is increased potential for the
116th Congress to consider legislation that sanctions those Iranian economic sectors that could not
be sanctioned under the JCPOA. The following have been introduced:
 Several bills similar or virtually identical to those introduced previously have
been introduced, imposing sanctions on Iranian proxies in Iraq and elsewhere.
These bills include H.R. 361, the Iranian Proxies Terrorist Sanctions Act of 2019,
and H.R. 571, the Preventing Destabilization of Iraq Act of 2019.
 The Iranian Revolutionary Guard Corps Exclusion Act (S. 925), similar to H.R.
5132 in the 115th Congress, has been introduced in the Senate.
 The Iran Ballistic Missiles and International Sanctions Enforcement Act (H.R.
2118). The bill includes provisions similar to H.R. 1698 in the 115th Congress
(see above).
Other Possible U.S. and International Sanctions124
There are a number of other possible sanctions that might receive consideration—either in a
global or multilateral framework. These possibilities are analyzed in CRS In Focus IF10801,
Possible Additional Sanctions on Iran, by Kenneth Katzman.

124 See CRS In Focus IF10801, Possible Additional Sanctions on Iran, by Kenneth Katzman.
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Appendix A. U.S., U.N., EU and Allied Country
Sanctions (Pre-JCPOA)
Table A-1. Comparison Between U.S., U.N., and EU and Allied Country Sanctions
(Prior to Implementation Day)
EU and Other Allied
U.S. Sanctions
U.N. Sanctions
Countries
General Observation: Most
As of 2010, U.N. sanctions were
EU closely aligned its sanctions
sweeping sanctions on Iran of
intended to give countries
tightening with that of the United
virtually any country in the world
justification to cooperate with U.S.
States. Most EU sanctions lifted in
secondary sanctions.
accordance with the JCPOA,
Post-JCPOA: Resolution 2231 is the
although some sanctions on arms,
only operative Resolution on Iran.
dual-use items, and human rights
remain.
Japan, South Korean, and China
sanctions also became extensive
but were almost entirely lifted in
concert with the JCPOA.
Ban on U.S. Trade with,
U.N. sanctions did not at any time
No comprehensive EU ban on
Investment in, and Financing
ban civilian trade with Iran or
trade in civilian goods with Iran
for Iran: Executive Order 12959
general civilian sector investment in
was imposed at any time.
bans (with limited exceptions) U.S.
Iran.
Japan and South Korea did not ban
firms from exporting to Iran,
normal civilian trade with Iran.
importing from Iran, or investing in
Iran.
Sanctions on Foreign Firms
No U.N. equivalent existed.
With certain exceptions, the EU
that Do Business with Iran’s
However, Resolution 1929 “not[es]
banned almost all dealings with
Energy Sector: The Iran Sanctions the potential connection between
Iran’s energy sector after 2011.
Act, P.L. 104-172, and subsequent
Iran’s revenues derived from its
These sanctions now lifted.
laws and executive orders,
energy sector and the funding of
Japanese and South Korean
discussed throughout the report,
Iran’s proliferation-sensitive nuclear
measures banned new energy
mandate sanctions on virtually any
activities.” This wording was
projects in Iran and called for
type of transaction with/in Iran’s
interpreted as providing U.N.
restraint on ongoing projects.
energy sector.
support for countries to ban their
South Korea in December 2011
companies from dealing with Iran’s
cautioned its firms not to sell
energy sector.
energy or petrochemical
equipment to Iran. Both cut oil
purchases from Iran sharply. These
sanctions now lifted.
Ban on Foreign Assistance:
No U.N. equivalent
EU measures of July 27, 2010,
U.S. foreign assistance to Iran—
banned grants, aid, and
other than purely humanitarian
concessional loans to Iran. Also
aid—is banned under §620A of the
prohibited financing of enterprises
Foreign Assistance Act, which bans
involved in Iran’s energy sector.
U.S. assistance to countries on the
These sanctions now lifted.
U.S. list of “state sponsors of
Japan and South Korea measures
terrorism.” Iran is also routinely
did not specifically ban aid or
denied direct U.S. foreign aid under
lending to Iran.
the annual foreign operations
appropriations acts (most recently
in §7007 of division H of P.L. 111-8).
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EU and Other Allied
U.S. Sanctions
U.N. Sanctions
Countries
Ban on Arms Exports to Iran:
As per Resolution 1929 (paragraph
EU sanctions include a
Iran is ineligible for U.S. arms
8), as superseded by Resolution
comprehensive ban on sale to Iran
exports under several laws, as
2231, Security Council approval is
of all types of military equipment,
discussed in the report.
required to sell Iran major weapons
not just major combat systems.
systems.
Arms embargo remains post-
JCPOA.
No similar Japan and South Korean
measures announced, but neither
has exported arms to Iran.
Restriction on Exports to Iran
U.N. resolutions on Iran banned the
EU banned the sales of dual use
of “Dual Use Items”:
export of many dual-use items to
items to Iran, including ballistic
Primarily under §6(j) of the Export
Iran. Resolution 2231 sets up a
missile technology, in line with
Administration Act (P.L. 96-72) and
procurement network for the P5+1
U.N. resolutions. These
§38 of the Arms Export Control
to approve of all purchases for Iran’s restrictions generally remain post-
Act, there is a denial of license
ongoing nuclear program.
JCPOA.
applications to sell Iran goods that
Japan and S. Korea have announced
could have military applications.
full adherence to strict export
control regimes when evaluating
sales to Iran. These restrictions
generally remain post-JCPOA.
Sanctions Against Lending to
Resolution 1747 (oper. paragraph 7)
The July 27, 2010, measures
Iran:
requested, but did not mandate, that prohibited EU members from
Under §1621 of the International
countries and international financial
providing grants, aid, and
Financial Institutions Act (P.L. 95-
institutions refrain from making
concessional loans to Iran,
118), U.S. representatives to
grants or loans to Iran, except for
including through international
international financial institutions,
development and humanitarian
financial institutions. Sanctions
such as the World Bank, are
purposes. (No longer applicable.)
lifted post-JCPOA.
required to vote against loans to
Japan and South Korea banned
Iran by those institutions.
medium- and long-term trade
financing and financing guarantees.
Short-term credit was still allowed.
These sanctions now lifted.
Sanctions Against the Sale of
Resolution 1737 (oper. paragraph
The EU measures imposed July 27,
Weapons of Mass Destruction-
12) imposed a worldwide freeze on
2010, commit the EU to freezing
Related Technology to Iran:
the assets and property of Iranian
the assets of WMD-related entities
Several laws and regulations provide WMD-related entities named in an
named in the U.N. resolutions, as
for sanctions against entities, Iranian Annex to the Resolution. Each
well as numerous other named
or otherwise, that are determined
subsequent resolution expanded the
Iranian entities. Most of these
to be involved in or supplying Iran’s
list of Iranian entities subject to
restrictions remain.
WMD programs (asset freezing, ban these sanctions.
Japan and South Korea froze assets
on transaction with the entity).
of U.N.-sanctioned entities. Most
of these restrictions have been
lifted.
Ban on Transactions with
No direct equivalent, but Resolution No direct equivalent, but many of
Terrorism Supporting Entities:
1747 (oper. paragraph 5) bans Iran
the Iranian entities named as
Executive Order 13224 bans
from exporting any arms. Resolution blocked by the EU, Japan, and
transactions with entities
2231 continues that restriction for a
South Korea overlap or
determined by the Administration
maximum of five years.
complement Iranian entities named
to be supporting international
as terrorism supporting by the
terrorism. Numerous entities,
United States.
including some of Iranian origin,
Japan and S. Korea did not impose
have been designated.
specific terrorism sanctions on
Iran.
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EU and Other Allied
U.S. Sanctions
U.N. Sanctions
Countries
Human Rights Sanctions:
No U.N. sanctions were imposed on EU sanctions include 87 named
CISADA provides for a prohibition
Iran for terrorism or human rights
Iranians subject to a ban on travel
on travel to the U.S., blocking of
abuses.
to the EU countries. The EU also
U.S.-based property, and ban on
retains a ban on providing
transactions with Iranians
equipment that can be used for
determined to be involved in
internal repression.
serious human rights abuses against
Japan and South Korea have
Iranians since the June 12, 2009,
announced bans on named Iranians
presidential election there, or with
involved in WMD programs.
persons selling Iran equipment to
commit such abuses.
Restrictions on Iranian
Resolution 1803 and 1929 authorize
The EU measures announced July
Shipping:
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. Department of the Treasury
Iran Shipping Lines (IRISL)—or any
measures also freeze the EU-based
has 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 reinsurance for
entities as entities whose U.S.-based the shipments include goods whose
Iranian firms are banned. These
property is to be frozen.
export to Iran is banned.
sanctions now lifted.
These resolutions no longer apply.
Japan and South Korean measures
took similar action against IRISL
and Iran Air. Sanctions now lifted.
Banking Sanctions:
No direct equivalent
The EU froze Iran Central Bank
During 2006-2011, several Iranian
However, two Iranian banks were
assets January 23, 2012, and
banks have been named as
named as sanctioned entities under
banned all transactions with Iranian
proliferation or terrorism
the U.N. Security Council
banks unless authorized on
supporting entities under Executive
resolutions. U.N. restrictions on
October 15, 2012.
Orders 13382 and 13224,
Iranian banking now lifted.
Brussels-based SWIFT expelled
respectively.
sanctioned Iranian banks from the
CISADA prohibits banking
electronic payment transfer
relationships with U.S. banks for any
system. This restriction has been
foreign bank that conducts
lifted.
transactions with Iran’s
Japan and South Korea took similar
Revolutionary Guard or with Iranian
measures South Korea imposed
entities sanctioned under the
the 40,000 Euro threshhold
various U.N. resolutions.
requiring authorization. Japan and
FY2012 Defense Authorization (P.L.
S. Korea froze the assets of 15
112-81) prevents U.S. accounts with
Iranian banks; South Korea
foreign banks that process
targeted Bank Mellat for freeze.
transactions with Iran’s Central
These sanctions now lifted.
Bank (with specified exemptions).
Ballistic Missiles: U.S.
Resolution 1929 (paragraph 9)
EU measures on July 27, 2010,
proliferations laws provide for
prohibited Iran from undertaking
required adherence to this
sanctions against foreign entities
“any activity” related to ballistic
provision of Resolution 1929. EU
that help Iran with its nuclear and
missiles capable of delivering a
has retained ban on providing
ballistic missile programs.
nuclear weapon. Resolution 2231
ballistic missile technology to Iran
calls on Iran not to develop or
in post-JCPOA period.
launch ballistic missiles designed to
be capable of carrying a nuclear
weapon.

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Appendix B. Post-1999 Major Investments
in Iran’s Energy Sector
Table B-1. Post-1999 Major Investments in Iran’s Energy Sector
Company(ies)/Status
Output/
Date
Field/Project
(If Known)
Value
Goal
Feb. 1999
Doroud (oil)
Total (France)/ENI (Italy)
$1 billion
205,000 bpd
Total and ENI exempted from sanctions
because of pledge to exit Iran
Apr. 1999
Balal (oil)
Total/ Bow Valley
$300 million
40,000 bpd
Dec./May
Initial development completed in 2004
(Canada)/ENI
2016
Dec. 2016: Thailand PTTEP signed agreement
Thailand PTTEP
with NIOC to study further development.

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

(Inpex stake);
of which
China $2.5
80,000 is
CNPC (China) – N. Azadegan operator
billion
from N.
(bought from Inpex)
Azadegan.
Royal Dutch Shell/Petronas (Malaysia) – MoU
to develop S. Azadegan
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Company(ies)/Status
Output/
Date
Field/Project
(If Known)
Value
Goal
Jan. 2004
Tusan Block
Petrobras (Brazil)
$178 million

Oil found in block in Feb. 2009, but not in
commercial quantity, according to the firm.
Oct. 2004
Sinopec (China), deal
$2 billion
300,000 bpd

Yadavaran (oil)
finalized Dec. 9, 2007

Dec. 2016
2005
Saveh bloc (oil)
PTT (Thailand)

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

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.)
Jul. 2006
Arak Refinery expansion
Sinopec (China); JGC
$959 million
Expansion to
(GAO reports; Fimco FZE Machinery website;
(Japan). Work continued by
(major initial
produce
http://www.fimco.org/index.php?option=
Hyundai Heavy Industries (S. expansion;
250,000 bpd
com_content&task=view&id=70&Itemid=78.)
Korea)
extent of
Hyundai work
unknown)
Sept. 2006
Khorramabad block (oil)
Norsk Hydro and Statoil
$49 million
no estimates
Seismic data gathered, but no production is
(Norway).
planned. (Statoil factsheet, May 2011)
Dec. 2006
North Pars Gas Field (offshore gas).
China National Offshore
$16 billion
3.6 billion cfd
Includes gas purchases
Oil Co. Work suspended in

2011, but reportedly
resumed in 2016.
Feb. 2007
LNG Tanks at Tombak Port
Daelim (S. Korea)
$320 million
200,000 ton
Contract to build three LNG tanks at Tombak,
capacity
30 miles north of Assaluyeh Port.
(May not constitute “investment” in pre-2010
version of ISA, because that definition did not
specify LNG as “petroleum resource” of Iran.)

Feb. 2007
South Pars Phases 13 and 14
Royal Dutch Shell, Repsol
$4.3 billion

Deadline to finalize (May 2009) not met; firms
(Spain)
submitted revised proposals to Iran in
June 2009. State Department said on
September 30, 2010, that Royal Dutch Shell and
Repsol will not pursue this project any further.
Mar. 2007
Esfahan refinery upgrade
Daelim (S. Korea)

NA
Jul. 2007
S. Pars Phases 22, 23, and 24
Turkish Petroleum
$12. billion
2 billion cfd
Pipeline to transport Iranian gas to Turkey, and
Company (TPAO)
on to Europe and building three power plants
in Iran. Contract not finalized to date.
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Company(ies)/Status
Output/
Date
Field/Project
(If Known)
Value
Goal
Dec. 2007
Golshan and Ferdowsi onshore and
Petrofield Subsidiary of SKS
$15 billion
3.4 billion cfd
offshore gas and oil fields and LNG plant
Ventures (Malaysia)
of
Contract modified but reaffirmed December
gas/250,000
2008 (GAO reports; Oil Daily, January 14,
bpd of oil
2008.)
2007
Jofeir Field (oil)
Belarusneft (Belarus) under
$500 million
40,000 bpd
GAO report cited below. Belarusneft, a
contract to Naftiran.
subsidiary of Belneftekhim, sanctioned under
No production to date
ISA on March 29, 2011. Naftiran sanctioned on
September 29, 2010, for this and other
activities.
2008
Dayyer Bloc (Persian Gulf, offshore, oil)
Edison (Italy)
$44 million

GAO reports.
Feb. 2008
PGNiG (Polish Oil and Gas
$2 billion

Lavan field (offshore natural gas)
Company, Poland), divested

to Iranian firms in 2011

Mar. 2008
Danan Field (on-shore oil)
Petro Vietnam Exploration

“PVEP Wins Bid to Develop Danan Field.” Iran
and Production Co.
Press TV, March 11, 2008.
(Vietnam)
Apr. 2008
Iran’s Kish Gas Field
Oman (cofinancing of
$7 billion
1 billion cfd
Includes pipeline from Iran to Oman.
project)
Apr. 2008
Moghan 2 (onshore oil and gas, Ardebil
INA (Croatia), but firm
$40-$140

province)
withdrew in 2014
million

2008
Kermanshah petrochemical plant (new
Uhde (Germany)

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

Capacity is 1
Production of polyethelene at two polymer
firm withdrew in 2014
million tons
plants in Bushehr Province. Product exported
per year.

Mar. 2009
Phase 12 South Pars (gas)—Incl. LNG
Indian firms: Oil and Natural $8 billion
20 million
terminal construction and Farsi Block gas
Gas Corp. of India
tonnes of
field/Farzad-B bloc.
(ONGC); Oil India Ltd.,
LNG annually
India Oil Corp. Ltd./minor
by 2012
stakes by Sonanagol
(Angola) and PDVSA
(Venezuela).
Aug. 2009
Abadan refinery
Sinopec
Up to $6

Upgrade and expansion; building a new refinery
billion if new
at Hormuz on the Persian Gulf coast.
refinery is
built
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Company(ies)/Status
Output/
Date
Field/Project
(If Known)
Value
Goal
Oct. 2009
South Pars Gas Field—Phases 6-8, Gas
G and S Engineering and
$1.4 billion

Sweetening Plant
Construction (South Korea)
CRS conversation with Embassy of S. Korea in
Washington, DC, July 2010.
Contract signed but then abrogated by S.
Korean firm.
Nov. 2009
South Pars Phase 12—Part 2 and Part 3
Daelim (S. Korea)—Part 2;
$4 billion ($2

(“Italy, South Korea To Develop South Pars
Tecnimont (Italy)—Part 3
bn each part)
Phase 12.” Press TV [Iran], November 3, 2009,
http://www.presstv.com/pop/Print/?id=110308.)
Feb.
South Pars Phase 11
CNPC (China), with Iran
$4.7 billion

2010/July
Project originally awarded to CNPC in 2010,
Petropars
2017
but CNPC exited the project in October 2012.
In July 2017, Total took over the project as
operator, with CNPC as minority partner
(30%). Iran’s Petropars has a 20% stake as well.
In November 2018, Total exited and CNPC
became operator.
2011
Azar Gas Field
Gazprom (Russia)

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

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

Zarubezhneft signed a MoU to assess the field.
Nov. 2016
Parsi and Rag E-Sefid
Schlumberger (France)

Schlumberger signed a MoU to assess the fields.
Nov. 2016
South Pars Phase 11
Total SA (France)/CNPC
$4.8 billion
1.8 billion cu
Total has announced it will divest in response
(China) and Petropars
ft/day
to U.S. reimposition of sanctions in 2018

Nov. 2016
Sumar Oil Field
PGNiG (Poland)

Polish Oil and Gas Company (PGNiG) signed a
MoU to assess the field for six months.
Nov. 2016
Karanj
Pergas (consortium of 15

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

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

Royal Dutch Shell signed MoU to assess the
field
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Company(ies)/Status
Output/
Date
Field/Project
(If Known)
Value
Goal
Dec. 2016
Chesmekosh Gas Field
Gazprom (Russia) and

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

500,000 bpd
Khuzestan province (southern Iran). Currently
max.
producing about 65,000 bpd.
Sources: Various oil and gas journals, as well as CRS conversations with some U.S. and company officials. Some
information comes from various GAO reports, the latest of which was January 13, 2015 (GAO-15-258R).
Notes: CRS has no mandate, authority, or means to determine violations of the Iran Sanctions Act, and no way
to confirm the status of any of the reported investments. The investments are private agreements between Iran
and the firms involved, which are not required to reveal the terms of their arrangements. 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.

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Appendix C. Entities Sanctioned Under U.N.
Resolutions and EU Decisions
Table C-1. Entities Sanctioned Under U.N. Resolutions and EU Decisions
Persons listed are identified by the positions they held when designated; some have since changed.
U.N. Security Council Resolutions
Entities in italics were “delisted” on Implementation Day. Entities in standard font to remain listed until Transition Day
(October 2023), unless removed earlier by Security Council
Entities Sanctioned by Resolution 1737 (resolution no longer active)
- Farayand Technique (centrifuge
- Gen. Mohammad Mehdi Nejad Mouri - Atomic Energy Organization of Iran
program)
(Malak Ashtar University of Defense
(AEIO)
Technology rector)
- Mesbah Energy Company (Arak
- Defense Industries Organization
- Bahmanyar Morteza Bahmanyar (AIO supplier)
(DIO)
official)
- Mohammad Qanadi, AEIO Vice
- 7th of Tir (DOI subordinate)
- Reza Gholi Esmaeli (AOI Official)
President
- Shahid Hemmat Industrial Group
- Ahmad Vahid Dastjerdi (Head of
- Behman Asgarpour (Arak manager)
(SHIG)—missile program
AOI)
- Ehsan Monajemi (Natanz construction
- Shahid Bagheri Industrial Group
- Maj. Gen. Yahya Rahim Safavi
manager)
(SBIG)—missile program
(Commander in Chief, IRGC)
- Jafar Mohammadi (Adviser to AEIO)
- Fajr Industrial Group—missile
- Gen. Hosein Salimi (Commander,
- Dawood Agha Jani (Natanz official)
program
IRGC Air Force)
- Ali Hajinia Leilabadi (Director of Mesbah
Energy)

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

Entities Added by Resolution 1929 (resolution no longer active)
Over 40 entities added; makes mandatory a previously nonbinding travel ban on most named Iranians of previous resolutions.
Adds one individual banned for travel—AEIO head Javad Rahiqi.
- Amin Industrial Complex; Armament
- Malek Ashtar University (subordinate -Shahid Sayyade Shirazi Industries (acts
Industries Group
of Defense Technology and Science
on behalf of the DIO)
- Defense Technology and Science
Research Center, above)
-Special Industries Group (DIO
Research Center (owned or
- Ministry of Defense Logistics Export
subordinate)
controlled by Ministry of Defense)
(sells Iranian made arms to customers
-Tiz Pars (cover name for SHIG)
- Doostan International Company
worldwide)
-Yazd Metallurgy Industries
- Farasakht Industries
- Mizan Machinery Manufacturing
- Modern Industries Technique
- First East Export Bank, PLC
- Pejman Industrial Services Corp.;
Company
- Kaveh Cutting Tools Company
- Sabalan Company; Sahand Aluminum
- Nuclear Research Center for
- M. Babaie Industries
Parts Industrial Company
Agriculture and Medicine
-Shahid Karrazi Industries
- Shahid Sattari Industries
(research component of the AEIO)
The following Revolutionary Guard affiliated firms (several are subsidiaries of Khatam ol-Anbiya, the main Guard construction
affiliate):
- Fater Institute
- Imensazan Consultant Engineers
- Oriental Oil Kish
- Garaghe Sazendegi Ghaem
Institute
- Rah Sahel
- Gorb Karbala
- Khatam ol-Anbiya
- Rahab Engineering Institute
- Gorb Nooh
- Makin
- Sahel Consultant Engineers
- Hara Company
- Omran Sahel
- Sepanir
- Sepasad Engineering Company
The following entities owned or controlled by Islamic Republic of Iran Shipping Lines (IRISL): Irano Hind Shipping
Company; IRISL Benelux; and South Shipping Line Iran.

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

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Appendix D. Entities Sanctioned under U.S. Laws
and Executive Orders
For U.S. executive order, names in italics are entities and individuals that were delisted to
implement the JCPOA. Under the JCPOA, entities in boldface were to be delisted on Transition
Day (October 2023). However, because of the U.S. withdrawal from the JCPOA in 2018, all
delisted entities were relisted on November 5, 2018, and no entities are currently planned to be
delisted.
Table D-1. Entities Designated Under U.S. Executive Order 13382 (Proliferation
Entities)
(many designations coincide with EU and UN designations)
Entity
Date Named
Shahid Hemmat Industrial Group (Iran)
June 2005,
September 2007
Shahid Bakeri Industrial Group (Iran)
June 2005,
February 2009
Atomic Energy Organization of Iran (AEOI). AEOI and 23 subsidaries remain delisted for secondary June 2005
sanctions under E.O. 13382 but are still designated as Iran-owned or controlled entities.
Novin Energy Company (Iran) and Mesbah Energy Company (Iran)
January 2006
Four Chinese entities: Beijing Alite Technologies, LIMMT Economic and Trading Company, China
June 2006
Great Wall Industry Corp, and China National Precision Machinery Import/Export Corp.
Sanam Industrial Group (Iran) and Ya Mahdi Industries Group (Iran)
July 2006
Bank Sepah (Iran)
January 2007
Kalaye Electic Company
February 2007
Defense Industries Organization (Iran)
March 2007
Pars Trash (Iran, nuclear program), Farayand Technique (Iran, nuclear program), Fajr Industries
June 2007
Group (Iran, missile program), Mizan Machine Manufacturing Group (Iran, missile program).
Aerospace Industries Organization (AIO) (Iran); Korea Mining and Development Corp. (N. Korea).
September 2007
Islamic Revolutionary Guard Corps (IRGC); Ministry of Defense and Armed Forces Logistics; Bank
October 21, 2007
Melli (Iran’s largest bank, widely used by Guard); Bank Melli Iran Zao (Moscow); Melli Bank PC
(U.K.); Bank Kargoshaee; Arian Bank (joint venture between Melli and Bank Saderat). Based in
Afghanistan; Bank Mellat (provides banking services to Iran’s nuclear sector); Mellat Bank SB CJSC
(Armenia). Reportedly has $1.4 billion in assets in UAE; Persia International Bank PLC (U.K.); Khatam
ol Anbiya Gharargah Sazendegi Nooh (main IRGC construction and contracting arm, with $7 billion
in oil, gas deals); Oriental Oil Kish (Iranian oil exploration firm); Ghorb Karbala; Ghorb Nooh
(synonymous with Khatam ol Anbiya); Sepasad Engineering Company (Guard construction affiliate);
Omran Sahel (Guard construction affiliate); Sahel Consultant Engineering (Guard construction
affiliate); Hara Company; Gharargahe Sazandegi Ghaem
Individuals: Bahmanyar Morteza Bahmanyar (AIO, Iran missile official, see above under Resolution
October 21, 2007
1737); Ahmad Vahid Dastjerdi (AIO head, Iran missile program); Reza Gholi Esmaeli (AIO, see
under Resolution 1737); Morteza Reza’i (deputy commander, IRGC). See also Resolution 1747;
Mohammad Hejazi (Basij commander). Also, Resolution 1747; Ali Akbar Ahmadian (Chief of IRGC
Joint Staff). Resolution 1747; Hosein Salimi (IRGC Air Force commander). Resolution 1737; Qasem
Soleimani (Qods Force commander). Resolution 1747.
Future Bank (Bahrain-based but allegedly controlled by Bank Melli)
March 12, 2008
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Entity
Date Named
Yahya Rahim Safavi (former IRGC Commander in Chief); Mohsen Fakrizadeh-Mahabadi (senior
July 8, 2008
Defense Ministry scientist); Dawood Agha-Jani (head of Natanz enrichment site); Mohsen Hojati
(head of Fajr Industries, involved in missile program); Mehrdada Akhlaghi Ketabachi (heads Shahid
Bakeri Industrial Group); Naser Maliki (heads Shahid Hemmat Industrial Group); Tamas Company
(involved in uranium enrichment); Shahid Sattari Industries (makes equipment for Shahid Bakeri); 7th
of Tir (involved in developing centrifuge technology); Ammunition and Metallurgy Industries Group
(partner of 7th of Tir); Parchin Chemical Industries (deals in chemicals used in ballistic missile
programs)
Karaj Nuclear Research Center; Esfahan Nuclear Fuel Research and Production Center (NFRPC); Jabber August 12, 2008
Ibn Hayyan (reports to Atomic Energy Org. of Iran, AEIO); Safety Equipment Procurement
Company; Joza Industrial Company (front company for Shahid Hemmat Industrial Group, SHIG)
Islamic Republic of Iran Shipping Lines (IRISL) and 18 affiliates, including Val Fajr 8; Kazar; Irinvestship;
September 10,
Shipping Computer Services; Iran o Misr Shipping; Iran o Hind; IRISL Marine Services; Iriatal Shipping;
2008
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 Industries Group; Farasakht
September 17,
Industries; Iran Aircraft Manufacturing Industrial Co.; Iran Communications Industries; Iran
2008
Electronics Industries; and Shiraz Electronics Industries (SEI)
Export Development Bank of Iran (EDBI). Provides financial services to Iran’s Ministry of Defense and
October 22, 2008
Armed Forces Logistics; Banco Internacional de Desarollo, 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 property in New York City on
December 17,
behalf of Iran)
2008
11 Entities Tied to Bank Melli: Bank Melli Iran Investment (BMIIC); Bank Melli Printing and Publishing;
March 3, 2009
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
IRGC General Rostam Qasemi, head of Khatem ol-Anbiya Construction Headquarters (main IRGC
February 10,
corporate arm) and several entities linked to Khatem ol-Anbiya, including Fater Engineering
2010
Institute, Imensazen Consultant Engineers Institute, Makin Institute, and Rahab Institute
- Post Bank of Iran
June 16, 2010
- 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 (SAIG, 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.
Europaisch-Iranische Handelsbank (EIH) for providing financial services to Bank Sepah, Mellat, EDBI,
September 7,
and others.
2010
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Entity
Date Named
Pearl Energy Company (formed by First East Export Bank, a subsidiary of Bank Mellat, Pearl Energy
November 30,
Services, SA, Ali Afzali (high official of First East Export Bank), IRISL front companies: Ashtead Shipping, 2010
Byfleet Shipping, Cobham Shipping, Dorking Shipping, Effingham Shipping, Farnham Shipping, Gomshall
Shipping, and Horsham Shipping (all located in the Isle of Man).- IRISL and affiliate officials:
Mohammad Hosein Dajmar, Gholamhossein Golpavar, Hassan Jalil Zadeh, and Mohammad Haji Pajand.
Bonyad (foundation) Taavon Sepah, for providing services to the IRGC; Ansar Bank (for providing
December 21,
financial services to the IRGC); Mehr Bank (same justification as above); Moallem Insurance Company 2010
(for providing marine insurance to IRISL, Islamic Republic of Iran Shipping Lines)
Bank of Industry and Mine (BIM)
May 17, 2011
Tidewater Middle East Company; Iran Air; Mehr-e Eqtesad Iranian Investment Co.
June 23, 2011
For proscribed nuclear activities, including centrifuge development and heavy water research: By
November 21,
State—Nuclear Reactor Fuels Company; Noor Afzar Gostar Company; Fulmen Group; Yasa Part. 2011
By Treasury—Javad Rahiqi; Modern Industries Technique Company; Iran Centrifuge
Technology Company (TESA); Neka Novin; Parto Sanat; Paya Partov; Simatic
Development Co
Iran Maritime Industrial Company SADRA (owned by IRGC engineering firm Khatem-ol-Anbiya, has March 28, 2012
offices in Venezuela); Deep Offshore Technology PJS (subsidiary of the above); Malship Shipping
Agency and Modality Ltd (both Malta-based affiliates of IRISL); Seyed Alaeddin Sadat Rasool (IRISL legal
adviser); Ali Ezati (IRISL strategic planning and public affairs manager)
Electronic Components Industries Co. (ECI) and Information Systems Iran (ISIRAN); Advanced
July 12, 2012
Information and Communication Technology Center (AICTC) and Hamid Reza Rabiee (software
engineer for AICTC); Digital Medical Lab (DML) and Value Laboratory (owned or controlled by
Rabiee or AICTC); Ministry of Defense Logistics Export (MODLEX); Daniel Frosh (Austria) and
International General Resourcing FZE)—person and his UAE-based firm allegedly supply Iran’s
missile industry.
National Iranian Oil Company; Tehran Gostaresh, company owned by Bonyad Taavon Sepah; Imam
November 8,
Hossein University, owned by IRGC; Baghyatollah Medical Sciences University, owned by IRGC or
2012
providing services to it.
Atomic Energy Organization of Iran (AEOI) chief Fereidoun Abbasi Davani; Seyed Jaber Safdari
December 13,
of Novin Energy, a designated affiliate of AEOI; Morteza Ahmadi Behzad, provider of services to
2012
AEOI (centrifuges); Pouya Control—provides goods and services for uranium enrichment; Iran
Pooya—provides materials for manufacture of IR-1 and IR-2 centrifuges; Aria Nikan Marine
Industry—source of goods for Iranian nuclear program; Amir Hossein Rahimyar—procurer
for Iran nuclear program; Mohammad Reza Rezvanianzadeh—involved in various aspects of nuclear
program; Faratech—involved in Iran heavy water reactor project; Neda Industrial Group—
manufacturer of equipment for Natanz enrichment facility; Tarh O Palayesh—designer of
elements of heavy water research reactor; Towlid Abzar Boreshi Iran—manufacturer for
entities affiliated with the nuclear program.
SAD Import Export Company (also designated by U.N. Sanctions Committee a few days earlier for
December 21,
violating Resolution 1747 ban on Iran arms exports, along with Yas Air) for shipping arms and other 2012
goods to Syria’s armed forces; Marine Industries Organization—designated for affiliation with Iran
Ministry of Defense and Armed Forces Logistics; Mustafa Esbati, for acting on behalf of Marine
Industries; Chemical Industries and Development of Materials Group—designated as affiliate of
Defense Industries Org.; Doostan International Company—designated for providing services to Iran
Aerospace Industries Org, which oversees Iran missile industries.
Babak Morteza Zanjani—chairmen of Sorinet Group that Iran uses to finance oil sales abroad;
April 11, 2013
International Safe Oil—provides support to NIOC and NICO; Sorinet Commercial Trust Bankers
(Dubai) and First Islamic Investment Bank (Malaysia)—finance NIOC and NICO; Kont Kosmetik and
Kont Investment Bank—controlled by Babak Zanjani; Naftiran Intertrade Company Ltd.—owned by
NIOC.
Iranian-Venezuelan Bi-National Bank (IVBB), for activities on behalf of the Export Development Bank
May 9, 2013
of Iran that was sanctioned on October 22, 2008 (see above). EDBI was sanctioned for providing
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Entity
Date Named
financial services to Iran’s Ministry of Defense. Aluminat, for providing centrifuge components to
Kalaye Electric Co.; Pars Amayesh Sanaat Kish; Pishro Systems Research Company (nuclear
research and development); Taghtiran Kashan Company; and Sambouk Shipping FZC (UAE)
For supporting Iran Air, the IRGC, and NIOC: Aban Air; Ali Mahdavi (part owner of Aban Air); DFS
May 23, 2013
Worldwide; Everex; Bahareh Mirza Hossein Yazdi; Farhad Ali Parvaresh; Petro Green; Hossein Vaziri.
For helping Iran’s nuclear program: Farhad Bujar; Zolal Iran Company; Andisheh Zolal Co.
For helping MODAFL: Reza Mozaffarinia.
Bukovnya AE (Ukraine) for leasing aircraft to Iran Air.
May 31, 2013
Several Iranian firms and persons: Eyvaz Technic Manufacturing Company; The Exploration
December 12,
and Nuclear Raw Materials Company; Maro Sanat Company; Navid Composite Material
2013
Company; Negin Parto Khavar; Neka Novin officials Iradj Mohammadi Kahvarin and
Mahmoud Mohammadi Dayeni; Neka Novin alisaes including Kia Nirou; Qods Aviation
Industries (operated by IRGC, produces UAVs, paragliders, etc); Iran Aviation Industries
Organization; Reza Amidi; Fan Pardazan; Ertebat Gostar Novin.
Ali Canko (Turkey) and Tiva Sanat Group, for procuring IRGC-Navy fast boats; Advance
February 6, 2014
Electrical and Industrial Technologies and Pere Punti (Spain), for procurement for Neka
Novin; Ulrich Wipperman and Deutsche Forfait (Germany), and Deutsche Forfait Americas (U.S.) for
facilitating oil deals for NIOC.
Karl Lee (aka Li Fangwei) and 8 China-based front companies: Sinotech Industry Co. Ltd.; MTTO
April 29, 2014
Industry and Trade Limited; Success Move Ltd.; Sinotech Dalian Carbon and Graphite
Manufacturing Corporation; Dalian Zhongchuang Char-White Co., Ltd.; Karat Industry Co., Ltd.;
Dalian Zhenghua Maoyi Youxian Gongsi; and Tereal Industry and Trade Ltd.
By State: Organization of Defensive Innovation and Research (nuclear research); Nuclear
April 29, 2014
Science and Technology Research Institute (implements nuclear projects including heavy water
(by both State
reactor at Arak); Jahan Tech Rooyan Pars: and Mandegar Baspar Kimiya Company (latter
and Treasury)
two are involved in procuring carbon fiber for proscribed aspects of Iran’s nuclear program).
By Treasury: Mohammad Javad Imarad and Arman Imanirad (for acting on behalf of
Aluminat, which procures aluminum products for Iran’s nuclear program); Nefertiti Shipping (IRISL’s
agent in Egypt); Sazeh Morakab (provides services to Shahid Hemat Industrial Group, SHIG, and
Iran’s Aircraft Manufacturing Industrial Co., HESA); Ali Gholami and Marzieh Bozorg (officials of
Sazeh Morakab). SHIG aliases identified: Sahand Aluminum Parts Co and Ardalan Machineries Co.
11 ballistic missile-related entities: Mabrooka Trading Co LLC (UAE); Hossein
January 17, 2016
Pournaghshband; Chen Mingfu; Anhui Land Group (Hong Kong); Candid General Trading; Rahim

Reza Farghadani; Sayyed Javad Musavi; Seyed Mirahmad Nooshin; Sayyed Medhi Farahi (deputy
director of the Ministry of Defense and Armed Forces Logistics); Seyed Mohammad Hashemi;
Mehrdada Akhlaghi Ketabachi. According to the designations, Musavi (has worked with North
Korean officials involved in that country’s ballistic missile programs.
Two Iranian entities subordinate to SHIG: Shahid Nuri Industries and Shahid Movahed Industries.

Updating of prior IRGC Missile Command designation to include IRGC Al Ghadir Missile Command
(specific IRGC element with operational control of Iran’s missile program).
17 ballistic missile-related Entities. Abdollah Asgharzadeh Network (for supporting SHIG):
February 3, 2017
Abdollah Asgharzadeh; Tenny Darian; East Start Company; Ofog Sabze Company; Richard Yue

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

SHIG); and Ruan Ruling and three associated Chinese companies (for supporting Iran’s missile
guidance capabilities): Shanghai Gang Quan Trade Company, Shanghai North Begins International,
and Shanghai North Transway International Trading Company.
12 IRGC/military and ballistic missile entities designated by Treasury and two by State. By
July 18, 2017
Treasury: Rayan Roshd Afzar Company for IRGC drone and censorship equipment, plus three

company officials: Mohsen Parsajam, Seyyed Reza Ghasemi, and Farshad Hekemzadeh; Qeshm
Madkandaloo Cooperative Co., Ramor Group (Turkey) and Resit Tavan of Ramor Group for
supplying IRGC-Navy infrastructure; Emily Liu, Abascience Tech Co. Ltd, Raybeam Optronics Co.
Ltd., Raytronic Corporation Ltd., and Sunway Tech Co. Ltd (all China) for supporting MODAFL
subcontractor Shiraz Electronics Industries. By State: IRGC Aerospace Force Self Sufficiency Jihad
Org and IRGC Research and Self Sufficiency Jihad Org—both for supporting Iran ballistic missile
program.
Missile entities related to Iran Simorgh space launch on July 27: six subordinate entities to
July 28, 2017
Shahid Hemmat Industrial Group (SHIG, main Iran missile contractor) involved in making various

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

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

Research Center; and Shahid Shustari Industries.
Green Wave Telecommunications (Malaysia) and Morteza Razavi (for supporting Fanamoj,
January 12, 2018
designated on October 13, 2017); Iran Helicopter Support and Renewal Company (PANHA) and
Iran Aircraft Industries (SAHA) (for supporting Iran’s military aviation industry); Shi Yuhua (China)
(for selling Iran navigation equipment); Pardazan System Namad Arman (PASNA)(for procuring lead
zirconium tritanate (PZT) for Iranian military undersea and aircraft weaponry); and Bochuang
Ceramic Inc. and Zhu Yuequn (China) for selling Iran PZT.
Sayyed Mohammad Ali Haddadnezhad Tehrani, for supporting the IRGC Research and Self-
May 22, 2018
Sufficiency Jihad Organization (see above), which is improving Houthi missile capabilities
Bank Tejarat (for providing servides to support Bank Sepah); Trade Capital Bank (Belarus); Morteza November 5,
Ahmadali Behzad (for acting on behalf of Pishro Company.
2018
31 individuals/entities connected to Iran’s Organization of Defense Innovation and
March 22, 2019
Research (SPND), itself designated in April 2014 (see above): Shahid Karimi Group—missiles and
explosives—and four of its employees—Mohammad Reza Mehdipur, Akbar Motallebizadeh, Jalal
Emami Gharah Hajjlu, and Sa’id Borji. Shahid Chamran Group—studies on electron acceleration,
pulse power, wave generation—and its managing expert Sayyed Ashgar Hashemitabar. Shahid
Fakhar Moghaddam Group—explosion simulators, neutron monitoring systems—and two
employees Ruhollah Ghaderi Barmi, and Mohammad Javad Safari. Ten entities that research lasers,
plasma technology, satellites, biotechnology, and other technologies for SPND: Sheikh Baha’i
Science and Technology Research Center, Shahid Avini Group, Shahid Baba’i Group, Shahid
Movahhed Danesh Group, Abu Reihan Group, Shahid Kazemi Group, Shahid Shokri Science and
Technology Research Group, Heidar Karar Research Group, Shahid Zeinoddin Group, Bu Ali
Group, and Sadra Research Center. Three persons acting on behalf of SPND: Gholam Reza Eta’ati,
Mansur Asgari, and Reza Ebrahimi. Three SPND front companies and four of their officials: Pulse
Niru and officials Mohammad Mahdi Da’emi Attaran and Mohsen Shafa’i; Kimiya Pakhsh Shargh and
officials Mehdi Masoumian, and Mohammad Hossein Haghighian; and Paradise Medical Pioneers
Company.
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Iran Sanctions

Entity
Date Named
Petrochemicals Network: Persian Gulf Petrochemical Industries Company (PGPIC), for
June 7, 2019
supporting the IRGC’s engineering conglomerate Khatem ol-Anbiya, and 39 PGPIC subsidiaries and
sales agents: Arvand Petrochemical Co.; Bandar Imam Abniroo Petrochemical Co (PC).; Bandar
Imam Besparan PC; Bandar Imam Faravaresh PC; Bandar Imam Kharazmi PC; Bandar Imam Kimiya
PC; Bandar Imam PC; Bu Al Sina PC; Fajr PC; Hengam PC; Hormoz Urea Fertilizer Co.; Iranian
Investment Petrochemical Group Co.; Karoun PC; Khouzestan PC; Lordegan Urea Fertilizer Co.;
Mobin PC; Modabberan Eqtesad Co.; Nouri PC; Pars PC; Pazargad Non Industrial Operation Co.;
Persian Gulf Apadana PC; Persian Gulf Bid Boland Gas Refinery Co.; Persian Gulf Petrochemical
Industry Commercial Co.; Persian Gulf Fajr Yadavaran Gas Refinery Co.; Petrochemical Industries
Development Management Co.; Rahavaran Fonoon PC; Shaid Tondgoyan PC; Urmia PC; Hemmat
PC; Petrochemical Non-Industrial Operations and Services Co.; Ilam PC; Gachsaran Polymer
Industries; Dah Dasht Petrochemical Industries; Broojen PC; NPC International (UK); NPC Alliance
Corp. (Philippines); Atlas Ocean and Petrochemical (UAE); and Naghmeh FZE (UAE).
Missile Proliferation Entities: Hamid Dehghan, Pishtazan Kavosh Gostar Boshra LLC (PKGB),
August 28, 2019
Ebtekar Sanat Ilya, Hadi Dehghan, Shaghayegh Akhaei, Mahdi Ebrahimzadeh, Shafagh Senobar Yazd,
and Green Industries (Hong Kong). Also designated: Asre Sanat Eshragh Company and Seyed
Hossein Shariat for procuring aluminum alloy for Iran.
Iranian Space Entities: Astronautics Research Institute, Iran Space Agency, Iran Space Research
September 3,
Center.
2019

Table D-2. Iran-Related Entities Sanctioned Under Executive Order 13224
(Terrorism Entities)
Entity
Date Named
Martyr’s Foundation (Bonyad Shahid), a major Iranian foundation (bonyad)—for providing financial
July 25, 2007
support to Hezbollah and PIJ; Goodwill Charitable Organization, a Martyr’s Foundation office in
Dearborn, Michigan; Al Qard Al Hassan—part of Hezbollah’s financial infrastructure (and associated
with previously designated Hezbollah entities Husayn al-Shami, Bayt al-Mal, and Yousser Company
for Finance and Investment); Qasem Aliq—Hezbollah official, director of Martyr’s Foundation
Lebanon branch, and head of Jihad al-Bina, a previously designated Lebanese construction company
run by Hezbollah; Ahmad al-Shami—financial liaison between Hezbollah in Lebanon and Martyf’s
Foundation chapter in Michigan.
IRGC-Qods Force and Bank Saderat (allegedly used to funnel Iranian money to Hezbollah, Hamas,
October 21, 2007
PIJ, and other Iranian supported terrorist groups)
Al Qaeda Operatives in Iran: Saad bin Laden; Mustafa Hamid; Muhammad Rab’a al-Bahtiyti; Alis Saleh January 16, 2009
Husain.
Qods Force senior officers: Hushang Allahdad, Hossein Musavi,Hasan Mortezavi, and Mohammad
August 3, 2010
Reza Zahedi; Iranian Committee for the Reconstruction of Lebanon, and its director Hesam
Khoshnevis, for supporting Lebanese Hezbollah; Imam Khomeini Relief Committee Lebanon branch,
and its director Ali Zuraik, for providing support to Hezbollah; Razi Musavi, a Syrian based Iranian
official allegedly providing support to Hezbollah.
Liner Transport Kish (for providing shipping services to transport weapons to Lebanese Hezbollah)
December 21, 2010
Qasem Soleimani (Qods Force commander); Hamid Abdollahi (Qods force); Abdul Reza Shahlai
October 11, 2011
(Qods Force); Ali Gholam Shakuri (Qods Force); Manssor Arbabsiar (alleged plotter)
Mahan Air (for transportation services to Qods Force)
October 12, 2011
Ministry of Intelligence and Security of Iran (MOIS)
February 16, 2012
Five entities/persons for weapons shipments to Syria and an October 2011 shipment to Gambia,
March 27, 2012
intercepted in Nigeria: Yas Air (successor to Pars Air); Behineh Air (Iranian trading company); Ali
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Iran Sanctions

Entity
Date Named
Abbas Usman Jega (Nigerian shipping agent); Qods Force officers: Esmail Ghani, Sayyid Ali
Tabatabaei, and Hosein Aghajani.
Mohammad Minai, senior Qods Force member involved in Iraq; Karim Muhsin al-Ghanimi, leader of
November 8, 2012
Kata’ib Hezbollah (KH) militia in Iraq; Sayiid Salah Hantush al-Maksusi, senior KH member; and
Riyad Jasim al-Hamidawi, Iran based KH member.
Ukraine-Mediterranean Airlines (Um Air, Ukraine) for helping Mahan Air and Iran Air conduct illicit
May 31, 2013
activities; Rodrigue Elias Merhej (owner of Um Air); Kyrgyz Trans Avia (KTA, Kyrgyzstan) for
leasing aircraft to Mahan Air; Lidia Kim, director of KTA; Sirjanco (UAE) for serving as a front for
Mahan Air acquisition of aircraft; Hamid Arabnejad, managing director of Mahan Air.
Several persons/entities in UAE aiding Mahan Air (see above): Blue Sky Aviation FZE; Avia Trust
February 6, 2014
FZE; Hamidreza Malekouti Pour; Pejman Mahmood Kosrayanifard; and Gholamreza Mahmoudi.
Several IRGC-Qods Force offices or facilitators involved in Iran’s efforts in Afghanistan: Sayyed
Kamal Musavi; Alireza Hemmati; Akbar Seyed Alhosseini; and Mahmud Afkhami Rashidi.
One Iran-based Al Qaeda facilitator (supporting movement of Al Qaeda affiliated fightes to Syria):
Olimzhon Adkhamovich Sadikov (aka Jafar al-Uzbeki or Jafar Muidinov).
Meraj Air (for delivering weapons to Syria from Iran); Caspian Air (supports IRGC by transporting
August 29, 2014
personnel and weapons to Syria); Sayyed Jabar Hosseini (manager of Liner Transport Kish which
IRGC uses to support terrorist activities outside Iran); Pioneer Logistics (Turkey, helps Mahan Air
evade sanctions); Asian Aviation Logistics (Thailand, helps Mahan Air evade sanctions). Pouya Air
designated as alias of Yas Air.
Al Naser Airlines (Iraq) for transferring nine aircraft to Mahan Air, which is a 13224 designee: Issam
May 21, 2015
Shamout, a Syrian businessman, and his company Sky Blue Bird Aviation, for the same transaction.
Four U.K.-based and two UAE-based entities for supporting Mahan Air. U.K.: Jeffrey John James
March 24, 2016
Ashfield; Aviation Capital Solutions; Aircraft, Avionics, Parts and Support Ltd (AAPS); John Edward
Meadows (for acting on behalf of AAPS). UAE: Grandeur General Trading FZE and HSI Trading FZE.
Eight IRGC-QF and Hezbollah-related entities. Lebanon-Based IRGC-QF Network: Hasan
February 3, 2017
Dehghan Ebrahimi (IRGC-QF operative in Beirut supporting Hezbollah); Muhammad Abd-al-Amir
Farhat; Yahya al-hajj; Maher Trading and Construction Company (laundering funds and smuggling
goods to Hezbollah); Reem Phamaceutical; Mirage for Engineering and Trading; Mirage for Waste
Management and Environmental Services. Ali Sharifi (for procuring aviation spare parts for the
IRGC-QF).
Islamic Revolutionary Guard Corps (IRGC)
October 13, 2017
Six entities involved in IRGC-QF counterfeiting: Reza Heidari; Pardazesh Tasvir Rayan Co. (Rayan
November 20, 2017
Printing); ForEnt Technik and Printing Trade Center GmbH (Germany); Mahmoud Seif; Tejarat
Almas Mobin Holding (parent of Rayan Printing).
Nine individuals and entities, disrupted by U.S.-UAE joint action, attempting to acquire
May 10, 2018
dollars in UAE to provide to the IRGC-QF: Individuals: Mas’ud Nikbakht, Sa’id Najafpur, and
Mohammad Khoda’i, for financial activities on behalf of the IRGC-QF; Mohammadreza Valadzaghard,
Meghdad Amini, and Foad Salehi, for providing material support, including illicit financial assistance,
to the IRGC-QF. Entities: Jahan Aras Kish, a front company involved in transferring and converting
funds for the IRGC-QF, Rashed Exchange, for converting currency for the IRGC-QF, and Khedmati
and Company Joint Partnership, for being owned by Khedmati and Khoda’i.
Persons and entities providing funds to Hezbollah on behalf of the IRGC-QF: Central
May 15, 2018
Bank Governor Valiollah Seif; Aras Habib and his Iraq-based Al Bilad Islamic Bank; and Muhammad
Qasir
Four persons for helping the Houthi missile program through the IRGC Aerospace Forces Al
May 22, 2018
Ghadir Missile Command: Mahmud Bagheri Kazemabad; Mohammad Agha Ja’fari; Javad Bordbar Shir
Amin; and Mehdi Azarpisheh (IRGC-QF affiliate)
Twenty-one entities linked to the Basij security force, including firms it owns or controls that
October 16,2018
provide it revenue to send child soldiers to fight in Syria: Bonyad Taavon Basij (economic
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Entity
Date Named
conglomerate giving financial support to Basij members); Mehr Eqtesad Bank; Bank Mellat; Mehr
Eqtesad Iranian Investment Company; Tadbirgaran Atiyeh Investment Company; Negin Sahel Royal
Company; Mehr Eqtesad Financial Group; Technotar Engineering Company; Iran Tractor
Manufacturing Company (owned by Mehr Investment and Negin above); Taktar Investment
Company; Iran’s Zinc Mines Development Company; Calcimin (owned by Iran Zinc Mines above);
Bandar Abbas Zinc Production Company; Qeshm Zinc Smelting and Reduction Company; Zanjan
Acid Production Company; Parsian Catalyst Chemical Company; Esfehan’s Mobarakeh Steel
Company (largest steel maker in Middle East and North Africa); Andisheh Mehvaran Investment
Company; Parsian Bank; Sina Bank; and Bahman Group.
IRGC-QF personnel supporting the Taliban in Afghanistan (in conjunction with U.S.-GCC Terrorist
October 23, 2018
Financing Targeting Center): Mohammad Ebrahim Owhadi and Esma’il Razavi
Banks and other Entities newly designated. Many of these entities are also being redesignated
November 5, 2018
under EO13382, but their designations below under 13224 is new. Aircraft and vessels are not
(in concert with
included: Bank Melli; Arian Bank; Bank Kargoshaee; Melli Bank PLC; Tose-E Develoment Company;
reimposition of
Behshahr Industrial Development Corp.; Cement Industry and Development Company; Melli
JCPOA-related
International Building and Industry Company; BMIIC International General Trading LLC; Shomal
sanctions)
Cement Company; Persian Gulf Sabz Karafarinan; Mir Business Bank; Export Development Bank of
Iran (EDBI); EDBIStock Exchange; EDBI Exchange Brokerage; Banco Internacional de Desarrollo,
C.A.; Iran-Venezuela Bi-National Bank; Day Bank and subsidiaries—Atieh Sazan Day; Buali
Investment Company; Tejarat Gostar Fardad; Day Exchange Company; Day Leasing Co.; Day
Brokerage Co.; Tose-e Didar Iran Holding Co.; Royay-e Roz Kish Investment Co; Day E-
Commerce; Tose-e Donya Shahr Kohan Co.; Damavand Power Generation Co,; Omid Bonyan Day
Insurance Services; Omran Va Maskan Abad Day Co.; Day Iranian Financial and Accounting Services
Co.; Persian International Bank PLC; First East Export Bank PLC; Mellat Bank Close Joint-Stock Co.;
Bank Tejarat; and Trade Capital Bank (Belarus).
Four Hezbollah and IRGC-QF-related individuals who operate in Iraq : Shibl Mushin ‘Ubayd Al-
November 13, 2018
Zaydi; Yusuf Hashim; Adnan Hussein Kawtharani; Muhammad ‘Abd-Al-Hadi Farhat
Individuals involved in a network through which Iran provides oil to Syria’s government
November 20, 2018
and transfer funds to Iranian proxies including Hezbollah and Hamas: Mohamed Amer
Alchwiki (also designated under E.O. 13582 for providing financial support to the government of
Syria); Global Vision Group (also designated under E.O. 13582); Rasul Sajjad and Hossein Yaghoobi
(for assisting the IRGC-QF); and Muhammad Qasim al-Bazzal (for assisting Hezbollah).
Also designated under E.O. 13582 as part of the network: Promsyrioimport; Andrey Dogaev; Mir
Business Bank; and Tadbir Kish Medical and Pharmaceutical Company
Two Iran-recruited Afghan and Pakistani-staffed militia entities fighting in Syria:
January 24, 2019
Fatemiyoun Division and Zaynabiyoun Brigade. Qeshm Fars Air and Flight Travel LLC—Mahan Air
affiliates—for weapons deliveries into Syria.
Iraq-related entities: Harakat al-Nujaba (HAN), Iraqi Shia militia; and HAN leader Akram Abbas
March 5, 2019
al-Kabi (previously sanctioned in 2008 when he headed a Mahdi Army “special group” militia)
25 individuals and entities that illicitly moved more $1 billion+ to the IRGC via the
March 26, 2019
IRGC-controlled Ansar Bank and Ansar Exchange: (Iran) Ministry of Defense and Armed
Forces Logistics (MODAFL); Ansar Bank, its managing director Ayatollah Ebrahimi, and affiliates
Iranian Atlas Company, Ansar Bank Brokerage Company, and Ansar Information Technology; Ansar
Exchange, its managing director Alireza Atabaki, and UAE-based facilitators Reza Sakan, Mohammad
Vakili and the Vakili-owned Atlas Exchange; Zagros Pardis Kish for helping MODAFL acquire
vehicles in UAE, and its manager Iman Sedaghat; Sakan General Trading (UAE), its owner, Rez Sakan
and Iran-based affiliate Sakan Exchange; Hital Exchange and its owner Seyyed Mohammad Reza Ale
Ali; Golden Commodities General Trading (UAE), its owner Assadolah Seifi, and another Seifi-
owned UAE firm The Best Leader General Trading; Sulayman Sakan and his firm Atlas Doviz Ticaret
A.S. (Turkey) for assisting Atlas Exchange; Ali Shams Mulavi—Turkey-based financial facilitator for
Ansar Exchange and his UAE-based firm Naria General Trading; Lebra Moon General Trading
(UAE).
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Iran Sanctions

Entity
Date Named
Iraq-based entities facilitating IRGC-QF access to Iraq’s financial system: South Wealth
June 12, 2019
Resources Company (aka Manabea Tharwat al-Janoob General Trading Co.); Makki Kazim ‘Abd l
Hamid Al Asadi; and Muhammed Husayn Salih al-Hasani
Eight IRGC Commanders: IRGC Navy Commander Ali Reza Tangsiri; IRGC Aerospace
June 24, 2019
Commander Amirali Hajizadeh; IRGC Ground Forces Commander Mohammad Pakpour; and five
IRGC Navy district commaners: Abbas Gholamshahi (district 1); Ramezan Zirahi (district 2);
Yadollah Badin (district 3); Mansur Ravankar (district 4); and Ali Ozma’I (district 5)
Hezbollah Parliamentarians: Two Hezbollah parliamentarians for using their parliamentary
July 9, 2019
positions to advance Hezbollah objectives and “bolstering Iran’s malign activities”: Amin Sherri and
Muhammad Hasan Ra’d (who is also a member of Hezbollah’s Shura Council). Also designated: head
of Hezbollah security and liaison to Lebanon’s security services Wafiq Safa.
Financial Institutions used by Hezbollah (all in Lebanon): Jammal Trust Bank SAL; Trust
August 29, 2019
Insurance SAL; Trust Insurance Services SAL; Trust Life Insurance Company SAL
Financial Facilitators Moving Funds from IRGC-QF to Hamas: Muahmmad Sarur; Kamal
August 29, 2019
Abdelrahman Aref Awad; Fawaz Mahmud Ali Nasser; Muhammad Al-Ayy. Designations made in
partnership with the Sultanate of Oman
Oil Tanker Seized and Released by Gibraltar: Adrian Darya 1 and Akhilesh Kumar (ship and
August 30, 2019
captain, for carrying oil to Syria)
Iran Oil Shipping Network: 16 entities and 10 persons, including: Rostam Qasemi (former Oil
September 4, 2019
Minister, now head of Iranian-Syrian Economic Relations Development Committee); Mehdi Group
and subsidiaries (India) – Bushra Ship Management Private Limited, Khadija Ship Management Private
Limited, Vaniya Ship Management. Kish P and I Club shipping insurer (Iran). Hokoul SAL Offshore,
Talaqi Group, Nagham Al Hayat, Tawafuk, ALUMIX (Lebanon) for supplying Syrian state owned
Sytrol oil company under IRGC-QF auspices.

Table D-3. Determinations and Sanctions under the Iran Sanctions Act
Entity
Date Named
Total SA (France); Gazprom (Russia); and Petronas (Malaysia)—$2 billion project to develop South Pars gas
May 18, 1998
field. ISA violation determined but sanctions waived in line with U.S.-EU agreement for EU to cooperate on
antiterrorism and antiproliferation issues and not file a complaint at the WTO. Then-Secretary of State
Albright, in the May 18, 1998, waiver announcement indicated that similar future such projects by EU firms
in Iran would not be sanctioned. (http://www.parstimes.com/law/albright_southpars.html). Violation
determined but sanctions waived.
Naftiran Intertrade Co. (NICO), Iran and Switzerland. Sanctioned for activities to develop Iran’s energy
Sept. 30, 2010
sector. Sanctions lifted under JCPOA.
Total (France); Statoil (Norway); ENI (Italy); and Royal Dutch Shell.
Sept. 30, 2010
Exempted under ISA “special rule” for pledging to wind down work on Iran energy fields.
Inpex (Japan)
Nov. 17, 2010
Exempted under the Special rule for divesting its remaining 10% stake in Azadegan oil field.
Belarusneft (Belarus, subsidiary of Belneftekhim) Sanctioned for $500 million contract with NICO (see
March 29, 2011
above) to develop Jofeir oil field. Other subsidiaries of Belneftekhim were sanctioned in 2007 under E.O.
13405 (Belarus sanctions). Sanctions remain.
Petrochemical Commercial Company International (PCCI) of Bailiwick of Jersey and Iran; Royal Oyster
May 24, 2011
Group (UAE); Tanker Pacific (Singapore); Allvale Maritime (Liberia); Societie Anonyme Monegasque Et
Aerienne (SAMAMA, Monaco); Speedy Ship (UAE/Iran); Associated Shipbroking (Monaco); and Petroleos de
Venezuela (PDVSA, Venezuela).
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Iran Sanctions

Entity
Date Named
Sanctioned under CISADA amendment to ISA imposing sanctions for selling gasoline to Iran or helping Iran
import gasoline. Allvale Maritime and SAMAMA determinations were issued on September 13, 2011, to
“clarify” the May 24 determinations that had named Ofer Brothers Group. The two, as well as Tanker
Pacific, are affiliated with a Europe-based trust linked to deceased Ofer brother Sami Ofer, and not Ofer
Brothers Group based in Israel. Firms named subjected primarily to the financial sanctions provided in ISA.
U.S.-based subsidiaries of PDVSA, such as Citgo, were not sanctioned. Sanctions lifted under JCPOA.
Zhuhai Zhenrong Co. (China); Kuo Oil Pte Ltd. (Singapore); FAL Oil Co. (UAE)
January 12, 2012
Sanctioned for brokering sales or making sales to Iran of gasoline. Sanctions lifted under JCPOA.
Sytrol (Syria), for sales of gasoline to Iran. Sanctions remain.
August 12, 2012
Dr. Dimitris Cambis; Impire Shipping; Kish Protection and Indemnity (Iran); and Bimeh Markasi-Central
March 14, 2013
Insurance of Iran (CII, Iran)
Sanctioned under ISA provision on owning vessels that transport Iranian oil or providing insurance for the
shipments. Treasury sanctions also imposed on eight UAE-based oil traders that concealed the transactions.
Sanctions lifted under JCPOA.
Tanker Pacific; SAMAMA; and Allvale Maritime
April 12, 2013
Sanctions lifted. Special rule applied after “reliable assurances” they will not engage in similar activity in the future.
Ferland Co. Ltd. (Cyprus and Ukraine)
May 31, 2013
Sanctioned for cooperating with National Iranian Tanker Co. to illicitly sell Iranian crude oil. Sanctions lifted
under JCPOA.
Dettin SPA Italy-based company sanctioned for providing goods and services to Iran’s petrochemical
August 29, 2014
industry. Sanctions lifted under JCPOA.

Table D-4. Entities Sanctioned Under the Iran North Korea Syria Nonproliferation
Act or Executive Order 12938 for Iran-Specific Violations
These designations expire after two years, unless redesignated. The designations included in this table are
those that were applied specifically for proliferation activity involving Iran.
Entity
Date Named
Baltic State Technical University and Glavkosmos, both of Russia.
July 30, 1998
(both designations revoked in 2010)
D. Mendeleyev University of Chemical Technology of Russia and Moscow Aviation Institute (both removed
January 8, 1999
on May 21, 2010)
Changgwang Sinyong Corp. (North Korea)
January 2, 2001
Changgwang Sinyong Corp. (North Korea) and Jiangsu Yongli Chemicals and Technology Import-Export
June 14, 2001
(China)
Three entities from China for proliferation to Iran
January 16, 2002
Armen Sargsian and Lizen Open Joint Stock Co. (Armenia); Cuanta SA and Mikhail Pavlovich Vladov
May 9, 2002
(Moldova); and eight China entities for proliferation involving Iran
Norinco (China). For alleged 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-guided artillery shells to Iran. (Also
September 17,
designated under Executive Order 12938)
2003
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Iran Sanctions

Entity
Date Named
13 entities from Russia, China, Belarus, Macedonia, North Korea, UAE, and Taiwan.
April 1, 2004
14 entities from China, North Korea, Belarus, India (two nuclear scientists, Dr. Surendar and Dr. Y.S.R.
September 23,
Prasad), Russia, Spain, and Ukraine.
2004
14 entities, mostly from China, for supplying of Iran’s missile program. Designations included North Korea’s
December 2004
Changgwang Sinyong and China’s Norinco and Great Wall Industry Corp, have been sanctioned several
and January 2005
times previously. Others sanctioned included North Korea’s Paeksan Associated Corporation, and Taiwan’s
Ecoma Enterprise Co.
Nine entities, including from China (Norinco, Hondu Aviation, Dalian Sunny Industries, Zibo Chemet
December 23,
Equipment); India (Sabero Organicx Chemicals and Sandhya Organic Chemicals); and Austria (Steyr
2005
Mannlicher Gmbh). Sanctions against Dr. Surendar of India (see September 29, 2004) were ended because
of information exonerating him.
Two Indian chemical companies (Balaji Amines and Prachi Poly Products); two Russian firms
July 28, 2006
(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).
Abu Hamadi (Iraq); Aerospace Logistics Services (Mexico); Al Zargaa Optical and Electronics (Sudan);
December 28,
Alexey Safonov (Russia); Arif Durrani (Pakistan)China National Aero Technology Import-Export (China);
2006
China National Electronic Import Export (China); Defense Industries Org. (Iran); Giad Industrial Complex
(Sudan); Iran Electronics Industry (Iran); Kal al-Zuhiry (Iraq); Kolomna Design Bureau of Machine Building
(Russia); NAB Export Co. (Iran); Rosoboronexport (Russia); Sanam Industrial Group (Iran); Target
Airfreight (Malaysia); Tula Design Bureau of Instrument Building (Russia); Yarmouk Industrial Complex
(Sudan) Zibo Chemet Equipment Co. (China)
Rosobornexport, Tula Design, and Komna Design Office of Machine Building, and Alexei Safonov (Russia);
January 2007 (see
Zibo Chemical, China National Aerotechnology, and China National Electrical (China). Korean Mining and
below for Tula and
Industrial Development (North Korea) for WMD/advanced weapons sales to Iran and Syria.
Rosoboronexport
removal)
14 entities, including Lebanese Hezbollah. Some were penalized for transactions with Syria. Among the new
April 17, 2007
entities sanctioned for assisting Iran were Shanghai Non-Ferrous Metals Pudong Development Trade
Company (China); Iran’s Defense Industries Organization; Sokkia Company (Singapore); Challenger
Corporation (Malaysia); Target Airfreight (Malaysia); Aerospace Logistics Services (Mexico); and Arif
Durrani (Pakistani national).
China Xinshidai Co.; China Shipbuilding and Offshore International Corp.; Huazhong CNC (China); IRGC;
October 23, 2008
Korea Mining Development Corp. (North Korea); Korea Taesong Trading Co. (NK); Yolin/Yullin Tech, Inc.
(South Korea); Rosoboronexport (Russia sate arms export agency); Sudan Master Technology; Sudan
Technical Center Co; Army Supply Bureau (Syria); R and M International FZCO (UAE); Venezuelan Military
Industries Co. (CAVIM). (Rosoboronexport removed May 21, 2010.)
BelTechExport (Belarus); Dalian Sunny Industries (China); Defense Industries Organization (Iran); Karl Lee;
July 14, 2010
Shahid Bakeri Industries Group (SBIG); Shanghai Technical By-Products International (China); Zibo Chemet
Equipment (China)
16 entities: Belarus: Belarusian Optical Mechanical Association; Beltech Export; China: Karl Lee; Dalian
May 23, 2011
Sunny Industries; Dalian Zhongbang Chemical Industries Co.; Xian Junyun Electronic; Iran: Milad Jafari; DIO;
IRISL; IRGC Qods Force; SAD Import-Export; SBIG; North Korea: Tangun Trading; Syria: Industrial
Establishment of Defense; Scientific Studies and Research Center; Venezuela: CAVIM.
Belvneshpromservice (Belarus); Dalian Sunny Industries (China); Defense Industries Organization (Iran); Karl December 20,
Lee (China); SAD Import-Export (Iran); Zibo Chemet Equipment Co. (Iran); F
2011
Al Zargaa Engineering Complex (Sudan); BST Technology and Trade Co. (China); China Precision Machinery February 5, 2013
Import and Export Co. (China); Dalian Sunny Industries (China); Iran Electronics Industries (Iran); Karl Lee
(these designations,
(China); Marine Industries Organization (Iran); Milad Jafari (Iran); Poly Technologies (China); Scientific and
and prior
Industrial Republic Unitary Enterprise (Belarus); SMT Engineering (Sudan); TM Services Ltd. (Belarus);
designations above,
Venezuelan Military Industry Co. (CAVIM, Venezuela).
have expired)
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Entity
Date Named
Al Zargaa Engineering Complex (Sudan); Belvneshpromservice (Belarus); HSC Mic NPO Mashinostroyenia
December 19,
(Russia); Russian Aircraft Corporation (MiG); Giad Heavy Industries Complex (Sudan); Sudan Master
2014. Sanctions still
Technologies (Sudan); Military Industrial Corps. (Sudan); Yarmouk Industrial Complex (Sudan); Venezuelan
active. Syria
Military Industry Co. (CAVIM, Venezula)
designations not
included
BST Technology and Trade Co. (China); Dalian Sunny Industries (China); Li Fang Wei (China); Tianjin
August 28, 2015
Flourish Chemical Co. (China); Qods Force Commander Qasem Soleimani; IRGC; Rock Chemie (Iran);
Polestar Trading Co. Ltd. (North Korean entity in China); RyonHap-2 (North Korea) Tula Instrument
Design Bureau (Russia); Joint Stock Co. Katod (Russia); JSC Mic NPO Mashinostroyenia (Russia);
Rosoboronexport (Russia) Russian Aircraft Corp. MiG (Russia); Sudanese Armed Forces (Sudan); Vega
Aeronautics (Sudan); Yarmouk Complex (Sudan); Hezbollah; Eliya General Trading (UAE). (Designations
that applied to Syria or North Korea not included.)
Asaib Ahl Haq (Iraqi Shiite militia); Katai’b Hezbollah (Iraqi militia); IRGC; Shahid Moghadam-Yazd Marine
June 28, 2016
Industries (Iran); Shiraz Electronic Industries (Iran); Hezbollah; Military Industrial Corp. (Sudan); Khartoum
Sanctions still
Industrial Complex (Sudan); Khartoum Military Industrial Complex (Sudan); Luwero Industries (Uganda)
active.
11 entities sanctions for transfers of sensitive items to Iran’s ballistic missile program (all China except as
March 21, 2017
specified: Beijing Zhong Ke Electric Co.; Dalian Zenghua Maoyi Youxian Gongsi; Jack Qin; Jack Wang; Karl
Lee; Ningbo New Century Import and Export Co.; Shenzhen Yataida High-Tech Company; Sinotech Dalian
Carbon and Graphite Corp.; Sky Rise Technology (aka Reekay); Saeng Pil Trading Corp. (North Korea);
Mabrooka Trading (UAE)
Table D-5. Entities Designated under the Iran-Iraq Arms Non-Proliferation Act of
1992

(all designations have expired or were lifted)
Entity
Date Named
Mohammad al-Khatib (Jordan); Protech Consultants Private (India)
December 13,
2003
China Machinery and Electric Equipment Import and Export Corp. (China); China Machinery and Equipment
July 9, 2002
Import-Export Co. (China); China National Machinery and Equipment Import-Export Co. (China); China
Shipbuilding Trading Co. (China); CMEC Machinery (China); Hans Raj Shiv (India); Jiangsu Youngli Chemicals
and Technology Import-Export Co. (China); Q.C. Chen (China); Wha Cheong Tai Co. Ltd. (China).
Table D-6. Entities Designated as Threats to Iraqi Stability under Executive Order
13438 (July 17, 2007)
Entity
Date Named
Ahmad Forouzandeh. Commander of the Qods Force Ramazan Headquarters, accused of
January 8, 2008
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 Iranian arms to
Shiite militias in Iraq; Isma’il al-Lami (Abu Dura). Shiite militia leader, breakaway from Sadr
Mahdi Army, alleged to have committed mass kidnapings and planned assassination attempts
against Iraqi Sunni politicians; Mishan al-Jabburi. Financier of Sunni insurgents, owner of pro-
insurgent Al-Zawra television; Al Zawra Television Station.
Abdul Reza Shahlai, a deputy commander of the Qods Force; Akram Abbas Al Kabi, leader
September 16, 2008
of Mahdi Army “Special Groups”; Harith Al Dari, Sunnis Islamist leader (Secretary General
of the Muslim Scholars’ Association; Ahmad Hassan Kaka Al Ubaydi, ex-Baathist leader of
Sunni insurgents based in Iraq’s Kirkuk Province; and three person/entities designated for
operating Syria-based media that support Iraqi Sunni insurgents: Al Ray Satellite TV
Channel, and Suraqiya for Media and Broadcasting, owned by Mish’an Al Jabburi (see
above), and Raw’a Al Usta (wife of Al Jabburi.
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Entity
Date Named
Khata’ib Hezbollah (pro-Iranian Mahdi splinter group); Abu Mahdi al-Muhandis
July 2, 2009
Table D-7. Iranians Designated Under Executive Order 13553 on Human Rights
Abusers (September 29, 2010)
These persons are named in a semiannual report to Congress, required under CISADA. Virtually all of the
persons on this list, and those listed under Executive order 13628 (below) are designated as human rights
abusers by the European Union, whose list contains 87 individuals, including several province-level
prosecutors
Entity
Date Named
Eight persons: IRGC Commander Mohammad Ali Jafari; Minister of Interior at time of June
September 29,
2009 elections Sadeq Mahsouli; Minister of Intel igence at time of elections Qolam Hossein
2010
Mohseni-Ejei; Tehran Prosecutor General at time of elections Saeed Mortazavi; Minister of
Intelligence Heydar Moslehi; Former Defense Minister Mostafa Mohammad Najjar; Deputy
National Police Chief Ahmad Reza Radan; Basij (security militia) Commander at time of
elections Hossein Taeb
Two persons: Tehran Prosecutor General Abbas Dowlatabadi (appointed August 2009), for
February 23, 2011
indicting large numbers of protesters; Basij forces commander Mohammad Reza Naqdi
(headed Basij intelligence during 2009 protests)
Four entities: Islamic Revolutionary Guard Corps (IRGC); Basij Resistance Force; Law
June 9, 2011
Enforcement Forces (LEF); LEF Commander Ismail Ahmad Moghadam
Two persons: Chairman of the Joint Chiefs of Staff Hassan Firouzabadi; Deputy IRGC
December 13, 2011
Commander Abdollah Araghi
One entity: Ministry of Intelligence and Security of Iran (MOIS)
February 16, 2012
One person: Ashgar Mir-Hejazi for human rights abuses on/after June 12, 2009, and for
May 30, 2013
providing material support to the IRGC and MOIS.
One entity: Abyssec, for training the IRGC in cyber tradecraft and supporting its
December 30, 2014
development of offensive information operations capabilities.
One entity and One person: Tehran Prisons Organization. For severe beating of prisoners
April 13, 2017
at Evin Prison in April 2014; Sohrab Soleimani (brother of IRGC-QF commander) as head of
Tehran Prisoners Organization at the time of the attack above. Heads State Prisons
Organization.
Persons and entities designated following repression of December 2017-January 2018
January 12, 2018
protests: Judiciary head Sadeq Amoli Larijani (highest-ranking Iranian official sanctioned by
the United States); Rajaee Shahr Prison; and Gholmreza Ziaei
Ansar-e Hezbollah internal security militia designations: Ansar-e Hezbollah; Ansar leaders
May 30, 3018
Abdolhamid Mohtasham; Hossein Allahkaram; and Hamid Ostad. Evin Prison.
Ghavamin Bank (for assisting Iran’s Law Enforcement Forces, LEF)
November 5, 2018
Fatemiyoun Division and Zaynabiyoun Brigade
January 24, 2019
Table D-8. Iranian Entities Sanctioned Under Executive Order 13572 for Repression
of the Syrian People
(April 29, 2011)
Entity
Date Named
Revolutionary Guard—Qods Force (IRGC-QF)
April 29, 2011
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Entity
Date Named
Qasem Soleimani (Qods Force Commander); Mohsen Chizari (Commander of Qods Force
May 18, 2011
operations and training)
Ministry of Intelligence and Security (MOIS)
February 16, 2012
Iranian Entities Sanctioned Under Executive Order 13606 (GHRAVITY, April 23, 2012))
Ministry of Intelligence and Security (MOIS); IRGC (Guard Cyber Defense Command); Law
April 23, 2012
Enforcement Forces; Datak Telecom
IRGC Electronic Warfare and Cyber Defense Organization
January 12, 2018
Hanista Programming Group. For operating technology that monitors or tracks computers
May 30, 2018
Entities Sanctioned Under Executive Order 13608 Targeting Sanctions Evaders (May 1, 2012)
Ferland Company Ltd. for helping NITC deceptively sell Iranian crude oil
May 31, 2013
Three persons based in the Republic of Georgia: Pourya Nayebi, Houshang Hosseinpour, and
February 6, 2014
Houshang Farsoudeh.
Eight firms owned or controlled by the three: Caucasus Energy (Georgia); Orchidea Gulf Trading (UAE
and/or Turkey); Georgian Business Development (Georgia and/or UAE); Great Business Deals (Georgia
and/or UAE); KSN Foundation (Lichtenstein); New York General Trading (UAE); New York Money
Exchange (UAE and/or Georgia); and European Oil Traders (Switzerland).
Evren Kayakiran (Turkey) for directing employees to provide U.S. products and services to Iran February 7, 2019
Table D-9. Entities Named as Iranian Government Entities Under Executive Order
13599 (February 5, 2012)
Hundreds of entities—many of which are names and numbers of individual ships and aircraft—were
designated under this order to implement the JCPOA, and removed from the list of SDNs, in order that
secondary sanctions not apply. Those entities are in italics. Others were designated as owned or
controlled by the government of Iran before the JCPOA. As of November 5, 2018, all the entities
designated under E.O. 13599 are subject to secondary sanctions.
Entity
Date Named
Two insurance companies: Bimeh Iran Insurance Company (U.K.) Ltd. and Iran Insurance
June 16, 2010
Company.
20 Petroleum and Petrochemical Entities: MSP Kala Naft Co. Tehran; Kala Limited; Kala
Pension Trust Limited; National Iranian Oil Company PTE Ltd; Iranian Oil Company (U.K.) Ltd.;
NIOC International Affairs (London) Ltd.; Naftiran Trading Services Co. (NTS) Ltd.; NICO
Engineering Ltd.; National Petrochemical Company; Iran Petrochemical Commercial Company; NPC
International Ltd.; Intra Chem Trading Gmbh; Petrochemical Commercial Company International
Ltd.; P.C.C. (Singapore) Private Ltd.; Petrochemical Commercial Company FZE; Petrochemical
Commercial Company (U.K.) Ltd.; PetroIran Development Company (PEDCO) Ltd.; Petropars Ltd.;
Petropars International FZE; Petropars U.K. Ltd.
Central Bank of Iran (aka Bank Markazi)
February 12, 2012
Shipping Companies: Arash Shipping Enterprises Ltd.; Arta Shipping Enterprises Ltd.; Asan
July 12, 2012
Shipping Enterprise Ltd.; Caspian Maritime Ltd.; Danesh Shipping Co. Ltd.; Davar Shipping Co. Ltd.;
Dena Tankers FZE; Good Luck Shipping LLC; Hadi Shipping Company Ltd.; Haraz Shipping
Company Ltd.; Hatef Shipping Company Ltd.; Hirmand Shipping Company Ltd,; Hoda Shipping
Company Ltd.; Homa Shipping Company Ltd.; Honar Shipping Company Ltd.; Mehran Shipping
Company Ltd.; Mersad Shipping Company Ltd.; Minab Shipping Company Ltd.; Pars Petrochemical
Shipping Company; Proton Petrochemicals Shipping Ltd; Saman Shipping Company Ltd.; Sarv
Shipping Company Ltd.; Sepid Shipping Company Ltd.; Sima Shipping Company Ltd.; Sina Shipping
Company Ltd.; TC Shipping Company Ltd.
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Entity
Date Named
Energy Firms: Petro Suisse Intertrade Company (Switzerland); Hong Kong Intertrade Company
(Hong Kong); Noor Energy (Malaysia); Petro Energy Intertrade (Dubai, UAE) (all four named as
front companies for NIOC, Naftiran Intertrade Company, Ltd (NICO), or NICO Sarl)
58 vessels of National Iranian Tanker Company (NITC)
Banks: Ansar Bank; Future Bank B.S.C; Post Bank of Iran; Dey Bank; Eghtesad Novin Bank;
Hekmat Iranian Bank; Iran Zamin Bank; Islamic Regional Cooperation Bank; Joint Iran-Venezuela
Bank; Karafarin Bank; Mehr Iran Credit Union Bank; Parsian Bank; Pasargad Bank; Saman Bank;
Sarmayeh Bank; Tat Bank; Tosee Taavon Bank; Tourism Bank; Bank-e Shahr; Credit Institution for
Development
Entities and persons helping Iran evade oil shipping sanctions: Dimitris Cambis; Impire Shipping March 14, 2013
Co.; Libra Shipping SA; Monsoon Shipping Ltd.; Koning Marine Ltd.; Blue Tanker Shipping SA;
Jupiter Seaways Shipping; Hercules International Ship; Hermis Shipping SA; Garbin Navigation Ltd.;
Grace Bay Shipping Inc; Sima General Trading Co. FZE; Polinex General Trading LLC; Asia Energy
General Trading; Synergy General Trading FZE.
Sambouk Shipping FZC, which is tied to Dr. Dimitris Cambis and his network of front
May 9, 2013
companies.
Eight petrochemicals companies: Bandar Imam; Bou Ali Sina; Mobin; Nouri; Pars; Shahid
May 31, 2013
Tondgooyan; Shazand; and Tabriz.
Six individuals including Seyed Nasser Mohammad Seyyedi, director of Sima General Trading
September 6, 2013
who is also associated with NIOC and NICO. The other 5 persons sanctioned manage firms
associated with NIOC and NICO.
Four businesses used by Seyyedi to assist NIOC and NICO front companies: AA Energy
FZCO; Petro Royal FZE; and KASB International LLC (all in UAE); and Swiss Management Services
Sarl.
Execution of Imam’s Order (EIKO) and entities under its umbrella, designated for hiding assets
January 4, 2013
on behalf of the government of Iran’s leadership: Tosee e Eqtesad Ayandehsazan Company
(TEACO); Tadbir Economic Development Company (Tadbir Group); Tadbir Investment
Company; Modaber; Tadbir Construction Development Company; Tadbir Energy Development
Group; Amin Investment Bank; Pardis Investment Company; Mellat Insurance Company; Rey
Investment Company; Reyco GmbH; MCS International GmbH (Mannesman Cylinder Systems);
MCS Engineering (Efficient Provider Services GmbH); Golden Resources Trading Company L.L.C.
(GRTC); Cylinder System Ltd. (Cylinder System DDO); One Vision Investments 5 (Pty) Ltd.; One
Class Properties (Pty) Ltd.; Iran and Shargh Company; Iran and Shargh Leasing Company; Tadbir
Brokerage Company; Rafsanjan Cement Company; Rishmak Productive and Exports Company;
Omid Rey Civil and Construction Company; Behsaz Kashane Tehran Construction Company; Royal
Arya Company; Hormuz Oil Refining Company; Ghaed Bassir Petrochemical Products Company;
Persia Oil and Gas Industry Development Company; Pars Oil Company; Commercial Pars Oil
Company; Marjan Petrochemical Company; Ghadir Investment Company; Sadaf Petrochemical
Assaluyeh Company; Polynar Company; Pars MCS; Arman Pajouh Sabzevaran Mining Company;
Oil industry Investment Company; Rey Niru Engineering Company.
Five Iranian banks: Khavarmianeh Bank, Ghavamin Bank, Gharzolhasaneh Bank, Kish
August 29, 2014
International Bank, and Kafolatbank (Tajikistan).
Numerous Iranian aircraft and vessels were designated under this order, in keeping with the November 5, 2018
reimposition of U.S. secondary sanctions.
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Table D-10. Entities Sanctioned Under Executive Order 13622 for Oil and
Petrochemical Purchases from
Iran and Precious Metal Transactions with Iran (July 30, 2012)
All italicized entities were delisted during U.S. JCPOA implementation
Entity
Date Named
Jam Petrochemical Company (for purchasing petrochemical products from Iran); Niksima Food
May 31, 2013
and Beverage JLT (for receiving payments on behalf of Jam Petrochemical).
Asia Bank (for delivering from Moscow to Tehran of $13 million in U.S. bank notes paid to
August 29, 2014
representatives of the Iranian government).
Five individuals and one company for helping Iran acquire U.S. banknotes: Hossein Zeidi,
December 30, 2014
Seyed Kamal Yasini, Azizullah Qulandary, Asadollah Seifi, Teymour Ameri, and Belfast General
Trading.
Anahita Nasirbeik—Asia Bank official (see above).
Table D-11. Entities Sanctioned under the Iran Freedom and Counter-Proliferation
Act (IFCA, P.L. 112-239)
Entity
Date Named
Goldentex FZE (UAE)
August 29, 2014
Zhuhai Zhenrong (China) for purchasing oil from Iran
July 22, 2019
Table D-12. Entities Designated as Human Rights Abusers or Limiting Free
Expression under Executive Order 13628 (October 9, 2012, E.O pursuant to Iran
Threat Reduction and Syria Human Rights Act)
Entity
Date Named
Ali Fazli, deputy commander of the Basij; Reza Taghipour, Minister of Communications and
November 8, 2012
Information Technology; LEF Commander Moghaddam (see above); Center to Investigate
Organized Crime (established by the IRGC to protect the government from cyberattacks;
Press Supervisory Board, established in 1986 to issue licenses to publications and oversee
news agencies; Ministry of Culture and Islamic Guidance; Rasool Jalili, active in assisting the
government’s internet censorship activities; Anm Afzar Goster-e-Sharif, company owned by
Jalili, above, to provide web monitoring and censorship gear; PekyAsa, another company
owned by Jalili, to develop telecom software.
Islamic Republic of Iran Broadcasting (IRIB) and Ezzatollah Zarghami (director and head of
February 6, 2013
IRIB); Iranian Cyber Police (filters websites and hacks email accounts of political activists);
Iranian Communications Regulatory Authority (filters internet content); Iran Electronics
Industries (producer of electronic systems and products including those for jamming,
eavesdropping
Committee to Determine Instances of Criminal Content for engaging in censorship
May 30, 2013
activities on/after June 12, 2009; Ofogh Saberin Engineering Development Company for
providing services to the IRGC and Ministry of Communications to override Western
satellite communications.
Morteza Tamaddon for cutting mobile phone communications and harassing opposition
May 23, 2014
leaders Mir Hosein Musavi and Mehdi Karrubi when Tamaddon was governor-general of
Tehran Province in 2009.
Douran Software Technologies, for acting on behalf of the Committee to Determine
December 30, 2014
Instances of Criminal Content (see above).
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Entity
Date Named
Two entities that blocked social media sites and websites: Supreme Council for Cyberspace, January 12, 2018
and National Cyberspace Center
IRIB Director General Abdulali Ali-Asgari (see above); Abolhassan Firouzabadi (Secretary of
May 30, 3018
the Supreme Council of Cyberspace); and Abdolsamad Khoramabadi (Secreary of the
Committee to Determine Instances of Criminal Conduct, which oversees the censorship of
the internet)
Table D-13. Entities Designated under E.O. I3645 on Auto production, Rial Trading,
and Precious Stones (June 3, 2013)
All entities were delisted (and are italicized) and the order was revoked to implement the JCPOA
Entity
Date Named
Five entities/persons supporting NITC: Mid Oil Asia (Singapore); Singa Tankers (Singapore);
December 12, 2012
Siqiriya Maritime (Philippines); Ferland Company Limited (previously designated under other
E.O.); Vitaly Sokolenko (general manager of Ferland).
Three entities/persons for deceptive Iran oil dealings: Saeed Al Aqili (co-owner of Al Aqili
April 29, 2014
Group LLC); Al Aqili Group LLC; Anwar Kamal Nizami (Dubai-based Pakistani facilitator,
manages bank relations for affilates of Al Aqili and Al Aqili Group. Also works for Sima
General Trading, sanctioned under E.O. 13599).
Faylaca Petroleum (for obscuring the origin of Iranian sales of gas condensates); Lissome
August 29, 2014
Marine Services LLC and six of its vessels (for supporting NITC with ship-to-ship transfers);
Abdelhak Kaddouri (manages Iranian front companies on behalf of NICO); Mussafer Polat (for
obscuring origin of Iran’s gas condensate sales); Seyedeh Hanje Seyed Nasser Seyyedi
(managing director of Faylaca).
Table D-14. Entities Designated under Executive Order 13581 on Transnational
Criminal Organizations (July 24, 2011)
Entity
Date Named
Four individuals/entities: Ajily Software Procurement Group, Andisheh Vesal Middle East
July 18, 2017
Company, Mohammed Saeed Ajily, and Mohammed Reza Rezkhah. For stealing engineering
software programs from U.S. and other Western firms and selling them to Iranian military
and government entities.
Table D-15. Entities Designated under Executive Order 13694 on Malicious Cyber
Activities (April 1, 2015)
Entity
Date Named
Eight individuals/entities: ITSec Team, for 2011-12 distributed denial of services attacks on
September 14,
U.S. banks, acting on behalf of the IRGC; and Ahmad Fathi, Amin Shokohi, and Hamid
2017
Firoozi (for working for or with ITSec). Four persons working for or with Mersad Co, an
IRGC-affiliate firm indicted in 2016 for computer disruption/botnet/malware activities in
2012-13 targeting 24 U.S. financial sector companies: Sadegh Ahmazadegand; Sina Keissar;
Omid Ghaffarinia; and Nader Saedi.
Ten individuals and one entity, for theft of data from U.S. and third-country universities:
March 23, 2018
Mabna Institute, Gholamreza Rafatnejad, Ehsan Mohammadi, Seyed Ali Mirkarimi, Mostafa
Sadeghi, Sajjad Tamasebi, Abdollah Karima, Abuzr Gohair Moqadam. Roozbeh Sabahi,
Mohammed Reza Sabai, Behzad Mesri.
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Ali Khorashadizadeh and Mohammad Ghorbaniyan. For helping exchange bitcoin digital
November 28,
currency into Iranian rials on behalf of Iranian cyber actors involved with a “SamSam”
2018
ransomware scheme.
Table D-16. Entities Designated under Executive Order 13846 Reimposing Sanctions
(August 6, 2018)
Entity
Date Named
Ayandeh Bank (for materially assisting IRIB).
November 5, 2018

Author Information

Kenneth Katzman

Specialist in Middle Eastern Affairs

Acknowledgments
The author wishes to acknowledge that Sarah Manning, Research Associate, Foreign Affairs, Defense, and
Trade Division, contributed research to this report.

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Congressional Research Service
RS20871 · VERSION 297 · UPDATED
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