Iran Sanctions
July 23, 2020
Successive Administrations have used economic sanctions to try to change Iran’s
behavior. U.S. sanctions on Iran, which are primarily “secondary sanctions” on firms
Kenneth Katzman
that conduct certain transactions with Iran, have adversely affected Iran’s economy. The
Specialist in Middle
sanctions arguably have not, to date, altered Iran’s pursuit of core strategic objectives
Eastern Affairs
including its support for regional armed factions and its development of missiles.

Arguably, sanctions did contribute to Iran’s decision to enter into a 2015 agreement that

put limits on its nuclear program – the Joint Comprehensive Plan of Action (JCPOA).
During 2011-2015, global economic sanctions contributed to the shrinking of Iran’s economy as its crude oil
exports fell by more than 50% and it could not access its foreign exchange assets abroad. In accordance with the
JCPOA, the Obama Administration waived relevant sanctions and revoked relevant executive orders (E.O.s), and
U.N. and European Union sanctions were lifted as well. Remaining in place were U.S. sanctions on direct trade
with Iran and on Iran’s support for regional armed factions, its human rights abuses, and on its efforts to acquire
missile and advanced conventional weapons technology. U.N. Security Council Resolution 2231, which endorsed
the JCPOA, kept in place an existing ban on its importation or exportation of arms (until October 18, 2020) and a
non-binding restriction on Iran’s development of nuclear-capable ballistic missiles (until October 18, 2023). The
sanctions relief enabled Iran to increase its oil exports to nearly pre-sanctions levels, regain access to its foreign
exchange funds, and order some new passenger aircraft.
On May 8, 2018, President Trump announced that the United States would no longer participate in the JCPOA,
and it reimposed all secondary sanctions by November 6, 2018. Sanctions have since been 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. The policy has
caused major companies to exit the Iran market, and Iran’s economy has fallen into severe recession. Iran’s oil
exports have decreased dramatically, particularly after the Administration in May 2019 ended sanctions
exceptions for the purchase of Iranian oil. The Administration has also sanctioned several senior Iranian officials
as well as pro-Iranian militia figures in Iraq, Lebanon, Yemen, and Afghanistan. Despite the sanctions, Iran has
continued to develop its missile capabilities force and to provide arms and support to a broad array of armed
factions operating throughout the region, while refusing to begin talks with the United States on a revised JCPOA.
The European Union and other countries have sought, unsuccessfully, to keep the economic benefits of the
JCPOA flowing to Iran in order to persuade Iran to remain in the nuclear accord. Since mid-2019, Iran has
responded to the increasing sanctions by decreasing its compliance with the nuclear commitments of the JCPOA
and by conducting provocations in the Persian Gulf and in Iraq.
The COVID-19 pandemic has prompted international criticism, including from some in Congress, that U.S.
sanctions on Iran might be hindering Iran’s response to the outbreak. Iran has reported more cases and more
deaths from the illness than any other country in the region. Numerous accounts indicate that sanctions have
hindered Iran’s ability to finance the purchase of medical equipment, even though U.S. sanctions do not apply to
humanitarian transactions. In March 2020, the Administration revised public sanctions guidance to prompt foreign
companies to proceed with sales of humanitarian items to Iran. The Administration offered assistance to help Iran
deal with COVID-19, but Iran has refused the U.S. aid. Iran has applied to the International Monetary Fund (IMF)
for a $5 billion loan.
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.
Congressional Research Service

Iran Sanctions

Overview
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 trying to persuade Iran to agree to limits to its nuclear program. Still, sanctions
have had multiple objectives and sought to address multiple threats from Iran simultaneously.
This report analyzes U.S. and international sanctions against Iran. CRS cannot independently
corroborate whether any individual or other entity might be in violation of U.S. or international
sanctions against Iran. The report tracks implementation of the various U.S. laws and executive
orders, some of which require the blocking of U.S.-based property of sanctioned entities. No
information has been released from the executive branch indicating the extent, if any, to which
any such property is currently blocked.
The sections below are grouped by function, in the chronological order in which these themes
have emerged.
Blocked Iranian Property and Assets
Post-JCPOA Status: Iranian Assets Still Frozen, but Some Issues Resolved
U.S. sanctions on Iran were first imposed during the U.S.-Iran hostage crisis of 1979-1981, in the
form of executive orders issued by President Jimmy Carter blocking nearly all Iranian assets held
in the United States.1
U.S.-Iran Claims Tribunal
The Algiers Accords that resolved the U.S.-Iran hostage crisis established a “U.S.-Iran Claims
Tribunal” at the Hague that continues to arbitrate government-to-government cases resulting from
the 1980 break in relations and freezing of some of Iran’s assets. All of the 4,700 private U.S.
claims against Iran were resolved in the first 20 years of the Tribunal, resulting in $2.5 billion in
awards to U.S. nationals and firms. The major government-to-government cases involve Iranian
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.
On January 17, 2016 (the day after the JCPOA took effect), the United States announced it had
settled with Iran on additional FMS cases that were frozen when the Shah’s government fell. Iran
had been depositing its FMS payments into a DoD-managed “Iran FMS Trust Fund,” and, after
1990, the Fund had a balance of about $400 million.2 Under the 2016 settlement, the United
States sent Iran the $400 million balance, plus $1.3 billion in accrued interest (paid from the
Department of the Treasury’s Judgment Fund.) In order not to violate U.S. regulations barring

1 The Orders included E.O. 12170 of November 14, 1979, blocking all Iranian government property in the United
States, and E.O 12205 (April 7, 1980) and E.O. 12211 (April 17, 1980) banning virtually all U.S. trade with Iran. The
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” (hereafter: “Accords”) that resolved the U.S.-Iran hostage crisis.
2 In 1990, $200 million was paid from the Trust Fund to Iran to settle some FMS cases. In 1991, the United States paid
$278 million from the separate Treasury Department Judgment Fund to settle some additional FMS cases.
Congressional Research Service
1

Iran Sanctions

direct U.S. dollar transfers to Iranian banks, the funds were remitted to Iran in foreign hard
currency from the central banks of the Netherlands and of Switzerland. Some remaining claims
involving the FMS program with Iran remain under arbitration.
Other Iranian Assets Frozen
Iranian assets in the United States remain blocked under several provisions, including Executive
Order 13599 of February 2010.
 About $1.9 billion in blocked Iranian assets are bonds belonging to Iran’s Central
Bank, in a Citibank account in New York belonging to Clearstream, a
Luxembourg-based securities firm. In 2008, Clearstream allegedly improperly
allowed those funds to access the U.S. financial system. Clearstream transferred
$1.67 billion to its accounts in Luxembourg and those proceeds have been
deemed by Luxembourg courts as outside U.S. jurisdiction.
 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.3
 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. In June 2017, the United
States won control over the New York City office building through litigation.
Use of Iranian Assets to Compensate U.S. Victims of Iranian Terrorism4
Nearly $50 billion in court awards have been made to victims of Iranian terrorism. These include
the families of the 241 U.S. soldiers killed in the October 23, 1983, bombing of the U.S. Marine
barracks in Beirut. U.S. funds equivalent to the $400 million balance in the DOD account (see
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 using settlements paid by various
banks for concealing Iran-related transactions, and proceeds from other Iranian frozen assets.
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

3 http://www.treasury.gov/resource-center/sanctions/Documents/tar2010.pdf.
4 For details on these issues, see CRS In Focus IF10341, Justice for United States Victims of State Sponsored Terrorism
Act: Eligibility and Funding, by Jennifer K. Elsea; CRS Report RL31258, Suits Against Terrorist States by Victims of
Terrorism, by Jennifer K. Elsea; CRS Legal Sidebar LSB10104, It Belongs in a Museum: Sovereign Immunity Shields
Iranian Antiquities Even When It Does Not Protect Iran, by Stephen P. Mulligan; and CRS Legal Sidebar LSB10140,
Iran’s Central Bank Asks Supreme Court to Consider Whether the Bank’s Assets Abroad are Immune from Attachment
to Satisfy Terror Judgments, by Jennifer K. Elsea.
Congressional Research Service
2

Iran Sanctions

officials involved in the negotiations told CRS in November 2012 that the United States later
arranged to provide a substitute used aircraft to Iran.
Executive Order 13599 Impounding Iran-Owned Assets
Executive Order 13599 (February 5, 2012) blocks U.S.-based assets of entities determined to be
“owned or controlled by the Iranian government.” The order was issued to implement Section
1245 of the FY2012 National Defense Authorization Act (P.L. 112-81) that imposed secondary
U.S. sanctions on Iran’s Central Bank. The order requires that U.S. banks block U.S.-based assets
of the Central Bank of Iran or any Iranian government-controlled entity. The order goes beyond
the regulations issued pursuant to the 1995 imposition of the U.S. trade ban with Iran, in which
U.S. banks are required to refuse such transactions. Even before the issuance of the order,
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).5 The
Department of the Treasury characterizes EIKO as an Iranian leadership entity that controls
“massive off-the-books investments.”
Implementation of the JCPOA. To implement the JCPOA, many 13599-designated entities (in
JCPOA “Attachment 3”) were “delisted” from U.S. secondary sanctions (no longer considered
“Specially Designated Nationals,” SDNs) in early 2016 and instead referred to as “designees
blocked solely pursuant to E.O 13599,” a characterization that permits foreign entities to conduct
transactions with the listed entities but bars U.S. persons from conducting transactions with them.
In concert with the U.S. withdrawal from the JCPOA in 2018, virtually all of the 13599-
designated entities were relisted as SDNs on November 5, 2018.6
Civilian Nuclear Entity Exception. Among those entities “relisted” as Iranian owned entities were
the Atomic Energy Organization of Iran (AEOI), and 23 of its subsidiaries. However, the
Administration did not relist these entities as subject to secondary sanctions (SDNs) under E.O.
13382, in order to facilitate continued international work with Iran’s permitted civilian nuclear
program.7 The subsequent ending of most sanctions waivers for nuclear technical assistance to
Iran prohibits work almost all work with AEOI entities.
Sanctions for Iran’s Support for Militant Groups
After about five years during which no U.S. sanctions were imposed on Iran, the United States
imposed sanctions for Iran’s 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 later
established Lebanese Hezbollah. The designation triggers substantial sanctions. None of the laws
or executive orders in this section were waived or revoked to implement the JCPOA, and no
entities discussed in this section were “delisted” from sanctions.

5 Department of Treasury. Treasury Targets Assets of Iranian Leadership. June 4, 2013.
6 For entities designated under E.O. 13599, see: https://www.treasury.gov/ofac/downloads/13599/13599list.pdf.
7 U.S. diplomatic “non-paper” provided to CRS.
Congressional Research Service
3

Iran Sanctions

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 was 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 the designation are as follows:
 Restrictions on sales of U.S. dual use items. The Export Administration Act, as
superseded by the Export Control Reform Act of 2018 (in P.L. 115-232), requires
a presumption of denial of any license applications to sell dual use items to Iran.
Enforcement is 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) bar U.S. foreign assistance (U.S.
government loans, credits, credit guarantees, and Ex-Im Bank loan guarantees) to
terrorism list countries. Successive foreign aid appropriations laws since the late
1980s have banned direct assistance to Iran, and with no waiver provisions.
Under the FY2012 foreign operations appropriation (Section 7041(c)(2) of P.L.
112-74), the Ex-Im Bank cannot finance any entity sanctioned under the Iran
Sanctions Act.
 Requirement to oppose multilateral lending. U.S. officials are required to use the
country’s “voice and vote” to oppose multilateral lending to any terrorism list
country by Section 1621 of the International Financial Institutions Act (P.L. 95-
118, as amended [added by Section 327 of the Anti-Terrorism and Effective
Death Penalty Act of 1996 (P.L. 104-132)]). The law provides waiver authority,
for example to support an international loan in humanitarian circumstances.
 Withholding of U.S. foreign assistance to countries that assist or sell arms to
terrorism list countries. Under Sections 620G and 620H of the Foreign
Assistance Act (FAA), as added by Sections 325 and 326 of the Anti-Terrorism
and Effective Death Penalty Act of 1996 (P.L. 104-132), the President is required
to withhold foreign aid from any country that aids or sells arms to a terrorism list
country. Waiver authority is provided. Section 321 of P.L. 104-132 makes it a
crime for a U.S. person to conduct transactions with terrorism list governments.
 Withholding of U.S. Aid to Organizations That Assist Iran. Section 307 of the
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 option is provided.
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 in 1997; $350,000 worth of aid to the victims of a June 2002, earthquake;
and $5.7 million in assistance for victims of the December 2003 earthquake in Bam, Iran, which
killed 40,000. The U.S. military flew 68,000 kilograms of supplies to Bam. The Trump
Congressional Research Service
4

Iran Sanctions

Administration has offered Iran assistance, via the World Health Organization, to help it battle the
COVID-19 outbreak in early 2020, but, as of mid-April 2020, Iran has refused the aid.
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 wil 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 then requires a veto override.
Sanctions on States “Not Cooperating” Against Terrorism
Section 40A to the Arms Export Control Act (added by Section 330 of the Anti-Terrorism and
Effective Death Penalty Act (P.L. 104-132)) prohibits the sale or licensing of U.S. defense articles
and services to any country designated (by each May 15) as “not cooperating fully with U.S. anti-
terrorism efforts.” The President can waive the provision upon determining that a defense sale is
“important to the national interests” of the United States.
Every year since this was enacted, Iran has been designated as a country that is “not fully
cooperating” with U.S. antiterrorism efforts. However, the provision is largely redundant with
other laws that prohibit U.S. defense sales to Iran.
Executive Order 13224 Sanctioning Terrorism-Supporting Entities
Executive Order 13324 (September 23, 2001)8 mandates the freezing of the U.S.-based assets of,
and a ban on U.S. transactions with, entities determined by the Administration to be supporting
international terrorism. E.O. 13224, issued two weeks after the September 11, 2001, attacks on
the United States, targeted Al Qaeda, but it has subsequently been used to also target Iran. On
September 10, 2019, the Administration amended E.O. 13224 to authorize barring from the U.S.
financial system any foreign bank determined to have “conducted or facilitated any significant
transaction” with any person or entity designated under the order.9
CAATSA Application to the Islamic Revolutionary Guard Corps (IRGC)
Section 105 of the Countering America’s Adversaries through Sanctions Act (CAATSA, P.L. 115-
44, August 2, 2017), mandates the imposition of E.O. 13324 penalties on the IRGC and its
officials, agents, and affiliates by October 30, 2017 (90 days after enactment). The Treasury
Department made the designation of the IRGC as a terrorism-supporting entity under E.O. 13224
on October 13, 2017.

8 The Order was issued under the authority of the IEEPA, the National Emergencies Act, the U.N. Participation Act of
1945, and Section 301 of the U.S. Code.
9 For text of the amendments to the Order, see https://www.whitehouse.gov/presidential-actions/executive-order-
modernizing-sanctions-combat-terrorism/
Congressional Research Service
5

Iran Sanctions

Implementation of E.O. 13224
Successive Administrations have used the Order extensively to sanction Iran-related entities,
including members of Iran-allied organizations, such as Lebanese Hezbollah, and entities
involved in financing or facilitating Iran’s regional operations. The Iran-related entities
designated under E.O. 13224 are shown in the tables later in the report. The Trump
Administration has used the Order to sanction Iranian economic entities that furnish funds for the
Islamic Revolutionary Guard Corps (IRGC) and its regional activities. No entities designated
under E.O. 13224 were delisted to implement the JCPOA.
Foreign Terrorist Organization (FTO) Designations
The State Department has authority under Section 219 of the Immigration and Nationality Act
(8.U.S.C. 1189) to designate an entity as a Foreign Terrorist Organization (FTO). The designation
carries penalties similar to those of E.O. 13224, but also subjects any U.S. person (or person
under U.S. jurisdiction) who “knowingly provides material support or resources to an FTO, or
attempts or conspires to do so to “fine or up to 20 years in prison.” A bank that commits such a
violation is subject to fines.
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. On
April 22, 2019, the State Department guidelines for implementing the designation
indicating that it would not penalize routine diplomatic or humanitarian-related
dealings with the IRGC by U.S. partner countries or nongovernmental entities.10
 Lebanese Hezbollah.
 Kata’ib Hezbollah (KAH). Iran-backed Iraqi Shi’a militia.
 Asa’ib Ahl Al Haq (AAH). Iran-backed Iraqi Shi’a militia (designated Jan. 3,
2020)
 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

10 “Exclusive: U.S. Carves out Exceptions for Foreigners Dealing with Revolutionary Guards.” Reuters, April 21, 2019.
See CRS Insight IN11093, Iran’s Revolutionary Guard Named a Terrorist Organization, by Kenneth Katzman.
Congressional Research Service
6

Iran Sanctions

undermine efforts to promote economic reconstruction or political reform in Iraq.
The order extends to persons designated as materially assisting such designees.
Persons sanctioned under the order include IRGC-Qods Force officers, Iraqi
Shiite militia-linked figures, and other entities, some of which play 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.
Hezbollah-Specific Financial Sanctions
 The Hizballah International Financing Prevention Act (P.L. 114-102) and
Hizballah International Financing Prevention Amendments Act of 2018 (P.L.
115-272). The latter Act was signed on October 23, 2018, the 25th anniversary of
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 2018 amendment
also authorizes 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 target Iran, but are largely redundant with other sanctions on Iran.
Ban on U.S. Trade and Investment with Iran
In 1995, the Clinton Administration issued Executive Order 12959 (May 6, 1995) banning U.S.
trade with and investment in Iran. 11 The order superseded and broadened Executive Order 12957,
which was issued two months earlier (March 15, 1995), which barred U.S. investment in Iran’s
energy sector. The March 1995 order accompanied President Clinton’s declaration of a “state of
emergency” with respect to Iran. E.O 13059 (August 19, 1997) added a prohibition on U.S.
companies’ knowingly exporting goods to a third country for incorporation into products destined
for Iran. Each March since 1995, the Administration in power has renewed the “state of
emergency” with respect to Iran.
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.12

11 The executive order was issued not only under the authority of International Emergency Economic Powers Act
(IEEPA, 50 U.S.C. 1701 et seq.(IEEPA) 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. IEEPA gives the President wide powers to regulate commerce with a foreign country when a ”state of
emergency” is declared in relations with that country, and to alter regulations to license transactions with Iran—
regulations enumerated in Section 560 of the Code of Federal Regulations (Iranian Transactions Regulations, ITRs).
12 Imports were mainly of artwork for exhibitions around the United States, which are counted as imports even though
Congressional Research Service
7

Iran Sanctions

Section 101 of the Iran Freedom Support Act (P.L. 109-293) codified the ban on U.S. investment
in Iran, but gave the President authority to terminate this sanction with notification to Congress.
JCPOA-Related Easing and Subsequent Reversal. In accordance with U.S. commitments under
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 non-sanctioned Iranian
airlines.13 In concert with the 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) pursuant to the orders and laws discussed above. The regulations
are administered by the Treasury Department’s Office of Foreign Assets Control (OFAC).
 Energy Transactions. 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, which was
authorized by Section 505 of the International Security and Development
Cooperation Act of 1985 (22 U.S.C. 2349aa-9). The 1987 Order 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, beginning with the
denial of a Mobil Corporation application to do so in April 1999. The regulations
do not ban the importation, from foreign refiners, of gasoline or other energy
products in which Iranian oil is mixed with oil from other producers, because
such refined oil is considered to be a product of the country where it is refined.
 Transshipment and Brokering. The regulations prohibit U.S. transshipment of
prohibited goods across Iran, and ban any activities by U.S. persons to broker
commercial transactions involving Iran.
 Shipping Insurance. Iran requires shipping insurance in order to transport its
exports. A pool of 13 major insurance organizations, called the International
Group of P & I (Property and Indemnity) Clubs, dominates the shipping
insurance industry and is based in New York. The U.S. location of this pool
renders it subject to the U.S. trade ban, but waivers of Sections 212 and 213 of
the Iran Threat Reduction and Syria Human Rights Act (ITRSHRA) were issued
to enable numerous insurers to give Iranian ships insurance during the period of
U.S. implementation of the JCPOA.14 This waiver ended on August 6, 2018.

the works return to Iran after the exhibitions conclude.
13 The text of the guidance is at https://www.treasury.gov/resource-center/sanctions/Programs/Documents/
implement_guide_jcpoa.pdf.
14 Shipping insurers granted the waiver included Assuranceforeningen Skuld, Skuld Mutual Protection and Indemnity
Association, Ltd. (Bermuda), Gard P and I Ltd. (Bermuda), Assuranceforeningen Gard, the Britannia Steam Ship
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
Congressional Research Service
8

Iran Sanctions

 Civilian Airline Sales. The regulations have always permitted the licensing of
goods related to the safe operation of civilian aircraft for sale to Iran and spare
parts sales have always been licensed periodically.15 However, from June 2011
until JCPOA implementation in 2016, Iran’s largest state-owned airline, Iran Air,
as well as other Iranian airlines were sanctioned under Executive Order 13382
and 13224, rendering sales of spare parts impermissible. In accordance with the
JCPOA, the United States relaxed restrictions to allow for the sale to Iran of
finished commercial aircraft, including to Iran Air, which was “delisted” from
sanctions.16 A March 2016 general license was issued to permit those sales. Pre-
existing licensing restrictions went back into effect on August 6, 2018. 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.
 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
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 (humanitarian items) have been generally permitted,
although in many cases a specific license issued by OFAC is required. 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 required). This list of general
license items list was expanded in 2013 and 2016 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 sold to Iran (excludes alcohol, cigarettes, gum, or fertilizer).
 Humanitarian and Related Services. Donations by U.S. residents directly to
Iranians (such as packages of food, toys, clothes, etc.) are permitted, but U.S.
relief organizations operating in Iran are required to obtain a specific OFAC
license to work there. On September 10, 2013, General License E was issued that
allows relief organizations to conduct activities (up to a value of $500,000 in one
year) without a specific licensing requirement, including (1) providing Iran
services for health projects, disaster relief, wildlife conservation; (2) conducting
human rights projects there; or (3) undertaking activities related to sports
matches and events. The policy allows importation from Iran of services related
to sporting activities, including sponsorship of players, coaching, referees, and

Ltd. (Europe), and the West of England Ship Owners Mutual Insurance Association (Luxembourg).
15 (§560.528 of Title 31, C.F.R.),
16 “Exclusive: Boeing Says Gets U.S. License to Sell Spare Parts to Iran,” Reuters, April 4, 2014.
Congressional Research Service
9

Iran Sanctions

training. In the cases of earthquakes in Iran in 2003 and the 2012, OFAC has
issued blanket temporary general licensing for relief work in Iran.
 Payment Methods, Trade Financing, and Financing Guarantees. U.S. importers
are allowed to pay Iranian exporters for approved imports, but the payment
cannot go directly to Iranian banks, and must instead pass through third-country
banks. Regulations provide that transactions that are incidental to an approved
transaction are allowed, meaning that financing (“letter of credit”) for approved
transactions are normally approved (as long as there is no involvement of an
Iranian bank).17 Title IX of the Trade Sanctions Reform and Export Enhancement
Act of 2000 (P.L. 106-387) bans the use of official credit guarantees (such as the
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 presence on the terrorism list.
Application to Foreign Subsidiaries of U.S. Firms
The regulations do not ban foreign subsidiaries of U.S. firms from dealing with Iran, as long as
the 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 “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.
During the U.S. implementation of the JCPOA, the United States licensed “controlled” foreign
subsidiaries to conduct transactions with Iran through “General License H: Authorizing Certain
Transactions Relating to Foreign Entities Owned or Controlled by a United States Person.”18 The
President has authority under IEEPA to license transactions with Iran, the ITRSHRA
notwithstanding. The Trump Administration revoked General License H and restored the pre-
JCPOA licensing policy (“Statement of Licensing Policy,” SLP) on November 6, 2018.

17 Text of 31 CFR 598.405: Transactions incidental to a licensed transaction. Any transaction ordinarily incident to a
licensed transaction and necessary to give effect to the licensed transaction is also authorized by the license.
18 The text of General License H can be found at Treasury Department: Archive of Revoked and Expired General
Licenses. https://www.treasury.gov/resource-center/sanctions/Pages/general_license_archive.aspx#iran
Congressional Research Service
10

Iran Sanctions

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. 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.
Sanctions on Iran’s Energy Sector19
In 1996, Congress and the executive branch began to pressure Iran’s energy sector, with the stated
aim of denying Iran the financial resources to support terrorist organizations and other armed
factions or to further its nuclear and WMD programs. Iran’s oil sector is as old as the petroleum
industry itself (early 20th century), and Iran’s onshore oil fields are in need of substantial
investment.20 Since 2011, Iran has been reducing its dependence on oil and gas revenues, to the
point where Iran’s 2020-2021 budget assumes minimal revenue from oil sales.21
The Iran Sanctions Act
This sections includes sanctions triggers under the Act that were added by subsequent laws.
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
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. (All
triggers were waived during JCPOA implementation and reinstated in 2018, unless specified
below.)
Trigger 1 (Original Trigger): “Investment” To Develop Iran’s Oil and Gas Fields
The core trigger of ISA when it was first enacted was a requirement that the President sanction
companies (entities, persons) that make an “investment” of more than $20 million in one year in

19 The Federal Register (Volume 77, Number 219) “Policy Guidance” defines what products and chemicals constitute
“petroleum,” “petroleum products,” and “petrochemical products” that are used in the laws and executive orders
discussed throughout the report. See http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-27642.pdf.
20 Basic data on Iran’s energy sector, including reserves, exports, pipeline projects, and related issues can be found in:
Energy Information Agency. Background Reference: Iran. January 7 2019.
21 “Iran outlines budget to resist U.S. sanctions as oil exports plunge.” Reuters, December 7, 2019.
Congressional Research Service
11

Iran Sanctions

Iran’s energy sector. 22 As amended by CISADA (P.L. 111-195) and P.L. 107-24, the definitions of
sanctionable activity under ISA includes: construction of pipelines to or through Iran, as well as
contracts to lead the construction, upgrading, or expansions of energy projects; sales of energy-
related equipment to Iran (if such sales are structured as investments or ongoing profit-earning
ventures); equity and royalty arrangements and any contract that includes “responsibility for the
development of petroleum resources” of Iran; and additions to existing investment. CISADA also
clarified that the definition of energy sector includes liquefied natural gas (LNG), oil or LNG
tankers, and products to make or transport pipelines that transport oil or LNG.
Trigger 2: Sales of WMD and Related Technologies, Advanced Conventional
Weaponry, and Participation in Uranium Mining Ventures
The Iran Freedom Support Act (P.L. 109-293, September 30, 2006) added 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.”
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: This provision of ISA was not waived under the JCPOA. No ISA sanctions have
been imposed on any entities under this provision.
Trigger 3: Sales of Gasoline to Iran
Section 102(a) of the CISADA (mentioned above) amended Section 5 of ISA to sanction Iran’s
importation of gasoline Its enactment followed legislation, such as P.L. 111-85, that prohibited the
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 sanctions:
 Sales to Iran of over $1 million worth in a single transaction (or $5 million in
multiple transactions a one-year period) of gasoline and related aviation and
other fuels. (Fuel oil, a petroleum by-product, was not defined as sanctionable.)
 Sales to Iran of equipment or services (same dollar threshold as above) which
would help Iran make or import gasoline. Examples include equipment and
services for Iran’s oil refineries or port operations.

22 Under §4(d) of the original act, for Iran, the threshold dropped to $20 million, from $40 million, one year after
enactment, when U.S. allies did not join a multilateral sanctions regime against Iran. P.L. 111-195 set the threshold
investment level at $20 million.
Congressional Research Service
12

Iran Sanctions

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, 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 in a single transaction (or a total of $5 million
in multiple transactions in a one-year period) worth of goods or services that Iran
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, and oil rights.
 provide to Iran $250,000 in a single transaction (or $1 million in multiple
transactions in a one-year period) worth of goods or services that Iran could use
to maintain or expand its production of petrochemical products.23
Trigger 5: Transporting Iranian Crude Oil
Section 201 of the ITRSHRA amends ISA by sanctioning entities the Administration determines:
 owns a vessel that was used to transport Iranian crude oil. The section also
authorizes but does not require the President to prohibit a ship from putting to
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 (adds
Section 5[a][4] to ISA).
Iran Threat Reduction and Syria Human Rights Act (ITRSHRA): ISA sanctions
on shipping insurance, Iranian bonds, and dealings with the IRGC
Separate provisions of the ITRSHR Act—which do not amend and were not formally
incorporated into ISA—require the application of ISA sanctions (five out of the 12 sanctions on
the ISA menu) on any entity that:
 provides insurance or reinsurance for the National Iranian Oil Company (NIOC)
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).
 assists or engages in a significant transaction with the IRGC or any of its
sanctioned entities or affiliates. (Section 302). This section was not waived to
implement the JCPOA.

23 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.
Congressional Research Service
13

Iran Sanctions

 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 CISADA sanctions (see below).
Implementation. 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. NIOC and NITC were delisted under the JCPOA, but they
were “relisted” on November 5, 2018.
Executive Order 13622/13846: Sanctions on the Purchase of Iranian Crude Oil
and Petrochemical Products, and Dealings in Iranian Bank Notes
Status: 13622 (July 30, 2012) revoked (by E.O. 13716, January 2016) but was put back into effect
by E.O. 13846 of August 6, 2018
Executive Order 13622 (July 30, 2012) imposed specified sanctions on the ISA sanctions menu,
and bars banks from the U.S. financial system, for the following activities:
 the purchase of oil, other petroleum, or petrochemical products from Iran.24
 transactions with the National Iranian Oil Company (NIOC) or Naftiran
Intertrade Company (NICO).
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 as of November 6, 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 importation
exception under Section 1245 of P.L. 112-81, discussed below. An exception also is provided for
pre-existing projects that bring gas from Azerbaijan to Europe and Turkey.
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 recommending, but not requiring, a 180-day time limit for a violation determination.25
CISADA (Section 102[g][5]) mandated that the Administration begin an investigation of potential

24 A definition of what chemicals and products are considered “petroleum products” for the purposes of the order are in
the policy guidance issued November 13, 2012, http://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-27642.pdf.
25 Other ISA amendments under that law included recommending against U.S. nuclear agreements with countries that
supply nuclear technology to Iran and expanding provisions of the USA Patriot Act (P.L. 107-56) to curb money-
laundering for use to further WMD programs.
Congressional Research Service
14

Iran Sanctions

ISA violations when there is “credible information” about a potential violation, and made
mandatory the 180-day time limit for a determination of violation.
ITRSHRA defines “credible information” needed to begin an investigation of a violation to
include a corporate announcement or corporate filing to its shareholders that it has undertaken
transactions with Iran. It also says the President may use as credible information reports from the
Government Accountability Office and the Congressional Research Service. Section 219 of
ITRSHRA requires that an investigation begin if a company reports to the Securities and
Exchange Commission (SEC) that it has engaged in activities that would violate ISA (or Section
104 of CISADA or transactions with entities designated under E.O 13224 or 13382, see below).
Oversight
ITRSHRA added several mechanisms for Congress to oversee whether the Administration is
investigating ISA violations. Section 223 of that law required a Government Accountability
Office report, within 120 days of enactment, and another such report a year later, on companies
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.

Congressional Research Service
15

Iran Sanctions

ISA Sanctions Menu
For companies that the President determines violated ISA, the original version of ISA required the imposition of
two of a menu of six sanctions on that firm. The Iran Freedom Support Act added three new possible sanctions
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 fol ows:
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 mil ion 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)
(original ISA)
5. prohibition on U.S. government procurement from the entity (original ISA)
6. prohibition on transactions in foreign exchange by the entity (added by CISADA)
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 control ing 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.
Interpretations of ISA and Related Laws
The sections below provide information on how key ISA provisions have been applied.
Application to Energy Pipelines
As noted above, ISA’s definition of “investment” has been consistently interpreted by successive
Administrations to include construction of energy pipelines to or through Iran because pipelines
help Iran develop its petroleum (oil and natural gas) sector. In March 2012, then-Secretary of
State Clinton clarified that the Obama Administration interpreted the provision to be applicable
from the beginning of pipeline construction.26

26 “Tough US warning on Iran gas pipeline.” Dawn, March 1, 2012.
Congressional Research Service
16

Iran Sanctions

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 below, in August 2019, the Trump Administration began using various
terrorism-related provisions to sanction some Iranian oil shipments and persons involved in
shipping Iranian oil. 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
OFAC updated its sanctions guidance to state that “bunkering services” (port operational support)
for Iranian oil shipments could subject firms and individuals 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. And, sanctions on financial transactions with Iran impede
implementation of purchase agreements for Iranian gas.
The effective dates of U.S. sanctions laws and orders exclude long-standing joint natural gas
projects that involve some Iranian firms—particularly the Shah Deniz natural gas field and
related pipelines in the Caspian Sea. Iran’s NICO holds a passive 10% share in Shah Deniz,
which also includes BP, Azerbaijan’s natural gas firm SOCAR, Russia’s Lukoil, and other firms.
NICO is a sanctioned entity under ISA and other provisions, 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 not developed an LNG export capability to date. CISADA
specifically included LNG in the ISA definition of petroleum resources and therefore made
subject to sanctions LNG investment in Iran and supply of LNG tankers to Iran.
Application to Private Financing but Not Official Credit Guarantee Agencies
The ISA definition of investment includes financing for investment in Iran’s energy sector, or for
sales of gasoline and refinery-related equipment and services. However, the definitions of
financial institutions are interpreted not to apply to official credit guarantee agencies, such as
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 publicly reported on the accounts, if any,
that have been blocked under the orders or laws discussed in this section, and the entities
sanctioned likely do not have a financial presence in the United States.
Congressional Research Service
17

Iran Sanctions

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. 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.
ISA (§5[f]) also contains several exceptions such as that the President is not required to impose sanctions that
prevent procurement of defense articles and services under existing contracts, in cases where a firm is the sole
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. 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 it certifies that Iran:
(1) has ceased its efforts to acquire WMD; (2) has been removed from the U.S. list of state sponsors of terrorism;
and (3) no longer “poses a significant threat” to U.S. national security and U.S. allies.27
This termination provision, like the sunset provision discussed 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 fol owed 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 on whether ISA should be repealed. That report
was submitted to Congress in January 2004, and did not recommend that ISA be repealed.
Oil Export Sanctions: FY2012 NDAA Sanctioning the Central Bank
In 2011, Congress sought to reduce Iran’s exportation of oil by imposing sanctions on financial
transactions with Iran’s Central Bank, which receives Iran’s oil payments worldwide. President
Obama, in his signing statement on the bill, indicated he would implement the provision so as not
to damage U.S. relations with U.S. partner countries, many of whom were purchasers of Iranian
oil. Section 1245 of the FY2012 National Defense Authorization Act (NDAA, P.L. 112-81,
December 31, 2011):

27 This termination requirement added by P.L. 109-293 formally removed Libya from the act. Application of the act to
Libya terminated on April 23, 2004, with a determination that Libya had fulfilled U.N. requirements.
Congressional Research Service
18

Iran Sanctions

 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 reduce 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. To maintain the SRE, countries are
required to reduce their oil buys from Iran relative to the previous 180-day
period.28 The law lacks a precise definition of “significant reduction” of oil
purchases, but a January 2012 letter by several Senators to the then-Treasury
Secretary set that definition at an 18% purchase reduction based on total paid for
the Iranian oil (not just volume reduction).29The banks of countries given an SRE
may continue to conduct any transactions (not just for oil) with the Central Bank
or with any sanctioned Iranian bank.
 Sanctions on transactions for oil apply if: the President certifies to Congress
every 90 days, based on a report by the Energy Information Administration, that
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.
 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. However: the Central
Bank’s designation as a terrorist entity under E.O. 13224 on September 20, 2019,
voided that exception. In February 2020, as the COVID-19 pandemic affected
Iran greatly, the Treasury Department issued a General License to permit
transactions with Iran’s Central Bank for the purchase of humanitarian items.30
Implementation/SREs Issued and Ended
The Obama Administration used the FY2012 NDAA to pressure Iran without causing economic
difficulty to U.S. allies, other Iran policy partners, or the global oil market. The table below
indicates cuts made by major customers compared to 2011. SREs were issued as follows:
 March 20, 2012: Japan
 September 2012 (following a July 2012 EU Iran oil purchase embargo): 10 EU
countries - Belgium, Czech Republic, France, Germany, Greece, Italy, the
Netherlands, Poland, Spain, and Britain
 December 2012: China, India, Malaysia, South Africa, South Korea, Singapore,
Sri Lanka, Turkey, and Taiwan.

28 ITRSHRA amended Section 1245 such that any country that completely ceased purchasing oil from Iran entirely
would retain an exception.
29 Text of letter from Senators Mark Kirk and Robert Menendez to Secretary Geithner, January 19, 2012.
30 Treasury Issues General License No. 8 Regarding Certain Permitted Humanitarian Trade Transactions Involving the
Central Bank of Iran. JDSupra. March 12, 2020.
Congressional Research Service
19

Iran Sanctions

SREs Ended in May 2019 and Results
The January 2016 waivers issued to implement the JCPOA suspended the requirement for a
country to cut oil purchases from Iran in order to maintain their SREs, and Iran’s oil customers
quickly resumed buying Iranian oil. The provision went back into effect on November 5, 2018 in
concert with the U.S. withdrawal from the JCPOA.31 Eight countries were given SREs and
continued to buy Iranian oil: China, India, Italy, Greece, Japan, South Korea, Taiwan, and Turkey.
On April 22, 2019, the State Department announced that no more SREs would be granted after
May 2, 2019.32 The Administration indicated that the decision would “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.”33Senior U.S. officials added that the move
sought to drive Iran’s oil exports as close to zero as possible. Entities sanctioned are in the tables
at the end of this report. In March 2020, Treasury Department officials warned oil traders of U.S.
penalties if they continued to conduct “ship-to-ship” transfers and other mechanisms to conceal
trading in Iranian oil.34
Waiver and Termination
The law provides for the President to waive the sanctions for 120 days, renewable for successive
120-day periods, if the President determines that doing so is in the national security interest. This
provision was waived to implement both the interim nuclear accord (January 2014 – January
2016), which allowed Iran’s oil customers to maintain purchases level at 1.1 million barrels per
day) and to implement the JCPOA. The Trump Administration renewed the waiver for the last
time, on January 12, 2018. The law went back into effect on November 5, 2018.
Iran Foreign Account “Restriction” Provision
Section 504 of the ITRSHRA, which went into effect in February 2013, impedes the ability of
Iran to repatriate hard currency to its Central Bank, including U.S. dollars that are the primary
form of payment for oil. The provision amended Section 1245 of the FY2012 NDAA (adding
“clause ii” to Paragraph D[1]) to require that any funds paid to Iran as a result of exempted
transactions (oil purchases, for example) be credited to an account located in the country with
primary jurisdiction over the foreign bank making the transaction. Iran can therefore only use the
funds to buy the products of the countries where the funds are held.
The September 25, 2019, designation of the Central Bank as a terrorist entity under E.O. 13224,
restricted Iran’s ability to use its Central Bank accounts abroad to pay for imports of humanitarian
items because the terrorism designation does not carry a humanitarian exception. The
Administration eased that restriction with the February 27, 2020 General License that Iran’s
Central Bank accounts could be used for humanitarian transactions (see above).
Waiver
The waiver under the FY2012 NDAA (P.L. 112-81) applies to the foreign bank account restriction
provision, in six month periods. To implement the JCPOA, a waiver was issued under P.L. 112-81

31 Department of State. Background Briefing on President Trump’s Decision to Withdraw from the JCPOA. May 8,
2018.
32 See CRS Insight IN11108, Iran Oil Sanctions Exceptions Ended, by Kenneth Katzman.
33 Secretary of State Michael Pompeo. Decision on Imports of Iranian Oil, April 22, 2019.
34 “U.S. to warn shippers against storing Iranian oil.” State Department official. Reuters, March 9, 2020.
Congressional Research Service
20

Iran Sanctions

(Section 212 and 213) to allow Iran to receive some hard currency from ongoing oil sales in
installments, but Iran remained unable to repatriate funds from its accounts abroad. During U.S.
implementation of the JCPOA, Sections 212(d)(10 and 2134(b)(1) of ITRSHRA were waived and
Iran was able to access the hard currency it received from oil sales. The waiver was last renewed
on January 12, 2018, and the restriction went back into effect on November 5, 2018.
Table 1. Iran Crude Oil Sales
(average daily volumes, in barrels per day)
JPA period
At U.S.
At SRE
May 2020
average
JCPOA Exit
Determination
(post-SRE
Country/Bloc
2011
(2014-2016)
(May ‘18)
(Oct. ‘18)
termination)
European Union
(particularly
Italy, Spain,
600,000
negligible
520,000 +
100,000
0
Greece)
China
550,000
410,000
700,000
838,000
130,000
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
97,000
swaps, other)
Total (mbd)
2.5
1.06
2.45
1.60
0.227
Sources: Bloomberg News, Reuters, and other press articles. Information on actual Iranian exports is often
preliminary and incomplete, and might not reflect 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 ended its purchases of that product from Iran to zero.
Note: mbd = mil ion barrels per day.
Sanctions on Arms and Weapons-Related
Technology Transfers
Several laws and executive orders seek to prevent Iran from obtaining arms and weapons-related
technology. Sanctions on Iran’s exportation of arms are discussed in the sections above on
sanctions for Iran’s support for terrorist groups. No sanctions in this section were eased to
implement JCPOA
Congressional Research Service
21

Iran Sanctions

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.”35
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. The definition is generally
understood to include technology used to develop ballistic missiles.
(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.
Sanctions to be imposed: Sanctions imposed on violating entities include: (1) a ban, for two years,
on U.S. government procurement from the entity; (2) a ban, for two years, on licensing U.S.
exports to that entity; and (3) authority, but not a requirement, to ban U.S. imports from the entity.
If the violator is determined to be a foreign country, sanctions to be imposed are: (1) a one-year
ban on U.S. assistance to that country; (2) a one-year requirement of a U.S. vote against
international loans to it; (3) a one-year suspension of U.S. coproduction agreements with the
country; (4) a one-year suspension of technical exchanges with the country in military or dual use
technology; (5) a one-year ban on sales of U.S. arms to the country; and (6) an authorization to
deny the country most-favored-nation trade status; and to ban U.S. trade with the country.
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.
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.”
Implementation. A number of entities were sanctioned under the act in the 1990s, as shown in the
tables at the end of this paper, but the designations have all expired.
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

35 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).
Congressional Research Service
22

Iran Sanctions

country that provides to a terrorism list country financial assistance or arms. Waiver authority is
provided.
Section 321 of the Anti-Terrorism and Effective Death Penalty Act also makes it a criminal
offense for U.S. persons to conduct financial transactions with terrorism list governments.
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 section, 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. As noted earlier, no sanctions under these sections have been
imposed.
Iran-North Korea-Syria Nonproliferation Act
The Iran Nonproliferation Act (P.L. 106-178, signed in March 2000) became the Iran-North
Korea-Syria Nonproliferation Act (INKSNA) after the enactment of laws expanding its
provisions to North Korea and to Syria. INKSNA authorizes sanctions—for two years unless
renewed—on foreign persons (individuals or companies, not governments) that are determined in
a report by the Administration to have assisted Iran’s WMD programs. Sanctions imposed include
(1) a 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.36
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.” No INKSNA sanctions were waived.
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, including that the government with jurisdiction over the entity
cooperates to stop future such transfers to Iran. There is no automatic sunset or expiration, or
stipulated conditions under which an Administration could terminate its application.
Executive Order 13382 on Proliferation-Supporting Entities
Executive Order 13382 (June 28, 2005) allows the President to block the assets of proliferators of
weapons of mass destruction (WMD) and their supporters under the authority granted by the
International Emergency Economic Powers Act (IEEPA; 50 U.S.C. 1701 et seq.), the National
Emergencies Act (50 U.S.C. 1601 et seq.), and Section 301 of Title 3, United States Code. The

36 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
to facilitate continued U.S. access and extended INA sanctions provisions to Syria.
Congressional Research Service
23

Iran Sanctions

numerous Iranian or Iran-related entities sanctioned under the order 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)
CAATSA (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 E.O. 13382 (see above) and mandates that the same
sanctions as in E.O. 13382 be imposed on entities determined by the
Administration to be assisting Iran’s ballistic missile program or any system
capable of delivering weapons of mass destruction (WMD). The section also
requires an Administration report every 180 days on persons contributing to
Iran’s ballistic missile program.
 Section 107 mandates 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 imposition of sanctions is not
required if the President certifies that Iran no longer poses a significant threat to
the United States or U.S. allies; 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.
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
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.
Sanctions on “Countries of Diversion Concern”
Section 303 of CISADA authorizes the President to designate as a “Destination of Diversion
Concern” a country allows substantial diversion of goods, services, or technologies characterized
in Section 302 of that law to Iranian end-users or intermediaries. The technologies include any
goods that could contribute to Iran’s nuclear or WMD programs, as well as goods listed on the
Commerce Control List or Munitions List. For any country designated as a country of diversion
concern, there would be prohibition of denial for licenses for U.S. exports to that country of the
goods that were being reexported or diverted to Iran. To date, no country has been designated a
“Country of Diversion Concern.” Some countries, such as the UAE, have adopted or enforced
anti-proliferation laws apparently to avoid designation.
Congressional Research Service
24

Iran Sanctions

Waiver and Termination. 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. 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 this sanction.
Summary of Sanctions on the Islamic Revolutionary Guard Corps (IRGC)
Numerous sanctions target Iran’s Islamic Revolutionary Guard Corps (IRGC), and none was waived or terminated
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
control ed 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 control ed 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 Department’s “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.
Congressional Research Service
25

Iran Sanctions

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
During 2006-2016, the Department of the Treasury conducted a campaign - which it termed
“targeted financial measures” - to persuade foreign banks to cease dealing with Iran. During the
outreach campaign, Treasury officials briefed bank officials on Iran’s use of the international
financial system to fund terrorist groups and acquire weapons-related technology. According to a
GAO report of February 2013, the Department of the Treasury made overtures to 145 banks in 60
countries, and convinced at least 80 of them cease handling financial transactions with Iranian
banks. During the period of U.S. implementation of the JCPOA, the Treasury Department instead
sought to encourage foreign banks to conduct normal transactions with Iran.
Ban on Iranian Access to the U.S. Financial System/Use of Dollars
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, but U.S. dollars cannot be directly transferred to an Iranian bank,
and instead must be paid through a third country bank. Section 560.510 of the Iran regulations
allows for U.S. payments to Iran to settle or pay judgments to Iran, but the prohibition on dealing
directly with Iranian banks applies.
On November 6, 2008, the Department of the Treasury barred U.S. banks from any transaction
with a foreign banks on behalf of an Iranian bank (“U-turn transactions”).37 Under that regulation,
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) to acquire dollars for that transaction. This ban
remained in effect during JCPOA implementation, and Iran argued that the restrictions deterred
European and other banks from reentering the Iran market because of the difficulty in paying Iran
with U.S. dollars. In 2016, the Obama Administration reportedly considered licensing
transactions by foreign clearinghouses to acquire dollars that might facilitate transactions with
Iran, but the Administration did not take that step. 38
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.39 (As noted above, the FY2016 Consolidated

37 For text of the OFAC ruling barring U-Turn transactions, see https://www.treasury.gov/resource-center/sanctions/
Documents/fr73_66541.pdf.
38 Washington Institute for Near East Policy. “Potential U.S. Clarification of Financial Sanctions Regulations,” by
Katharine Bauer. April 5, 2016.
39 Analyst conversations with U.S. banking and sanctions experts, 2010-2015.
Congressional Research Service
26

Iran Sanctions

Appropriation, P.L. 114-113, provided for use of the proceeds of the settlements above to pay
compensation to victims of Iranian terrorism.)
Table 2. Major Settlements/Fines Paid by Banks for Violations
Amount
Bank
Date
Paid
Violation
UBS (Switzerland)
2004
$100 mil ion
Unauthorized movement of U.S. dol ars to
Iran and others
ABN Amro (Netherlands)
December 2005
$80 mil ion
Failing to ful y report financial transactions
involving Bank Melli
Credit Suisse (Switzerland)
December 2009
$536 mil ion
Il icitly processing Iranian transactions with
U.S. banks
ING (Netherlands)
June 2012
$619 mil ion
Concealing movement of bil ions of dol ars
through the U.S. financial system for Iranian
and Cuban clients.
Standard Chartered (UK)
August 2012
$340 mil ion
Settlement paid to New York State for
processing transactions on behalf of Iran
Clearstream (Luxembourg)
January 2014
$152 mil ion
Helping Iran evade U.S. banking restrictions
Bank of Moscow (Russia)
January 2014
$9.5 mil ion
Il icitly allowing Bank Melli to access the U.S.
financial system
BNP Paribas
June 2014
$9 bil ion
Amount forfeited for helping Iran (and
Sudan and Cuba) violate U.S. sanction.
Standard Chartered (UK)
April 2019
$639 mil ion
Dubai branch of Standard Chartered
processed Iran-related transactions to or
through Standard Chartered - New York.
Unicredit AG (Germany,
April 2019
$1.3 bil ion
For il icitly processing transactions through
Austria, Italy)
the U.S. financial system on behalf of Islamic
Republic of Iran Shipping Lines (IRISL)
Halkbank
October 2019
N/A
Justice Department filed charges against
Halkbank for allegedly helping Iran evade
U.S. sanctions
Source: Various press reports.
CISADA: Sanctioning Foreign Banks That Conduct Transactions
with Sanctioned Iranian Entities
The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) was enacted
to try to limit Iran’s access to the international financial system and to reduce the ability of Iran’s
import-export community (referred to in Iran as the “bazaar merchants” or “bazaaris”) from
obtaining “letters of credit” (trade financing) to buy or sell goods. Section 104 of CISADA
requires the Secretary of the Treasury to forbid U.S. banks from opening new “correspondent
accounts” or “payable-through accounts” (or force the cancellation of existing such accounts)
for:40

40 Foreign banks that do not have operations in the United States typically establish correspondent accounts or payable-
through accounts with U.S. banks as a means of accessing the U.S. financial system. The Department of the Treasury
determines the amount money that constitutes a “significant” financial transaction.
Congressional Research Service
27

Iran Sanctions

 Any foreign bank that conducts a significant financial transaction with an entity
that is sanctioned by Executive Order 13224 or 13382 (see above). No
humanitarian exception is provided for. A full list of sanctioned entities is at the
end of this report, and entities “delisted” are in italics.
 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 State Department.
 Any foreign bank that facilitates “the activities of” an entity sanctioned under a
U.N. Security Council resolution.
 Any foreign bank that transacts business with the IRGC or any of its affiliates
designated under any executive order.
Section 1244(d) of the Iran Freedom and Counter-proliferation Act, IFCA, applies the CISADA
sanctions to any foreign bank that does business with Iran’s energy, shipping, and shipbuilding
sectors, including with NIOC, NITC, and IRISL. The provision was not an amendment to
CISADA itself. The IFCA provision was waived to implement the JCPOA, but was reinstated 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.
Section 104 was not waived to implement the JCPOA, but many entities with which transactions
would have triggered sanctions under Section 104 were “delisted” as Specially Designated
Nationals (SDNs), as provided by the JCPOA. The entities were relisted on November 5, 2018.
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.
Iran Designated a Money-Laundering Jurisdiction
On November 21, 2011, the Obama Administration identified Iran as a “jurisdiction of primary
money laundering concern”41 under Section 311 of the USA Patriot Act (31 U.S.C. 5318A), based
on a determination that Iran’s financial system constitutes a threat to governments or financial
institutions that do business with Iran’s banks. The designation imposed additional requirements

41 Federal Register. Finding That the Islamic Republic of Iran Is a Jurisdiction of Primary Money Laundering Concern.
November 25, 2011.
Congressional Research Service
28

Iran Sanctions

on U.S. banks to ensure against improper Iranian access to the U.S. financial system. On October
25, 2019, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a
final rule barring the U.S. financial system from any transactions with Iranian banks or foreign
banks acting on behalf of Iranian banks.42
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 region to circumvent U.S.
financial sanctions.
Financial Action Task Force (FATF)
In 2016, the Financial Action Task Force (FATF), a multilateral body that shares best practices to
combat money laundering and the financing of terrorism (AML/CFT), named Iran a “High Risk
Jurisdiction.” In June 2016, the FATF welcomed an “Action Plan” filed by Iran to address its
strategic AML/CFT deficiencies and suspended “countermeasures”—mostly voluntary
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 until 2020.
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 countermeasures, but called on
members to require increased supervisory examination for branches and subsidiaries of financial
institutions based in Iran.43 On February 21, 2020, the FATF stated that: “given Iran’s failure to
enact the Palermo and Terrorist Financing Conventions in line with the FATF Standards, the
FATF fully lifts the suspension of counter-measures and calls on its members and urges all
jurisdictions to apply effective counter-measures, in line with Recommendation 19” – a
determination that subjects Iran’s financial system to increased scrutiny by banks worldwide.44
“SWIFT” Electronic Payments 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
process transactions for Iranian banks. That law also authorizes, but does not mandate, sanctions
against SWIFT or against electronic payments systems.
Sanctions on Iran’s Non-Oil Industries and Sectors
Successive Administrations and Congresses have expanded sanctions on several significant non-
oil industries and sectors of Iran’s economy. The targeted sectors include Iran’s automotive

42 Treasury and State Announce New Humanitarian Mechanism to Increase Transparency of Permissible Trade
Supporting the Iranian People. October 25, 2019.
43 Statement by the Financial Action Task Force, June 19, 2019.
44 Statement by the Financial Action Task Force, February 21, 2020.
Congressional Research Service
29

Iran Sanctions

production sector, which is Iran’s second-largest industry (after energy), its mineral exports,
which account for about 10% of Iran’s export earnings, and various light manufacturing sectors.
The Iran Freedom and Counter-Proliferation Act (IFCA)
The Iran Freedom and Counterproliferation Act (IFCA, Subtitle D of the National Defense
Authorization Act for FY2013 (P.L. 112-239, January 2, 2013) sanctioned several Iranian
economic sectors simultaneously. IFCA’s provisions on Iran’s human rights practices are
discussed below. Most IFCA sections were waived during JCPOA implementation (2016-18).
 Section 1244 of IFCA mandates the blocking of U.S.-based property of any entity
(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 were 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 of the ISA menu of sanctions (see above) 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 SREs (see above) or to the purchase of natural gas
from Iran. E.O. 13846 of August 6, 2018 contains blocking of U.S.-based assets.
 Dealings in Precious Metals or Materials for Iran’s Missile, Nuclear, or Military
Programs. Section 1245 imposes five out of the 12 sanctions on the ISA menu on
entities that provide precious metals to Iran (including gold) or semi-finished
metals or software for integrating industrial processes. Section 1245 also
sanctions the supply to Iran of any material determined to be used in connection
with Iran’s nuclear, missile, or military programs. The section mandates the
exclusion from the United States of any foreign bank that facilitates any
stipulated transaction. There is no exception for countries that receive the SRE.
 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 that receive the SRE.
Congressional Research Service
30

Iran Sanctions

 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
The entities designated for sanctions under E.O. 13224, 13382, and other orders – which are
listed in the tables at the end of the report - trigger the IFCA sanctions discussed above. Some
sanctions have been imposed for transactions with the Iranian sectors stipulated in IFCA, as
shown in the tables at the end of the report.
Waiver and Termination
Sections 1244 and 1245 of IFCA provide for a waiver of sanctions for 180 days, if such a waiver
is determined to be vital to U.S. national security. Sections 1244(i), 1245(g), 1246(e), and 1247(f)
of IFCA were waived to implement the JCPOA on January 18, 2017, and that waiver was last
renewed on January 12, 2018. All sections of IFCA went back into effect in 2018 in concert with
the U.S. exit from the JCPOA.
Executive Order 13645/13846: Iran’s Automotive Sector, Rial
Trading, and Precious Stones
Executive Order 13645 of June 3, 2013, as superseded by 13846 of August 6, 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 conduct 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 affects banks in countries bordering or near Iran. The order
would presumably apply to any digital currency that Iran might develop that is
backed by or tied to the rial.
 Expands the application of Executive Order 13622 (above) to helping Iran
acquire precious stones or jewels (see above).
 Blocks U.S.-based property of a person that conducts transactions with an Iranian
entity listed as a Specially Designated National (SDN) or Blocked Person. As
noted earlier, all SDNs were “relisted” on November 5, 2018.
Executive Order 13871 on Iran’s Minerals and Metals Sectors
On May 8, 2019, President Trump issued Executive Order 13871 sanctioning transactions
involving Iran’s minerals and industrial commodities. The announcement stated that Iran earns
10% of its total export revenues from sales of the minerals and metals sanctioned.45 The order:

45 Statement by President Trump Imposing Sanctions on Iron, Steel, Aluminum and Copper Sectors of Iran, May 8,
2019.
Congressional Research Service
31

Iran Sanctions

 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 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.
Executive Order 13902 on the Construction, Mining,
Manufacturing, and Textiles Sector
On January 10, 2020, as a stated response to the Iranian missile strikes on an Iraqi air base used
by U.S. forces several days earlier (Iran’s response to the U.S. killing of IRGC-QF commander
Qasem Soleimani), President Trump issued Executive Order 13902 expanding the Iranian
industrial sectors subject to U.S. sanctions. The order:
 Blocks U.S. based property of persons determined by the Administration to
“operate in” or to have knowingly engaged in a significant transaction with the
construction, mining, manufacturing, or textiles sectors of Iran’s economy (such
as the vibrant carpet industry), “or any other sector of the Iranian economy as
may be determined by the Secretary of the Treasury, in consultation with the
Secretary of State.”
 Blocks U.S. property of persons determined to have assisted (financed, supplied
technology) persons sanctioned under the order.
 Bars from the U.S. financial system any foreign bank that conducts transactions
with these Iranian economic sectors or with persons that supplied goods or
services to those sectors.
 Persons sanctioned under the order are banned from travel to the United States.
Related State and Treasury Determination: E.O. 13902 followed an October 31, 2019,
determination by the State and Treasury Departments that the construction sector of Iran is
controlled by the IRGC and that, therefore, the supply of raw or semi-finished metals, graphite,
coal, and industrial software to Iran are sanctionable under Section 1245 of IFCA (see above).
The two agencies also determined that the sale to Iran of the following are sanctionable as useful
to Iran’s nuclear, missile, and military programs: stainless steel 304L tubes; MN40 manganese
brazing foil; and stainless steel (chromium, nickel, 60% tungsten, titanium, electro-slag remelting,
and vacuum remelting).46
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.

46 Dept. of State. Findings Pursuant to the Iran Freedom and Counter-Proliferation Act (IFCA) of 2012. October 31,
2019.
Congressional Research Service
32

Iran Sanctions

Sanctions on Cyber and Criminal Activities
The Trump Administration has used executive orders issued during the Obama Administration to
sanction Iranian entities determined to be engaged in malicious cyberactivities or in transnational
crime. Separately, the Justice Department has prosecuted some Iranian entities for such activity.
Entities sanctioned under the two orders below are listed in the tables at the end of the report.
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.
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.
U.S. 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. 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. 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.
Sanctions Supporting Democracy/Human Rights
U.S. policy and legislation since the June 12, 2009, election-related uprising in Iran has sought to
support the ability of the domestic opposition in Iran to communicate and to sanction Iranian
officials and institutions, such as the IRGC, that commit human rights abuses or engage in
corruption. Individuals and entities designated under the executive orders and provisions
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.47

47 U.S. Department of the Treasury, Office of Public Affairs, Treasury Sanctions Iranian Security Forces for Human
Rights Abuses, June 9, 2011.
Congressional Research Service
33

Iran Sanctions

Expanding Internet and Communications Freedoms
Some laws 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 to Congress companies that are
selling Iran technology equipment that it can use to control Internet usage by
Iranians.
 Relevant CISADA Provisions. 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 2008.48 The
provision was derived from the Reduce Iranian Cyber-Suppression Act (111th
Congress, S. 1475 and H.R. 3284). Section 103(b)(2) of CISADA exempts from
the U.S. export ban on Iran the sale of equipment to help Iranians communicate
via the Internet.
 Executive Order 13606 (April 23, 2012) sanctions 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 monitoring; or (2) selling to
Iran (or Syria) technology that enables them to carry out such actions.
 Section 403 of ITRSHRA sanctions (visa ban, U.S.-based property blocked)
persons/firms determined to have engaged in censorship in Iran, limited access to
media, or—for example, a foreign satellite service provider—supported Iranian
government jamming or frequency manipulation.
 Executive Order 13628 (October 9, 2012) implemented ITRSHRA Section 403
by blocking the property of entities determined to have committed censorship,
limited free expression, or assisted in jamming communications. The order
specifies the sanctions authorities of the Department of State and of Treasury.
 Regulations Changes by Treasury/OFAC. On March 8, 2010, the Iran
Transactions Regulations were amended to allow for a general license for
providing free mass market software to Iranians.49 On March 20, 2012, the
regulations were amended 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.50 The items included
personal communications, personal data storage, browsers, plug-ins, document

48 Christopher Rhoads, “Iran’s Web Spying Aided by Western Technology,” Wall Street Journal, June 22, 2009.
49 The regulations change required a waiver of the provision of the Iran-Iraq Arms Nonproliferation Act (Section 1606
waiver provision) discussed above.
50 Fact Sheet: Treasury Issues Interpretive Guidance and Statement of Licensing Policy on Internet Freedom in Iran,
March 20, 2012.
Congressional Research Service
34

Iran Sanctions

readers, and free mobile applications related to personal communications. On
May 30, 2013, the regulations were amended 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 Iran-specific legislation and administrative action has sought to sanction regime officials
involved in suppressing the domestic opposition in Iran or in human rights abuses more generally.
 Section 105 of CISADA bans travel and freezes the U.S.-based assets of those
Iranians determined to be human rights abusers. 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 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.
 Executive Order 13553 (September 29, 2010) implements Section 105 of
CISADA by sanctioning Iranians determined to be responsible for or complicit in
post-2009 Iran election human rights abuses.
 The CAATSA law (see above) 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 law 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 Iranian human rights abusers were designated under E.O. 13533 by an
October 31, 2017, CAATSA deadline.
 Sanctions against Iranian Profiteers. Section 1249 of IFCA amended Section 105
of CISADA 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 targets Iranian profiteers who
use official connections to corner the market for vital medicines. This provision
codified a similar provision of Executive Order 13645.
 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 services to IRIB. The waiver has been renewed each year since.
 Executive Order 13846 (August 6, 2018). The Executive Order that reimposed
pre-JCPOA sanctions on Iran contained provisions sanctioning Iranian human
rights abusers and corrupt officials. No sanctions imposed for such behaviors
Congressional Research Service
35

Iran Sanctions

were suspended to implement the JCPOA. Section 7 of the Order blocks the
U.S.-based property of persons that (1) engaged after January 2, 2013 in corrupt
diversion of goods intended for the Iranian people; (2) sold (after August 10,
2012) Iran goods or technologies or provided services used by the Iranian
government to commit serious human rights abuses; (3) engaged in censorship or
limited free expression in Iran (after June 12, 2009); or (4) provided goods or
services to any person sanctioned under the Order.
 Sanctions on Sales of Anti-Riot Equipment. Section 402 of the ITRSHRA
amended Section 105 of CISADA by imposing visa bans on and blocking the
U.S. property of any person or company that sells the Iranian government goods
or technologies that it can use to commit human rights abuses. 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 have sold such equipment to the IRGC.
 Separate Visa Bans. Since 2011, the State Department imposed visa restrictions
on over 100 Iranian officials for participating in political repression in Iran, but it
has not named them, on the grounds that visa records are confidential. The action
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
September 25, 2019, President Trump issued a proclamation denying entry into
the United States of senior Iranian officials and immediate family members.51
 High Level Iranian Visits to the United Nations. There are certain exemptions in
the case of high level Iranian visits to attend U.N. meetings in New York. Under
the U.N. Participation Act (P.L. 79-264), because the United States hosts the
United Nations headquarters in New York, visas are issued to heads of state and
their aides attending these meetings. In some cases, the State Department has
refused visas for Iranian officials on the grounds that they were involved in past
acts of terrorism or human rights abuses.
Non-Iran Specific Human Rights Laws
The Trump Administration has utilized global human rights laws to sanction Iranian violators.
 Global Magnitsky Act. The Global Magnitsky Human Rights Accountability Act,
enacted as part of the National Defense Authorization Act for Fiscal Year 2017
(NDAA 2017; P.L. 114-328; December 23, 2016), authorizes the President to
impose economic sanctions and deny entry into the United States to any foreign
person he identifies as engaging in human rights abuse or corruption. Executive
Order 13818, providing for sanctions on persons determined to have engaged in
the activity outlined in the Act, was issued on December 20, 2017.
 Section 7031(c) of the State Department and Foreign Operations Appropriation.
For the last few years, successive foreign aid appropriations laws have contained
a section (7031c) that makes persons determined to have committed gross
violations of human rights ineligible for entry to the United States. For FY2020,
this provision is in: P.L. 116-94, division G (H.R.1865)

51 Proclamation on the Suspension of Entry as Immigrants and Nonimmigrants of Senior Officials of the Government
of Iran. September 25, 2019.
Congressional Research Service
36

Iran Sanctions

Sanctions on Iran’s Leadership
The Trump Administration has imposed sanctions on some members of Iran’s civilian leadership.
Any Iranian official that is named an SDN is subject to a freezing of their U.S.-based property
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, imposing sanctions on the assets of Supreme Leader Ali Khamene’i and
his top associates. 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.
Implementation: Supreme Leader Khamene’i and his office are sanctioned by the order itself.
Subsequently, Iran’s Foreign Minister Mohammad Javad Zarif and other senior Iranian officials
and commanders were designated under the order, as shown in the tables at the end of the report.
U.N. Sanctions
U.N. sanctions on Iran, enacted by the Security Council under Article 41 of Chapter VII of the
U.N. Charter,52 applied to all U.N. member states. During 2006-2008, three U.N. Security
Council resolutions—1737, 1747, and 1803—imposed sanctions on Iran’s nuclear program and
weapons of mass destruction (WMD) infrastructure. Resolution 1929 (June 9, 2010) asserted that
major sectors of the Iranian economy support Iran’s nuclear program and authorized U.N.
member states to sanction civilian sectors of Iran’s economy. It also imposed binding limitations
on Iran’s development of nuclear-capable 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 contained the provisions below. The U.S.
withdrawal from the JCPOA did not change the status of Resolution 2231. The resolution
 Endorsed the JCPOA, superseded all prior Iran-related resolutions as of
Implementation Day (January 16, 2016), and lifted U.N. sanctions on Iran. Under
Paragraph 6(c) of Annex B of Resolution 2231, entities sanctioned under
Resolutions 1737 (and subsequent resolutions) and named in an attachment to the
Annex (mostly persons and entities connected to permitted aspects of Iran’s
nuclear program and its civilian economy) were immediately “delisted” on
Implementation Day. Those not listed on the attachment continue to be

52 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.
Congressional Research Service
37

Iran Sanctions

sanctioned until Transition Day (October 18, 2023). One notable person for
whom U.N. sanctions was to end on Transition Day is IRGC-QF commander
Qasem Soleimani, but his death from U.S. strike in January 2020 renders this
listing moot. Bank Sepah and Bank Sepah International PLC, were delisted on
Implementation Day by separate Security Council action. Paragraph 6(c)
provides for the Security Council to be able to delist or list any entity at any time.
 “Called on” Iran not to develop ballistic missiles “designed to be capable” of
delivering a nuclear weapon for a maximum of eight years from Adoption Day
(October 18, 2015). The restriction expires on October 18, 2023.
 Requires Security Council approval for Iran to export arms or to purchase any
arms (major combat systems named in the resolution) for a maximum of five
years from Adoption Day (October 18, 2020). See CRS In Focus IF11429, U.N.
Ban on Iran Arms Transfers, by Kenneth Katzman.
Table 3. Summary of Provisions of U.N. Resolutions on Iran Nuclear Program
(1737, 1747, 1803, 1929, and 2231)
Resolution 2231 superseded all the previous Iran resolutions
Resolution 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 continued enforcement of remaining restrictions.
Prior to JCPOA implementation, a Sanctions Committee, composed of the 15 members of the Security Council,
monitored implementation of all Iran sanctions and col ected 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 sanctions committee in implementing all Iran resolutions and to suggest ways to be more effective.
Source: Text of U.N. Security Council resolutions 1737, 1747, 1803, 1929, and 2231. http://www.un.org.

Congressional Research Service
38

Iran Sanctions

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.
Since mid-2019, Iran has decreased its compliance with the nuclear restrictions of the JCPOA on
the grounds that the United States has reimposed secondary sanctions on Iran.
U.N. reports on Iranian compliance with Resolution 223153 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 space and medium-
range missile launches as violations of the resolution. Iran has repeatedly violated the U.N. ban
on exportation of arms, as analyzed in CRS Insight IN11429, Capital Markets, COVID-19, and
Federal Government Emergency Facilities, cited above.
Sanctions Application under Nuclear Agreements
The following sections discuss sanctions relief provided under the November 2013 interim
nuclear agreement (Joint Plan of Action, JPoA) and the JCPOA.
Sanctions Eased by the JPoA
U.S. officials said that the JPoA provided “limited, temporary, targeted, and reversible” easing of
international sanctions. Under the JPoA (in effect January 20, 2014-January 16, 2016):54
 Iran’s oil customers were not required to further reduce their oil purchases from
Iran, in accordance with waivers of Section 1244c(1) of IFCA, ITRSHRA, and
ISA. The European Union amended its regulations to allow shipping insurance
for ships carrying oil from Iran.55
 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, and 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 related to automotive manufacturing.
 Executive Order 13382 and certain U.S.-Iran trade regulations were suspended to
allow for U.S. aircraft and spare parts sales to Iran Air.
Sanctions Easing under the JCPOA and U.S. Reimposition
In accordance with the JCPOA, international sanctions relief occurred at Implementation Day
(January 16, 2016). U.S. secondary sanctions were waived or terminated, but most sanctions on
direct U.S.-Iran trade remained. The secondary sanctions eased during JCPOA implementation
included (1) sanctions that limited Iran’s exportation of oil and sanction foreign sales to Iran of
gasoline and energy sector equipment, and which limit foreign investment in Iran’s energy sector;

53 The report is reprinted in, Iran Watch, at http://www.iranwatch.org/library/multilateral-organizations/united-nations/
un-secretary-general/third-report-secretary-general-implementation-security-council-resolution-2231.
54 The Administration sanctions suspensions and waivers are detailed at http://www.state.gov/p/nea/rls/220049.htm.
55 Daniel Fineren, “Iran Nuclear Deal Shipping Insurance Element May Help Oil Sales,” Reuters, November 24, 2013.
Congressional Research Service
39

Iran Sanctions

(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. All of the U.S. sanctions that
were eased went back into effect by November 5, 2018, in accordance with the Trump
Administration’s withdrawing the United States from the JCPOA.
The laws below were waived to implement the JCPOA:
• Iran Sanctions Act. The energy/economic-related provisions of ISA. The one 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
sanctioning transactions with SDNs and with named economic sectors.
• Executive Orders: 13574, 13590, 13622, 13645, and Sections 5-7 and 15 of Executive Order
13628 were revoked outright by Executive Order 13716.
• 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 “delisted” to implement the JCPOA.
• The United States delisted the specified Iranian economic entities and personalities listed in
Attachment III of the JCPOA, enabling 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.
• The JCPOA required the U.S. Administration, by “Transition Day,” (October 2023, eight
years after Adoption Day) to request that Congress lift virtually all of the sanctions that were
suspended under the JCPOA. No outcome is mandated.
• The JCPOA terminates U.N. sanctions on persons and entities still designated for U.N.
sanctions on Transition Day. All U.N. sanctions are to terminate by “Termination Day” (October
2025, ten years after Adoption Day).
In implementing its decision to exit the JCPOA and apply “maximum pressure” on Iran’s
economy, sanctions were reimposed. 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; and transactions with Iran in graphite, aluminum, steel,
coal, and industrial software.
 Importation of Iranian luxury goods to the United States.
 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; and 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).
Congressional Research Service
40

Iran Sanctions

 Entities that were delisted from sanctions were all relisted, with selected
exceptions (such as the AEOI and 23 subsidiaries), 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.
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, eight countries were given the SRE to enable them to continue
transactions with Iran’s Central Bank and to purchase Iranian oil. However, on
May 2, 2019, the SREs were terminated.
 At least initially, the Administration kept in place seven waivers under IFCA that
enable foreign entities to remove Iran’s LEU that exceeds the 300kg allowed
stockpile, to buy Iran’s heavy water, and expand the Bushehr civilian nuclear
power reactor. However, the Administration ended six of the seven waivers
gradually during 2019-2020.
 The Administration has continued to waive 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 waivers
for shorter periods.
 The Administration has issued the permitted IFCA exception for Afghan
reconstruction to enable India to continue work at Iran’s Chahbahar Port.
 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.
U.S. Sanctions that Remained in Place under the JCPOA
The JCPOA did not commit the United States to suspend U.S. sanctions related to terrorism,
proliferation, arms transfer, or human rights abuses, or suspend the ban on U.S.-Iran direct trade
(with the selected exceptions discussed above). The sanctions below remained in place 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 did not commit the United States to revoke Iran’s
placement on the terrorism list;
 E.O. 13382 on proliferation;
 the Iran-Iraq Arms Non-Proliferation Act;
 the Iran-North Korea-Syria Non-Proliferation Act (INKSNA);56
 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;

56 The JCPOA committed the United States to terminate sanctions on some entities designated under INKSNA.
Congressional Research Service
41

Iran Sanctions

 all sanctions on the IRGC, military, proliferation-related, and human rights- and
terrorism-related entities, which were not “delisted” from sanctions; and
 regulations barring Iran from access to the U.S. financial system.
Other Mechanisms to “Snap-Back” Sanctions on Iran
Sanctions might have been reimposed by congressional action in accordance with President
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 reimpose sanctions.57
The JCPOA (paragraph 36 and 37) and Resolution 2231 (paragraphs 10-13) contain a mechanism
for the “snap back” of U.N. sanctions if Iran does not satisfactorily resolve a compliance dispute.
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.”
Secretary of State Mike Pompeo asserts that Resolution 2231 allows the United States to trigger
the snap-back because it remains legally a “participant,” and that it will take that step unless the
Annex B ban on arms transfers to and from Iran is extended. The other JCPOA parties dispute
that the United States has the right to trigger the snap back because it withdrew from the
JCPOA.58
International Implementation and Compliance
During 2010-2016, converging international views on Iran’s expanding nuclear program
produced global consensus to pressure Iran through sanctions. All the JCPOA parties publicly
opposed the U.S. decision to exit the JCPOA in 2018 and have sought to continue to provide its
economic benefits to Iran. A comparison between U.S., U.N., and EU sanctions is contained in
the Appendix. 59
European Union (EU)
After the passage of Resolution 1929 in 2010, European Union (EU) sanctions on Iran became
nearly as extensive as those of the United States. This contrasted with earlier periods, when the
EU countries refused to join the 1995 U.S. trade ban on Iran, EU countries rescheduled $16
billion in Iranian debt bilaterally, and EU and Iran held talks on a trade agreement during 2002-
2005.60 Under the JCPOA, EU sanctions that were imposed in 2012 were lifted, including:
 A ban on oil and gas imports from Iran; including on insurance for shipping oil or
petrochemicals from Iran and a freeze on the assets of Iranian shipping firms.

57 For more information, see CRS Report R44942, U.S. Decision to Cease Implementing the Iran Nuclear Agreement,
by Kenneth Katzman, Paul K. Kerr, and Valerie Heitshusen.
58 “U.S. Calls for Indefinite Arms Embargo of Iran, but Finds No Takers.” New York Times, June 30. 2020
59 See: CRS Report R44017, Iran’s Foreign and Defense Policies, by Kenneth Katzman.
60 During the active period of talks, which began in December 2002, there were working groups on the trade agreement
terms, proliferation, human rights, Iran-sponsored terrorism, counternarcotics, refugees, migration issues, and the
Iranian opposition PMOI.
Congressional Research Service
42

Iran Sanctions

 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 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.
 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 after the JCPOA began implementation:
 An embargo on sales to Iran of arms, missile technology, other proliferation-
sensitive items, and gear for internal repression.
 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 Appendix A below).
Even though the EU countries did not reimpose sanctions on Iran after the U.S. withdrawal from
the JCPOA, many European firms have ceased Iran-related transactions or exited the Iran
market:61
 Cars and Buses. Renault and Citroen of France suspended their post-JCPOA $1
billion investments in a joint venture with two Iranian firms to boost car
production capacity in Iran to 350,000 cars per year. In August 2018, Daimler
(manufacturer of Mercedes Benz autos) announced suspension of business in
Iran. Scania of Sweden ended an effort to establish a factory in Iran to supply the
country with 1,350 buses, and Volvo halted truck assembly in Iran in 2018.
 Other Industry. German industrial giant 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. Among the major banks that have publicly announced exiting the Iran
market are: 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
blocked Iran’s withdrawal of $400 million in cash from the Europaische-
Iranische Handlesbank (EIH), which is partly owned by Iran.62
 Energy. No EU state has bought Iranian oil since U.S. energy sanctions went
back into effect in November 2018. Total SA of France has exited a nearly $5
billion energy investment in South Pars gas field.
 Shipping. Hapag-Lloyd of Germany and Denmark’s AP Moller-Maersk have
ceased shipping services to Iran.
 Telecommunications. Germany telecommunications firm Deutsche Telekom
announced in September 2018 that it would end its business in Iran.

61 “Iran Nuclear Deal: The EU’s Billion-Dollar Deals at Risk,” BBC News, May 11, 2018.
62 Germany’s Central Bank Imposes Rule to Stop Cash Delivery to Tehran. Jerusalem Post, August 6, 2018.
Congressional Research Service
43

Iran Sanctions

 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 services to the field.63
European Special Purpose Vehicle/INSTEX
The EU countries continue to try to preserve the JCPOA in the face of the Trump
Administration’s maximum pressure policy on Iran and Iran’s violations of the JCPOA’s terms.
On August 6, 2018, a 1996 EU “blocking statute” that seeks to protect EU firms from reimposed
U.S. sanctions took effect.
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 registration of the SPV,
named the “Instrument for Supporting Trade Exchanges” (INSTEX). Its stated focus has been on
transactions in goods not subject to sanctions, including medicines, medical devices, and food,
but it might eventually expand to oil and other products.64 In April 2019, Iran set up the required
counterparty—the “Special Trade and Finance Instrument” (STFI). Six additional countries in
Europe joined the INSTEX system in December 2019 and the mechanism subsequently sought to
speed up processing of medical transactions to help Iran deal with the COVID-19 pandemic in
2020. On March 31, 2020, INSTEX completed its first transaction—for about $540,000 worth of
medical equipment.65
At the August 2019 G-7 summit in Biarritz, France, French President Emmanuel Macron
proposed to provide a $15 billion credit line for Iran to purchase goods through INSTEX, with the
credit line to be secured by future Iranian oil deliveries. U.S. officials later signaled opposition to
the credit line proposal and it has not advanced.66
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
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. Italy in November 2019 banned
flights of Mahan Air.
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.67 Some Iranian banks were still able to conduct
electronic transactions with the European Central Bank via the “Target II” system. Even though

63 “U.S. Grants BP, Serica License to Run Iran-Owned North Sea Field.” Reuters, October 9, 2018.
64 Joint Statement on the New Mechanism to Facilitate Trade with Iran. January 31, 2019.
65 “EU Ramps up Trade System with Iran Despite U.S. Threats.” Wall Street Journal, March 31, 2020.
66 “Trump Administration cool to French plan for $15 billion Iranian credit line: officials.” Reuters, September 4, 2019;
Press briefing by Ambasador Brian Hook, September 4, 2019.
67 Avi Jorish, “Despite Sanctions, Iran’s Money Flow Continues,” Wall Street Journal, June 25, 2013.
Congressional Research Service
44

link to page 27 Iran Sanctions

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.
Increasingly aligned on regional issues, Iran and Russia have agreed to expand energy and more
general trade, but there is little evident implementation of any agreements. In December 2018,
Iran signed a free trade deal with the Russia-led “Eurasian Economic Union,” suggesting Russian
intent to potentially circumvent U.S. sanctions on Iran.
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. Since the reimposition of U.S. sanctions, China has reduced
its oil imports from Iran (see Table 1), but China has continued to import at least some Iranian oil
despite the ending of the SRE as of May 2, 2019. Iran’s automotive sector obtains a significant
proportion of its parts from China. In November 2018, China’s Kunlun Bank—a CNPC affiliate
that was sanctioned under CISADA in 2012—reportedly stopped accepting Euro and then China
currency-denominated payments from Iran.68 A state-owned China firm (CNPC) withdrew from a
major phase of Iran’s South Pars gas field, perhaps to avoid U.S. sanctions.
In mid-2019, the Administration has begun to more frequently sanction Chinese economic entities
for transactions with Iran.69 On July 23, 2019, the Administration sanctioned (under IFCA) a
small Chinese firm, Zhuhai Zhenrong Company Ltd., for buying oil from Iran.70 Prior to the
expiration of the SREs, China had stockpiled 20 million barrels of Iranian oil at its Dalian port,71
and importation of that oil apparently is not counted until it clears customs checkpoints.
Yet, China continues to invest in Iran. China’s President Xi Jinping visited Iran and other Middle
East countries in the immediate aftermath of the JCPOA, and stated that Iran is a vital link in an
effort to extend its economic influence westward through its “One Belt, One Road” initiative. In
concert, Chinese firms and entrepreneurs have been modernizing Iran’s rail and other
infrastructure.72 Since 2019, Iran and China have discussed a 25-year deal for China investments
in Iran to total $280 billion to be invested in Iran’s oil, gas, and petrochemical sectors, and $120
billion in upgrading Iran’s transport and manufacturing infrastructure.73 China and Iran were
reported in July 2020 to be negotiating finalizing the agreement, which might include arms sales

68 “As U.S. Sanctions Loom, China’s Bank of Kunlun to Stop Receiving Iran Payments—Sources.” Reuters, October
23, 2018.
69 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 a March 2017 settlement
agreement with BIS.
70 “The United States to Impose Sanctions on Chinese Firm Zhuhai Zhenrong Company Limited for Purchasing Oil
from Iran. Department of State, July 22, 2019.
71 “Boxed In: $1 billion of Iranian Crude Sits at China’s Dalian Port.” Reuters, May 1, 2019.
72 Thomas Erdbrink. “China’s Push to Link East and West Puts Iran at ‘Center of Everything.’” New York Times, July
25, 2017.
73 “China and Iran Flesh out Strategic Partnership.” Petroleum Economist, September 3, 2019.
Congressional Research Service
45

Iran Sanctions

to Iran and other strategic ties, and including China’s purchases of Iranian oil at discounted
prices.74
Japan/Korean Peninsula/Other East Asian Countries
During 2010-2016, Japan and South Korea enforced sanctions on Iran similar to those imposed
by the United States and the EU. Both countries cut imports of Iranian oil sharply and banks in
the two countries restricted Iran’s foreign exchange assets held in their banks. From 2016-2018,
when U.S. sanctions were suspended, both countries increased importation of Iranian oil, and
eased restrictions on Iran’s accounts.
Both countries—and their companies—have historically been unwilling to undertake transactions
with Iran that could violate U.S. sanctions. They reduced their Iranian oil purchases and received
SRE sanctions exceptions on November 5, 2018. In early 2019, Japan imported some Iranian oil,
and South Korea purchased about 200,000 barrels per day of Iranian condensates, butboth
countries stopped energy transactions with Iran upon expiration of their SREs in May 2019.
South Korea sought, but was denied, Administration concurrence to continue to import Iranian
condensates (a very light oil) on which South Korea’s petrochemical sector depends. Among
banks, South Korea’s Woori Bank and Industrial Bank of Korea, and Nomura Holdings of Japan,
are reportedly restricting Iran’s use of its Central Bank accounts held in both countries.75
Other East Asian Countries
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 strategic ventures, particularly the development of ballistic missiles. A
portion of the oil that China buys from Iran (and from other suppliers) might be transshipped to
North Korea, but it is not known if North Korea buys any Iranian oil directly.76
Taiwan and Singapore have generally been small buyers of Iranian oil. Taiwan resumed imports
of Iranian oil after sanctions were eased in 2016 and received an SRE in November 5, 2018, but
has bought no Iranian oil since late 2018. Singapore has been a small buyer of Iranian oil and has
not bought any Iranian oil since U.S. sanctions went back into effect in 2018.
India and Pakistan
Iran’s economy is highly integrated into those of its immediate neighbors in South Asia. India
cites U.N. Security Council resolutions as its guideline for policy toward Iran. During 2011-2016,
when U.N. sanctions were in force on Iran, India’s central bank ceased using a Tehran-based
regional body, the Asian Clearing Union, to handle transactions with Iran, and the two countries
agreed to settle half of India’s oil buys from Iran in India’s currency, the rupee. India reduced its
imports of Iranian oil substantially after 2011, but, after sanctions were eased in 2016, India’s oil
imports 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 2012-2016.77 In June 2018, after the Trump

74 “Defying U.S., China and Iran Near Trade and Military Partnership.” New York Times, July 11, 2020.
75 Author conversations with South Korean officials, January – December 2019.
76 “The Military Relationship Between Iran and North Korea.” Inside Sources, January 27, 2020.
77 “India Seeks to Pay $6.5 Billion to Iran for Oil Imports.” Economic Times of India. May 16, 2016.
Congressional Research Service
46

Iran Sanctions

Administration’s withdrawal from the JCPOA, India received an SRE until May 2019, and India
has not imported Iranian oil since that time,
In 2015, India and Iran agreed that India would help develop Iran’s Chahbahar port and an
associated railway that would enable India to trade with Afghanistan unimpeded by Pakistan. In
May 2016, Indian Prime Minister Narendra Modi visited Iran and signed an agreement to invest
$500 million to develop the port and related infrastructure. The Trump Administration has given
India the “Afghanistan reconstruction” exception under Section 1244(f) of IFCA. However, in
July 2020, Iran cited India’s non-performance of contracts to exclude the country from further
work on the railway at the port.78
Iran’s economic relations with Pakistan are less extensive than are its economic ties to India. One
test of Pakistan’s compliance with sanctions was a pipeline project that would carry Iranian gas to
Pakistan—a $7 billion project that U.S. officials on several occasions stated would be subject to
ISA sanctions. Iran reportedly completed the pipeline on its side of the border but, during
President Hassan Rouhani’s visit to Pakistan in March 2016, Pakistan did not commit to complete
the line. In 2009, India dissociated itself from the project.
Turkey
Turkey is a large neighbor whose relations with Iran have been uneven. Prior to the Trump
Administration’s ending of all SREs in 2019, Turkey bought about 40% of its oil from Iran.
Turkey reduced purchases of Iranian oil during 2012-2016, but its buys returned to 2011 levels
after sanctions on Iran were eased in 2016. Turkey’s SRE to buy Iranian oil expired in May 2019
and Turkey has not been a buyer of Iranian oil since, according to Bloomberg oil transactions
data.
Turkey also buys natural gas from Iran via a pipeline built in 1997, which at first was used for a
swap arrangement under which gas from Turkmenistan was exported to Turkey. Direct Iranian
gas exports to Turkey through the line began in 2001,79 but no ISA sanctions were imposed on the
grounds that the gas supplies were crucial to Turkey’s energy security.
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. U.S.
prosecutions have occurred since, against Halkbank and various individuals, for alleged
violations of U.S. sanctions on Iran.80
The rich energy reserves of the Caspian Sea have created challenges for U.S. efforts to deny Iran
financial resources. The Clinton and George W. Bush Administrations cited potential ISA
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.
Iraq and Persian Gulf States
The Arab monarchy states of the Persian Gulf—Saudi Arabia, United Arab Emirates, Qatar,
Kuwait, Bahrain, and Oman—are oil exporters and close allies of the United States. Still, they
maintain relatively normal trade with Iran. One Gulf state in particular, UAE, has sometimes

78 “Iran drops India from Chabahar rail project, cites funding delay.” The Hindu, July 14, 2020
79 “Iran Clears 40% of Gas Fine to Turkey.” Financial Tribune, June 13, 2017.
80 Department of Justice. Turkish Bank Charged In Manhattan Federal Court For Its Participation In A Multibillion-
Dollar Iranian Sanctions Evasion Scheme. October 15, 2019.
Congressional Research Service
47

Iran Sanctions

attracted U.S. scrutiny because of the large presence of Iranian firms there. Several UAE-based
firms have been sanctioned by the United States, as noted in the tables at the end of the report.
Iran and several of the Gulf states, including Kuwait and Bahrain, have had discussions on
various energy and related projects. However, their projects have not materialized because of
broad Iran-Gulf disputes. Qatar and Iran share the large gas field in the Gulf waters between
them, and 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, including a joint venture to expand Oman’s Al Duqm port, which is envisioned as a
major hub for regional trade. Omani banks, some of which operate in Iran, were used to
implement some of the financial arrangements of the JPoA and JCPOA.81
Iraq has sought to remain engaged economically with Iran while avoiding running afoul of U.S.
sanctions on Iran. In 2013, Iraq signed an agreement with Iran to buy natural gas through a joint
pipeline that would supply several Iraqi power plants. The Trump Administration has
accommodated Iraq’s need for Iranian electricity supplies by giving Iraq waiver permission—
under Section 1247 of IFCA—to pay Iran for electricity and the Iranian natural gas that runs
Iraq’s power plants. That section provides for waivers of up to 180 days, but the Administration
has limited the waiver to shorter increments, and requires that the funds due to Iran are held in
escrow at Iraq’s Trade Bank.82
Syria and Lebanon
Iran has extensive economic relations with both Syria and Lebanon, countries where Iran asserts
that core interests are at stake. Iran has sought to use banks in Lebanon to provide financial
assistance to Hezbollah as well as to the regime of Syrian President Bashar Al Asad. To try to
curb this activity, the Trump Administration has sanctioned some Lebanese banks for facilitating
Iranian aid to Hezbollah, although in the process perhaps weakening the Lebanese banking
system and aggravating Lebanon’s economic downturn. In July 2020, U.S. officials threatened to
impose sanctions on Lebanon if the government moves forward with a Hezbollah suggestion that
the country ease its financial difficulties by buying oil from Iran.83
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.84 In July 2019, Gibraltar diverted an Iranian tanker delivering oil to

81 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.” 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 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 “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. “Review of U.S. Treasury Department’s License
to Convert Iranian Assets Using the U.S. Financial System.” Majority Report. May 2018.
82 Department of State. Waiver Transmittal Letter, April 27, 2020.
83 “Pompeo: We are trying to prevent Iran from selling crude oil to Hezbollah.” Arab News, July 9, 2020.
84 Iran Signs Phone, Gas Deals with Syria. Agence France Presse, January 17, 2017.
Congressional Research Service
48

Iran Sanctions

Syria, a transaction that violated EU sanctions on Syria. The ship delivered the oil to Syria after
its release by Gibraltar in August 2019.
Venezuela
During 2020, Iran has expanded its economic relations with the regime of Nicolas Maduro in
Venezuela which, like Iran, is heavily targeted by U.S. sanctions. In May 2020, five Iranian
tankers shipped gasoline to Venezuela, reportedly in exchange for gold (which is a form of hard
currency). U.S. officials threatened sanctions on those as well as four other tankers bound for
Venezuela and successfully deterred the latter four from completing their deliveries.85 The United
States subsequently took legal action to impound those four shipments. Iran-Venezuela relations
had fluctuated prior to the 2020 Iranian shipments, and earlier agreements between the two
received little, if any, implementation.
International Financial Institutions/World Bank/IMF and WTO
The United States representatives to international financial institutions are required to vote
against international lending to Iran, but that vote, although weighted, is not sufficient to block
international lending. Asserting that it needs additional funds to cope with the costs of the
COVID-19 pandemic, Iran applied for a $5 billion International Monetary Fund (IMF) loan in
March 2020. Administration officials have opposed the loan on the grounds that Iran has
sufficient funds to manage its response to the pandemic, and no loan decision has been announced
by the IMF as of July 2020.86
Iran has received no international financial loans since 2005. In 1993, the United States voted its
16.5% share of the World Bank against loans to Iran of $460 million for electricity, health, and
irrigation projects, but the loans were approved. During FY1994-FY1996, foreign aid
appropriations (P.L. 103-87, P.L. 103-306, and P.L. 104-107) cut the amount appropriated for the
U.S. contribution to the bank because of its loans to Iran, contributing to a temporary halt in new
bank lending to Iran. In May 2000, the United States’ allies outvoted the United States to approve
$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, plus $400 million for earthquake relief.
WTO Accession
Iran has sought to join the World Trade Organization (WTO). Iran began accession talks in 2006
after the George W. Bush Administration dropped its objection to Iran’s application as part of an
effort to persuade Iran to reach a nuclear agreement. The accession process generally takes many
years, and generally requires consensus of existing WTO members. The Trump Administration
opposes Iran’s admission, and Iran’s efforts to join the WTO have not advanced.
Effectiveness of Sanctions
Trump Administration officials assert that U.S. sanctions on Iran are “working.”87 The following
sections assess the effectiveness of Iran sanctions according to a number of criteria.

85 Comments by Ambassador Brian Hook at Hudson Institute Seminar on Iran-Venezuela relations. July 10, 2020.
86 “Pompeo Reiterates US Opposition To IMF Loan For Iran.” Radio Farda, April 15, 2020.
87 “U.S. envoy says Iran sanctions working, warns against nuclear breaches.” Reuters, June 27, 2019.
Congressional Research Service
49

Iran Sanctions

Effect on Iran’s Nuclear Program and Strategic Capabilities
The international sanctions regime of 2011-2015 is widely credited with increasing Iran’s
willingness to accept the JCPOA. The Trump Administration asserts that its campaign of
“maximum pressure” on Iran, implemented mainly through sanctions, is intended to cause Iran to
negotiate a revised JCPOA that would limit not only Iran’s nuclear program but also its missile
program and its regional malign activities. Iran has refused such negotiations with the United
States, insisting that the United States provide JCPOA sanctions relief as a precondition to talks.88
Sanctions during 2011-2015 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, Iran has been able to expand the scale and sophistication of its missile capabilities,
as demonstrated by Iran’s September 14, 2019, strike on critical Saudi energy infrastructure and
Iran’s retaliatory attack for the killing of Qasem Soleimani in January 2020. Still, Iran’s nuclear
and missile programs might have advanced faster were sanctions not imposed.
Sanctions—as well as Resolution 2231—have prevented Iran from buying significant amounts of
major combat systems since the early 1990s. The U.N. ban on Iran’s importation and exportation
of weaponry expires on October 18, 2020. U.S. intelligence directors testified in 2019 that Iran
continues to develop its own increasingly advanced naval mines, submarines, and attack craft.89
Effects on Iran’s Regional Influence
The imposition, lifting, or reimposition of strict sanctions have arguably had minimal effect on
Iran’s regional behavior. Iran intervened extensively in Syria, Iraq, and Yemen during the 2011-
2015 period when sanctions had a significant adverse effect on Iran’s economy. Iran has remained
engaged in these regional conflicts after sanctions were eased in 2016, and since U.S. sanctions
were reimposed in late 2018. Iran’s regional activities are assessed in: CRS Report R44017,
Iran’s Foreign and Defense Policies, by Kenneth Katzman
Administration officials have cited Hezbollah’s financial difficulties as evidence that its
“maximum pressure” campaign on Iran is harming Iran’s abilities to project power in the region.90
The claim references reports since early 2019 that the party has had to appeal for donations, cut
expenses, request donations, and delay or reduce payments to its fighters.91 In 2020, the
Administration has also attributed the apparent drawdown of pro-Iranian fighters in Syria to the
effect of U.S. sanctions. An alternative explanation is that Iran is adjusting its expenditures to the
reduced activity on the Syria battlefield, where Hezbollah and other Iran-backed militias have
been fighting on behalf of the Asad regime.
The Administration also has sought to highlight the effect of its policy on Iran’s defense budget.
President Trump stated that Iran’s defense budget had increased 40% during the 2016-2018 time
frame of JCPOA implementation.92 On October 16, 2019, the State Department Special

88 “Iran says pandemic will not force talks with the US.” Al Monitor, April 20, 2020.
89 Worldwide Threat Assessment of the U.S. Intelligence Community, January 29, 2019.
90 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.
91 “Sanctions on Iran are Hitting Hezbollah,” Washington Post, May 19, 2019.
92 Statement from the President on the Reimposition of United States Sanctions with Respect to Iran, August 6, 2018.
Congressional Research Service
50

Iran Sanctions

Representative on Iran, Ambassador Brian Hook, testified before the Senate Foreign Relations
Committee that
However, from 2017 to 2018, when our pressure went into effect we saw a reduction in
[Iran’s] military spending of nearly 10 percent. Iran’s 2019 budget, which was released in
March, called for even steeper cuts, including a 28 percent cut to their defense budget and
a 17 percent cut for IRGC funding.93
Oversight. 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. However, because the United States has ceased
implementing the JCPOA, the semi-annual reports apparently are not prepared any more.
Domestic Political Effects
Although no U.S. Administration has publicly asserted that the goal of U.S. sanctions on Iran is to
bring about the change of Iran’s regime, a key question is whether U.S. sanctions might produce
political change in Iran. In late 2017- early 2018 and in November 2019, unrest broke out over
economic conditions and government repression. Still, U.S. sanctions were suspended at the time
of the unrest in late 2017 and there were few secondary sanctions during the large Green
Movement uprising of 2009-2010, suggesting that the connection between sanctions and Iran
unrest might be tenuous. Still, some Iranian protesters complain that the country’s money is being
spent on regional interventions rather than on the domestic economy.
Nor have U.S. sanctions necessarily always achieved favorable gradual political change. The
Trump Administration’s maximum pressure campaign has arguably undermined President Hassan
Rouhani—and bolstered Iranian hardliners—by illustrating that negotiations with the United
States do not produce better relations with the United States. Hardliners overwhelmingly won
Iran’s February 2020 parliamentary elections.94
Economic Effects
U.S. sanctions during 2011-2015, and since 2018, have taken a substantial toll on Iran’s economy.
 GDP and Employment Trends. During 2011-2015, Iran’s economy contracted
approximately 20% over the period, and the unemployment rate rose to about
20%, but the JCPOA-related sanctions easing enabled Iran to achieve 7% annual
growth during 2016-2018.95 The IMF reported that Iran’s economy declined by
about 8% during March 2019-March 2020, and a further contraction is expected
during 2020-2021.96 The estimates account for the effects of the COVID-19
pandemic and of U.S. sanctions.
 Oil Exports. During the 2011-2015 sanctions period, Iran’s crude oil sales fell
from 2.5 mbd in 2011 to about 1.1 mbd by 2014. The JCPOA sanctions relief
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
below 300,000 barrels per day in mid-2020.

93 Testimony of Special Representative Brian Hook. Senate Foreign Relations Committee, October 16, 2019.
94 “Iran’s Hardliners Win Election by Large Margin, Mehr Says.” Bloomberg News, February 23, 2020.
95 “Foreign Investors Flock to Iran as U.S. Firms Watch on the Sidelines.” Wall Street Journal, March 27, 2017.
96 The World Bank. Islamic Republic of Iran economy overview and outlook. May 1, 2020.
Congressional Research Service
51

Iran Sanctions

 Banking. Global banks mostly left the Iranian market during 2011-2015 and
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 Iran
transactions; (2) a lack of transparency in Iran’s financial sector; (3) lingering
concerns over past financial penalties for processing Iran-related transactions in
the United States; and (4) the inability to use dollars in Iran-related transactions.
Those banks that reentered the Iran market in 2016 exited again or limited their
transactions with Iran after the U.S. reimposed sanctions in 2018.
 Accessibility of Hard Currency Assets Held Abroad. During 2011-2016,
sanctions prevented Iran from accessing the hard currency in its accounts abroad
which, in January 2016, stood at about $115 billion.97 Iran was able to access the
funds during 2016-2018, but Iran’s foreign reserves again became restricted by
reimposed U.S. sanctions in late 2018. The current total value of Iran’s hard
currency assets abroad has been estimated by U.S. officials as about $85 billion,
but only about 10% of that is accessible due to the U.S.-imposed restrictions.98
 Currency Decline. For most of the period of JCPOA implementation (2016-
2018), the market value of the rial was 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, and it reached its lowest levels
ever (200,000 to the dollar) in late June 2020.99
 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. The U.S. exit from the
JCPOA caused inflation to increase to nearly 40%, by the end of 2018, but the
level stabilized in 2019, according to Iran’s Central Bank governor.100
 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 and 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.
 U.S.-Iran Trade.101 U.S.-Iran trade remains minimal. 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 accounted for the
significant increase in imports in 2016 to $86 million. U.S. exports to Iran spiked
to $440 million for 2018, primarily from a major increase in U.S. sales of
soybeans to Iran that year (about $318 million of that commodity). For 2019, the

97 CRS conversation with Department of the Treasury officials, July 2015. Of this amount, about $60 billion was due to
creditors such as China or to repay nonperforming loans to Iranian energy companies working in the Caspian and
Persian Gulf.
98 “Iran, Cut Off From Vital Cash Reserves, Faces Deeper Economic Peril, U.S. Says.” Wall Street Journal, December
3, 2019.
99 “Iran’s currency reaches lowest value ever against the dollar.” Arab News, June 22, 2020.
100 Ibid.
101 Figures in this paragraph is from the U.S Census Bureau. Foreign Trade Statistics database.
Congressional Research Service
52

Iran Sanctions

first full year in which all U.S. sanctions were back into effect, U.S. exports to
Iran fell to $73 million and imports from Iran were only about $1.4 million.
Iran’s Economic Coping Strategies
Iran has sought to try to mitigate the economic effect of sanctions.
 Export Diversification. Over the past 10 years, Iran has promoted sales of
petrochemicals and nonoil products, and they constitute a growing percentage of
Iran’s revenue.102 As discussed above, Iran’s March 2020-2021 budget assumes
that Iran will earn minimal oil revenues during the budget year.
 Reallocation of Investment Funds and Import Substitution. Sanctions compelled
some Iranian manufacturers to increase domestic production of some goods as
substitutes for imports. Supreme Leader Khamene’i publicly supports building a
“resistance economy” that is less dependent on imports and foreign investment.
 IRGC in the Economy/Privatization. Since 2010, portions of Iran’s state-owned
enterprises have been transferred to the control of quasi-governmental entities,
including cleric-run foundations (bonyads), holding companies, or investment
groups. The IRGC’s corporate affiliates are assessed by some experts as
controlling at least 20% of Iran’s economy.103 Rouhani has sought to push the
IRGC out of Iran’s economy through divestment, but with limited success.
 Subsidy Reductions. Then-President Ahmadinejad (2005-2013) reduced generous
subsidies while temporarily compensating families with small cash payments.
Gasoline prices were raised to levels similar to those in other regional countries.
Rouhani has continued that policy, and he has improved collections of taxes.104

102 Testimony of Patrick Clawson before the Senate Banking Committee. January 21, 2015.
103 “How Trump’s terrorist designation of Iran’s revolutionary guard impacts its economy.” CNBC, April 12, 2019.
104 Patrick Clawson testimony, January 21, 2015, op. cit.
Congressional Research Service
53

Iran Sanctions

Figure 1. Economic Indicators

Sources: IMF 2019, U.S. Energy Information Administration, OPEC.
Effect on Energy Sector Development
Since 2011, there has been little development activity at Iran’s various oil and gas development
sites, and many foreign investors resold their equity stakes to Iranian companies that are less
technically capable than international firms. The lifting of sanctions in 2016 prompted Iran to try
to lure foreign investors back into the sector with more generous investment terms under a
concept called the “Iran Petroleum Contract” that gives investing companies the rights to a set
percentage of Iran’s oil reserves for 20-25 years.105 Iran signed a number of new agreements with
international energy firms after 2016 but, as noted above, major energy firms divested again in
response to the U.S. exit from the JCPOA. Appendix B at the end of this report discusses various
Iranian oil and gas fields and the fate of post-1999 investments in them.
Iran’s development of its gas export sector has been slow. Iran still uses its gas mostly to reinject
into aging oil fields. However, Iran is exporting natural gas primarily to Turkey and Armenia.
Sanctions have rendered Iran unable to develop a liquefied natural gas (LNG) export business.

105 Thomas Erdbrink.“New Iran Battle Brews over Foreign Oil Titans.” New York Times, February 1, 2016.
Congressional Research Service
54

Iran Sanctions

With respect to gasoline, several suppliers stopped selling gasoline to Iran after CISADA (see
above) was enacted. In response, Iran expanded several of its refineries and, in 2017, Iranian
officials said Iran had become self-sufficient in gasoline.
Human Rights-Related Effects
It is difficult to draw any direct relationship between sanctions and Iran’s human rights practices.
Human rights reports by the State Department assess that there has been only modest
improvement in Iran’s practices in recent years, but the altered policies are not attributed by these
reports to any changes in sanctions.106
Since 2012, foreign firms have generally refrained from selling the Iranian government
equipment to monitor or censor social media use. However, the regime retains the ability to
monitor and censor social media use, and it is also developing a progressively more advanced
cyber capability using indigenously-upgraded technology.
Humanitarian Effects
The COVID-19 pandemic has put a spotlight on the extent to which sanctions might be affecting
Iran’s response to the disease—despite the fact that humanitarian items are exempt from U.S.
sanctions. For further analysis, see CRS Insight IN11279, COVID-19 and U.S. Iran Policy, by
Kenneth Katzman.
During 2012-2016, and since 2018, sanctions reportedly have limited Iran’s ability to import
expensive Western-made medicines, such as chemotherapy drugs and medicines for multiple
sclerosis. 107 Other reports in 2019 indicated that global food traders halted supplying Iran because
of the absence of trade financing,108or, alternately, their shipments have been held at Iranian docks
until payments clear. Some of the scarcity of medicines is caused by banks’ refusal to finance
such sales, even though doing so is not subject to sanctions. The State Department has issued
statements that the Iranian government exaggerates reports of the effects of U.S. sanctions on its
medical imports,109 whereas other accounts say that Iranians, particularly those with connections
to the government, take advantage of shortages by cornering the market for key medicines.
U.S. COVID Response
The Trump Administration has undertaken several steps to assist Iran’s response to the COVID-
19 pandemic and, in the process, perhaps parry calls to broadly ease sanctions on Iran.
 In January 2020, even before the COVID-19 pandemic had been acknowledged
in Iran, the United States processed the first transactions under a “Swiss
humanitarian channel” under which U.S. medical equipment can be sold to
buyers in Iran that are determined to be using the items purely for the purposes
intended. The channel was announced in October 2019, in partnership with
Switzerland.
 In February 2020, the Treasury Department clarified that Iran’s Central Bank
accounts abroad could be used for humanitarian purchases without risk of U.S.

106 Department of State. 2019 Country Reports on Human Rights, Released in 2020.
107 “Trump's Sanctions Are Proving a Bitter Pill for Iran's Sick.” Bloomberg News, November 20, 2018,
108 “Global Traders Halt New Iran Food Deals as U.S. Sanctions Bite.” Reuters, December 21, 2018.
109 State Department. Iran’s Sanctions Relief Scam., April 6, 2020.
Congressional Research Service
55

Iran Sanctions

sanction, and that donations could go to Iranians from U.S. donors. The steps
stopped short of steps taken in previous natural disasters in which the
Administration provided a 90 day general license for sales to Iran.
 In March 2020, the United States formally offered Iran assistance to help it cope
with the pandemic. Iran refused the aid.
 On the other hand, as noted, the United States is trying to persuade other
members of the IMF executive board to jointly, with the United States, deny Iran
the requested $5 billion loan for its COVID-19 response. Some Members of
Congress have called on the Administration to support the loan.110 The IMF has
not announced a decision on the loan as of July 2020.
Air Safety
In the aviation sector, some Iranian pilots complain publicly that U.S. sanctions caused Iran’s
passenger airline fleet to deteriorate to the point of jeopardizing safety. Iran’s aviation safety
record is widely assessed as relatively poor, but it is not clear if any issues were due to difficultly
in acquiring U.S. spare parts.
 In 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 2018.
 In December 2016, Boeing and Iran Air finalized an agreement for the purchase
of 80 passenger aircraft and the leasing of 29 others. Boeing received a specific
license for the transaction, which had an estimated value of $17 billion. None of
the aircraft was delivered by the time the export licenses were revoked in 2018.
 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 and was given
licenses to deliver another five by the November 2018 effective date of the export
license revocation.
Post-JCPOA Sanctions Legislation
JCPOA oversight and implications, and broader issues of Iran’s behavior have been the subject of
legislation.

110 Senator Robert Menendez: Menendez & Engel Propose Policies for Addressing COVID-19 in Iran. Press release,
April 3, 2020; Feinstein urges Trump to reverse plan to block Iran request for $5B in IMF aid, claims it is in ‘our
national interest’ Fox News, April 11, 2020.
Congressional Research Service
56

Iran Sanctions

114th Congress
The JCPOA stated that as long as Iran complies with the JCPOA, the sanctions that were
suspended or lifted shall not be reimposed on other bases. The Obama Administration asserted
that some new sanctions that seek to limit Iran’s military power, its human rights abuses, or its
support for militant groups would not violate the JCPOA.
Iran Nuclear Agreement Review Act (P.L. 114-17)
The Iran Nuclear Agreement Review Act of 2015 (INARA, P.L. 114-17) provided for a
congressional review period after which Congress could pass legislation to disapprove of the
JCPOA. No such legislation of disapproval was enacted. There are several certification and
reporting requirements under INARA, although most of them no longer apply as a result of the
Trump Administration withdrawal:
 Material Breach Report. INARA required the Administration to 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 it.
 Certification Report. INARA requiredthe President 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.
 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.
 Semiannual Report. INARA required 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 continued 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. 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 required an Administration report to Congress on how Iran has used the
benefits of sanctions relief.
Iran Sanctions Act Extension
The 114th Congress acted to extend ISA before its scheduled expiration on December 31, 2016.
The Iran Sanctions Extension Act (H.R. 6297), which extended ISA until December 31, 2026,
without any other changes, passed the House on November 15 by a vote of 419-1 and then passed
Congressional Research Service
57

Iran Sanctions

the Senate by 99-0. President Obama allowed the bill to become law without signing it (P.L. 114-
277), even though the Administration said the extension was not necessary.
Reporting Requirement on Iran Missile Launches
The conference report on the FY2017 National Defense Authorization Act (P.L. 114-328, Section
1226) required quarterly reports to Congress on Iran’s missile launches the imposition of U.S.
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 the requirement until December
31, 2022. The report is to include efforts to sanction entities that assist those missile launches.
114th Congress Legislation not Enacted
 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) 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 non-state groups.
 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 assist Iran’s nuclear program.
 The Justice for Victims of Iranian Terrorism Act (H.R. 3457/S. 2086) prohibited
the President from waiving U.S. sanctions until Iran completed paying judgments
issued for victims of Iranian terrorism. The House passed it on October 1, 2015,
by a vote of 251-173 despite Obama Administration opposition.111
 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 Iran’s automotive, chemical, computer science, construction, electronic,
energy metallurgy, mining, petrochemical, research, and telecommunications
industries 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, passed the House on July 14, 2016, by a vote of 246-
179.
 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.

111 For more information on the issue of judgments for victims of Iranian terrorism, see CRS Report RL31258, Suits
Against Terrorist States by Victims of Terrorism, by Jennifer K. Elsea.
Congressional Research Service
58

Iran Sanctions

 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 sections of the FY2017 Financial Services and General Government
Appropriations Act (H.R. 5485). H.R. 5711 passed by the House on November
17, 2016, by a vote of 243-174. The Obama Administration opposed the bills.
The Trump Administration and Iran Sanctions Legislation
Even before the Trump Administration withdrew 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 after incorporating sanctions on Russia, and it passed the Senate on
June 15, 2017, by a vote of 98-2. Subsequently, H.R. 3364, containing not only S.722 provisions
but also sanctions on North Korea, passed both chambers (P.L. 115-44, August 2, 2017). The
main provisions of CAATSA are discussed in the sections above, and Section 108 of the law
requires an Administration review of all designated entities to assess whether such entities are
contributing to Iran’s ballistic missile program or to Iranian support for international terrorism.
Legislation in the 115th Congress Not Enacted
 H.R. 1638. On November 14, 2017, the House Financial Services Committee
ordered reported H.R. 1638, the Iranian Leadership Asset Transparency Act,
requiring the Treasury Secretary to report to Congress on the assets and equity
interests held by named Iranian persons, including the Supreme Leader. That day,
the Committee also reported out H.R. 4324, 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 risks or benefited Iranian proliferation or terrorism.
 H.R. 5132. The Iranian Revolutionary Guard Corps Economic Exclusion Act
mandated Administration reports on whether specified categories of entities are
owned or controlled by the IRGC, or conduct significant transactions with it. The
bill defined an entity as owned or controlled by the IRGC even if the IRGC’s
ownership interest is less than 50%, and would have required a report on whether
the Iran Airports Company violates E.O. 13224 by facilitating flight operations
by Mahan Air, which is a designated as a terrorism supporting SDN.
 H.R. 4591, S. 3431, and H.R. 4238. Several bills would have codified Executive
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,
mentioning specifically the Iraqi militia groups As’aib Ahl Al Haq and Harakat
Hizballah Al Nujaba. H.R. 4591 passed the House on November 27, 2018.
Congressional Research Service
59

Iran Sanctions

116th Congress
Legislation introduced subsequent to the May 2018 U.S. withdrawal from the JCPOA appeared to
try to support implementation of the Administration’s maximum pressure campaign. The
following pertain to sanctions and not the broader issue of U.S.-Iran military confrontation or
other Iran issues and represents a sampling of introduced legislation.
 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.
 The Holding Iranian Leaders Accountable Act of 2020 (H.R. 6081) requires an
Administration report on the bank holdings of specified Iranian leaders.
 The Block Iranian Access to U.S. Banks Act of 2020 (H.R. 6243) would prohibit
any U.S. license to provide financial services to the government of Iran.
Other Possible U.S. and International Sanctions112
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.

112 See CRS In Focus IF10801, Possible Additional Sanctions on Iran, by Kenneth Katzman.
Congressional Research Service
60

Iran Sanctions

Appendix A. U.S., U.N., EU and Allied Country
Sanctions
EU and Other Allied
U.S. Sanctions
U.N. Sanctions
Countries
General Observation: Most
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 and South Korea 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 ban civilian
No comprehensive EU ban on
Investment in, and Financing
trade with Iran or general civilian
trade in civilian goods with Iran
for Iran: Executive Order 12959
sector investment in Iran.
was imposed at any time.
and CISAD ban U.S. firms from
Japan and South Korea did not ban
exporting to Iran, importing from
normal civilian trade with Iran.
Iran, or investing in Iran.
Sanctions on Foreign Firms
No U.N. equivalent. However,
The EU banned almost all dealings
that Do Business with Iran’s
Resolution 1929 “not[es] the
with Iran’s energy sector after
Energy Sector: Several laws and
potential connection between Iran’s
2011. These sanctions now lifted,
orders mandate sanctions on
revenues derived from its energy
but no oil imports from Iran since
virtually any type of transaction
sector and the funding of Iran’s
2018.
with/in Iran’s energy sector.
proliferation-sensitive nuclear
Japanese and South Korean
activities.” This is interpreted as
measures banned new energy
providing U.N. support for
projects in Iran.. These sanctions
countries to impose economic
now lifted, but no Iranian oil being
sanctions on Iran.
imported by either.
Ban on Foreign Assistance:
No U.N. equivalent
EU measures of July 2010, banned
U.S. foreign assistance to Iran—
grants, aid, and concessional loans
other than purely humanitarian
to Iran, and financing of enterprises
aid—is banned under §620A of the
involved in Iran’s energy sector.
Foreign Assistance Act. Iran is also
These sanctions now lifted.
routinely denied direct U.S. foreign
Japan and South Korea did not ban
aid under the annual foreign
aid or lending to Iran.
operations appropriations acts.
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
Arms embargo remains post-
systems.
JCPOA.
No similar Japan and South Korean
measures announced, but neither
exports arms to Iran.
Congressional Research Service
61

Iran Sanctions

EU and Other Allied
U.S. Sanctions
U.N. Sanctions
Countries
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 set 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 remain post-JCPOA.
Act, there is a denial of license
ongoing nuclear program.
Japan and S. Korea have announced
applications to sell Iran goods that
ful adherence to strict export
could have military applications.
control regimes.
Sanctions Against Lending to
Resolution 1747 (paragraph 7)
The July 2010 measures prohibited
Iran:
requested, but did not mandate, that EU members from providing
Under §1621 of the International
countries and international financial
grants, aid, and concessional loans
Financial Institutions Act (P.L. 95-
institutions refrain from making
to Iran, including through
118), U.S. representatives to
grants or loans to Iran, except for
international financial institutions.
international financial institutions,
development and humanitarian
Sanctions lifted post-JCPOA.
such as the World Bank, are
purposes.
Japan and South Korea banned
required to vote against loans to

medium- and long-term trade
Iran by those institutions.
No longer applicable
financing and financing guarantees.
Short-term credit was stil allowed.
These lifted post-JCPOA.
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
FTO and E.O 13224 designations
from exporting any arms. Resolution blocked by the EU, Japan, and
ban transactions with entities
2231 continues that restriction until
South Korea overlap or
determined by the Administration
October 18, 2020.
complement Iranian entities named
to be supporting terrorism.
by the United States.
Numerous entities, including some
Japan and S. Korea did not impose
of Iranian origin, have been
specific terrorism sanctions on
designated.
Iran.
Human Rights Sanctions:
No U.N. sanctions were imposed on The EU retains a ban on providing
CISADA and other laws provide for
Iran for terrorism or human rights
equipment that can be used for
a prohibition on travel to the U.S.,
abuses.
internal repression, and has
blocking of U.S.-based property, and
sanctioned nearly 100 Iranians for
ban on transactions with Iranians
human rights abuses.
determined to be involved in
Japan and South Korea have
serious human rights abuses, or
announced bans on named Iranians
who sell Iran equipment to commit
involved in WMD programs.
such abuses.
Congressional Research Service
62

Iran Sanctions

EU and Other Allied
U.S. Sanctions
U.N. Sanctions
Countries
Restrictions on Iranian
Resolution 1803 and 1929 authorize
The July 2010 EU measures banned
Shipping:
countries to inspect cargoes carried
Iran Air Cargo from access to EU
Under Executive Order 13382, the
by Iran Air and Islamic Republic of
airports and froze the EU-based
U.S. Department of the Treasury
Iran Shipping Lines (IRISL)—or any
assets of IRISL and its affiliates.
has named Islamic Republic of Iran
ships in national or international
Insurance and reinsurance for
Shipping Lines and several affiliated
waters—if there is an indication that Iranian firms are banned. These
entities as entities whose U.S.-based the shipments include goods whose
sanctions now lifted.
property is to be frozen.
export to Iran is banned.
Japan and South Korean measures
These resolutions no longer apply.
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, and
Iranian banking now lifted.
Brussels-based SWIFT expelled
CISADA prohibits banking
sanctioned Iranian banks from the
relationships with U.S. banks for any
electronic payment transfer
foreign bank that conducts
system. This restriction was lifted
transactions with Iran’s
but then reimposed when the U.,S.
Revolutionary Guard or with
left the JCPOA.
sanctioned Iranian entities.
Japan and South Korea took similar
FY2012 Defense Authorization (P.L.
measures South Korea imposed
112-81) prevents U.S. accounts with
the 40,000 Euro threshhold
foreign banks that process
requiring authorization. Japan and
transactions with Iran’s Central
S. Korea froze the assets of 15
Bank (with specified exemptions).
Iranian banks; South Korea
targeted Bank Mellat for freeze.
These sanctions now lifted.
Ballistic Missiles: U.S.
Resolution 1929 (paragraph 9)
EU measures of July 2010 required
proliferations laws provide for
prohibited Iran from undertaking
adherence to this provision of
sanctions against foreign entities
“any activity” related to ballistic
Resolution 1929. EU has retained
that help Iran with its nuclear and
missiles capable of delivering a
ban on providing ballistic missile
ballistic missile programs.
nuclear weapon. Resolution 2231
technology to Iran in post-JCPOA
calls on Iran not to develop or
period.
launch ballistic missiles designed to
be capable of carrying a nuclear
weapon. Expires October 18, 2023.

Congressional Research Service
63

Iran Sanctions

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

Nov. 1999
Soroush and Nowruz (oil)
Royal Dutch Shell
$800 mil ion
190,000 bpd
(Netherlands)/Japex
Royal Dutch received special rule ISA exemption
(Japan)
Apr. 2000
Anaran bloc (oil)
Lukoil (Russia) and
$105 mil ion
65,000
Lukoil and Statoil invested in 2000 but abandoned
Statoil (Norway)
work in 2009. Lukoil considering returning.
Jul. 2000
South Pars Phases 4 and 5 (gas)
ENI
$1.9 bil ion
2 bil ion cu.
On stream in 2005. ENI given special rule exemption
ft./day (cfd)
Mar. 2001
Caspian Sea oil exploration—construction of
GVA Consultants
$225 mil ion
NA
submersible dril ing rig for Iranian partner
(Sweden)
Jun. 2001
Darkhovin (oil)
ENI
$1 bil ion
100,000 bpd
ENI exited in 2013 and doing so enabled the firm to
Field in production
be exempted from U.S. sanctions
May 2002
Masjid-e-Soleyman (oil)
Sheer Energy
$80 mil ion
25,000 bpd
(Canada)/CNPC
(China))/ Naftgaran
Engineering (Iran)
Sept. 2002
South Pars Phases 9 and 10 (gas)
GS Engineering and
$1.6 bil ion
2 bil ion cfd
On stream as of early 2009
Construction Corp.
(South Korea)
Oct. 2002
South Pars Phases 6, 7, and 8
Statoil (Norway)
$750 mil ion
3 bil ion cfd
Field began producing late 2008; operational control
handed to NIOC in 2009. Statoil got special rule
Jan. 2004
Azadegan (oil)—South and North
CNPC—N. Azadegan $200 mil ion
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 (vice Inpex)
bil ion
from N.
Royal Dutch Shell/Petronas (Malaysia)—MoU to
Azadegan.
develop S. Azadegan
Jan. 2004
Tusan Block
Petrobras (Brazil)
$178 mil ion

Oil found in block in Feb. 2009, but not in commercial
quantity, according to the firm.
Oct. 2004
Yadavaran (oil)
Sinopec (China), deal
$2 bil ion
300,000 bpd
finalized Dec. 9, 2007
Congressional Research Service
64

Iran Sanctions

Company(ies)/Stat
Output/
Date
Field/Project
us (If Known)
Value
Goal
2005
Saveh bloc (oil)
PTT (Thailand)

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

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

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

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

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

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

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

“PVEP Wins Bid to Develop Danan Field.” Iran Press
Exploration and
TV, March 11, 2008.
Production Co.
(Vietnam)
Congressional Research Service
65

Iran Sanctions

Company(ies)/Stat
Output/
Date
Field/Project
us (If Known)
Value
Goal
Apr. 2008
Iran’s Kish Gas Field
Oman (cofinancing of
$7 bil ion
1 bil ion cfd
Includes pipeline from Iran to Oman.
project)
Apr. 2008
Moghan 2 (onshore oil and gas, Ardebil
INA (Croatia), but
$40-$140

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

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

Capacity is 1
Production of polyethelene at two polymer plants in
but firm withdrew in
mil ion tons
Bushehr Province. Product exported
2014
per year.
Mar. 2009
Phase 12 South Pars (gas)—Incl. LNG terminal
Indian firms: Oil and
$8 bil ion
20 mil ion
construction and Farsi Block gas field/Farzad-B bloc.
Natural Gas Corp. of
tonnes of
India (ONGC); Oil
LNG annually
India Ltd., India Oil
by 2012
Corp. Ltd./minor
stakes by Sonanagol
(Angola) and PDVSA
(Venezuela).
Aug. 2009
Abadan refinery
Sinopec
Up to $6

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

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

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

Iran later cancelled Gazprom’s contract due to
Gazprom’s failure to fulfil its commitments.
Dec. 2011
Zagheh Oil Field
Tatneft (Russia)
$1 bil ion
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)

Congressional Research Service
66

Iran Sanctions

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

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

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

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

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

Royal Dutch Shell signed MoU to assess the field
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, producing about 65,000 bpd.
max.
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. Responsibility for a
project to develop Iran’s energy sector is part of ISA investment definition.
Congressional Research Service
67

Iran Sanctions

Appendix C. Entities Sanctioned Under U.N.
Resolutions and EU Decisions

U.N. Security Council Resolutions
Entities in italics were “delisted” on Implementation Day. Entities in standard font to remain listed until Transition Day
(October 2023), unless removed earlier by Security Council. Persons listed are identified by the positions they held when
designated; some have since changed.
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 manager)
- Shahid Bagheri Industrial Group
- Maj. Gen. Yahya Rahim Safavi
- Jafar Mohammadi (Adviser to AEIO)
(SBIG)—missile program
(Commander in Chief, IRGC)
- Dawood Agha Jani (Natanz official)
- Fajr Industrial Group—missile
- Gen. Hosein Salimi (Commander,
- Ali Hajinia Leilabadi (Director of Mesbah
program
IRGC Air Force)
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.
Congressional Research Service
68

Iran Sanctions

Entities Added by Resolution 1803 (resolution no longer active)
Requires that countries report when the fol owing 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)
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)
control ed 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 (research
-Shahid Karrazi Industries
- Shahid Sattari Industries
component of the AEIO)
The fol owing IRGC-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 fol owing entities determined to be owned or control ed 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 Abdol ahi
Mansoor Arbabsiar—for alleged plot to assassinate Saudi Ambasador in Washington
Asadol ah Asadi—for alleged terrorist plot in Europe
Hashemi Moghadam—for alleged terrorist plot in Europe
Abdul Reza Shahlai—for alleged plot to assassinate Saudi Ambasador in Washington
Congressional Research Service
69

Iran Sanctions

Gholam Ali Shakuri—for alleged plot to assassinate Saudi Ambasador in Washington
Qasem Soleimani—IRGC-QF commander
Directorate for Internal Security of the Iranian Ministry of Intelligence and Security
Hamas
Hezbol ah 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-Hezbol ah. 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 ful list is at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02011D0235-20180413&qid=
1555351537619&from=EN

Congressional Research Service
70

Iran Sanctions

Appendix D. Entities Sanctioned under U.S. Laws
and Executive Orders
For every table below, 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), had the United States remained in the JCPOA. Because of the U.S.
withdrawal from the JCPOA in 2018, all delisted entities were relisted on November 5, 2018.
Table D-1. Entities Designated Under U.S. Executive Order 13382 (Proliferation)
(many designations coincide with EU and UN designations)
Entity
Date Named
Shahid Hemmat Industrial Group (Iran); Shahid Bakeri Industrial Group (Iran); Atomic Energy
June 2005,
Organization of Iran (AEOI). AEOI and 23 subsidiaries remained delisted for secondary sanctions
under E.O. 13382 but stil designated as Iran-owned or control ed 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 (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 bank ing services to Iran’s nuclear sector); Mellat Bank SB CJSC
(Armenia). Persia International Bank PLC (U.K.); Khatam ol Anbiya Gharargah Sazendegi Nooh (main
IRGC construction and contracting arm); Oriental Oil Kish (Iranian oil firm); Ghorb Karbala; Ghorb
Nooh (synonymous with Khatam ol Anbiya); Sepasad Engineering Company (IRGC construction
affiliate); Omran Sahel (IRGC construction affiliate); Sahel Consultant Engineering (IRGC
construction affiliate); Hara Company; Gharargahe Sazandegi Ghaem
Individuals: Bahmanyar Morteza Bahmanyar (AIO, Iran missile official; Ahmad Vahid Dastjerdi (AIO
head); Reza Gholi Esmaeli (AIO); Morteza Reza’i (deputy IRGC commander); Mohammad Hejazi
(Basij commander); Ali Akbar Ahmadian (Chief of IRGC Joint Staff); Hosein Salimi (IRGC Air Force
commander). Resolution 1737; Qasem Soleimani (Qods Force commander).
Future Bank (Bahrain-based but allegedly control ed by Bank Melli)
March 12, 2008
Yahya Rahim Safavi (former IRGC Commander in Chief); Mohsen Fakrizadeh-Mahabadi (senior
July 8, 2008
nuclear scientist); Dawood Agha-Jani (head of Natanz facility); Mohsen Hojati (head of Fajr
Industries/missile program; Mehrdada Akhlaghi Ketabachi (heads Shahid Bakeri Industrial Group);
Naser Maliki (heads Shahid Hemmat Industrial Group); Tamas Company uranium enrichment);
Shahid Sattari Industries; 7th of Tir (centrifuge technology); Ammunition and Metallurgy Industries
Group (partner of 7th of Tir); Parchin Chemical Industries (chemicals for ballistic missile programs)
Karaj Nuclear Research Center; Esfahan Nuclear Fuel Research and Production Center (NFRPC); Jabber August 12, 2008
Ibn Hayyan (reports to AEIO); Safety Equipment Procurement Company; Joza Industrial Company
(front company for SHIG)
Congressional Research Service
71

Iran Sanctions

Entity
Date Named
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: Armament Industries Group; Farasakht Industries; Iran
September 17,
Aircraft Manufacturing Industrial Co.; Iran Communications Industries; Iran Electronics Industries;
2008
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 in New York property management, see text)
Dec. 17, 2008
11 Bank Melli affiliates: Bank Melli Iran Investment (BMIIC); Bank Melli Printing and Publishing; Melli
March 3, 2009
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) and several linked entities: Fater
February 10,
Engineering Institute, Imensazen Consultant Engineers Institute, Makin Institute, and Rahab Institute
2010
Mohammad Ali Jafari, IRGC Commander-in-Chief; IRGC Air Force; IRGC Missile Command; Rah
June 16, 2010
Sahel and Sepanir Oil and Gas Engineering (for ties to Khatem ol-Anibya); Mohammad Reza Naqdi
(Head of the IRGC’s Basij militia); Ahmad Vahedi (Defense Minister); Javedan Mehr Toos, Javad
Karimi Sabet (atomic energy procurement brokers) Naval Defense Missile Industry Group (SAIG,
affiliate of Aircraft Industries Org that manages missile programs); Post Bank of Iran.
Five IRISL affiliates: Hafiz Darya Shipping Co.; Soroush Sarzamin Asatir Ship Management Co.; Safiran
Payam Darya; and Hong Kong-based Seibow Limited and Seibow Logistics.
27 vessels linked to IRISKL and 71 new names of already designated IRISL ships.
Several Iranian entities were also designated as owned or control ed by Iran under E.O. 13599.
Europaisch-Iranische Handelsbank (EIH) for financial services to Bank Sepah, Mellat, EDBI, and others. Sept. 7, 2010
Pearl Energy Company (formed by First East Export Bank, a subsidiary of Bank Mellat, 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: By State—Nuclear Reactor Fuels Company; Noor Afzar Gostar
November 21,
Company; Fulmen Group; Yasa Part. By Treasury—Javad Rahiqi; Modern Industries
2011
Technique Company; Iran Centrifuge Technology Company (TESA); Neka Novin;
Parto Sanat; Paya Partov; Simatic Development Co
Iran Maritime Industrial Company SADRA (owned by Khatem-ol-Anbiya, with offices in Venezuela);
March 28, 2012
Deep Offshore Technology PJS; Malship Shipping Agency and Modality Ltd (Malta-based affiliates of
IRISL); Seyed Alaeddin Sadat Rasool (IRISL legal adviser); Ali Ezati (IRISL)
Electronic Components Industries Co. (ECI) and Information Systems Iran (ISIRAN); Advanced
July 12, 2012
Information and Communication Technology Center (AICTC) and Hamid Reza Rabiee (AICTC);
Digital Medical Lab (DML) and Value Laboratory; Ministry of Defense Logistics Export (MODLEX);
Daniel Frosh (Austria) and International General Resourcing FZE (UAE, Iran missile assistance)
Congressional Research Service
72

Iran Sanctions

Entity
Date Named
National Iranian Oil Company; Tehran Gostaresh, company owned by Bonyad Taavon Sepah; Imam
November 8,
Hossein University (IRGC); Baghyatol ah Medical Sciences University (services to IRGC)
2012
Atomic Energy Organization of Iran (AEOI) chief Fereidoun Abbasi Davani; Seyed Jaber Safdari
December 13,
of Novin Energy (affiliate of AEOI); Morteza Ahmadi Behzad (services to AEOI); Pouya Control—
2012
provides goods and services for uranium enrichment; Iran Pooya (centrifuge materials); Aria
Nikan Marine Industry (goods for nuclear program); Amir Hossein Rahimyar (procurer for
Iran nuclear program); Mohammad Reza Rezvanianzadeh (nuclear program); Faratech (heavy water
reactor project); Neda Industrial Group (equipment for Natanz facility); Tarh O Palayesh—
(heavy water reactor); Towlid Abzar Boreshi Iran (nuclear program supplier).
SAD Import Export Company (for shipping arms and other goods to Syria’s armed forces); Marine
December 21,
Industries Organization (affiliate of Iran Ministry of Defense and Armed Forces Logistics); Mustafa
2012
Esbati (acting on behalf of Marine Industries); Chemical Industries and Development of Materials
Group (affiliate of Defense Industries Org); Doostan International Company (provided services to
Iran Aerospace Industries Org, which oversees Iran missile industries).
Babak Morteza Zanjani—chairmen of Sorinet Group that finances Iran oil sales abroad; International
April 11, 2013
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—control ed 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
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, (IRGC-Navy boats); Advance Electrical and
February 6, 2014
Industrial Technologies and Pere Punti (Spain), for nuclear procurement; Ulrich Wipperman
and Deutsche Forfait (Germany), and Deutsche Forfait Americas (U.S.) for NIOC oil deals.
Eight China-based front companies and Karl Lee (aka Li Fangwei): Sinotech Industry Co. Ltd.;
April 29, 2014
MTTO Industry and Trade Limited; Success Move Ltd.; Sinotech Dalian Carbon and Graphite
Manufacturing Corporation; Dalian Zhongchuang Char-White Co., Ltd.; Karat Industry Co., Ltd.;
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 (Arak reactor); Jahan Tech Rooyan Pars: and
(by both State
Mandegar Baspar Kimiya Company (carbon fiber for Iran’s nuclear program).
and Treasury)
By Treasury: Mohammad Javad Imarad and Arman Imanirad (aluminum for Iran’s nuclear
program); Nefertiti Shipping (IRISL’s agent in Egypt); Sazeh Morakab (services to SHIG, and Iran’s
Aircraft Manufacturing Industrial Co., HESA); Ali Gholami and Marzieh Bozorg (Sazeh Morakab).
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
Congressional Research Service
73

Iran Sanctions

Entity
Date Named
director of MODAFL); Seyed Mohammad Hashemi; Mehrdada Akhlaghi Ketabachi. Musavi has
worked with North Korean officials on ballistic missiles.
Two Iranian entities subordinate to SHIG: Shahid Nuri Industries and Shahid Movahed
March 24, 2016
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. Abdol ah Asgharzadeh Network (supporting SHIG):
February 3, 2017
Abdol ah 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.
Ballistic missile-related entities. Rahim Ahmadi (linked to Shahid Bakeri Industrial Group);
May 17, 2017
Morteza Farasatpour (Defense Industries Organization); Matin Sanat Nik Andishan (supporting

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

Hekemzadeh; Qeshm Madkandaloo Cooperative Co., Ramor Group (Turkey) and Resit Tavan of
Ramor Group (supplying IRGC-Navy); Emily Liu, Abascience Tech Co. Ltd, Raybeam Optronics Co.
Ltd., Raytronic Corporation Ltd., and Sunway Tech Co. Ltd (all China), for supporting MODAFL.
State: IRGC Aerospace Force Self Sufficiency Jihad Org and IRGC Research and Self Sufficiency
Jihad Org—both for supporting Iran ballistic missile program.
Missile entities related to Iran Simorgh space launch: six subordinates to Shahid Hemmat
July 28, 2017
Industrial Group (SHIG): 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 control ed 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) (military aviation industry); Shi Yuhua (China) (navigation
equipment); Pardazan System Namad Arman (PASNA)(for procuring lead zirconium tritanate (PZT)
for Iranian military); and Bochuang Ceramic Inc. and Zhu Yuequn (China) for selling Iran PZT.
Sayyed Mohammad Ali Haddadnezhad Tehrani, for supporting the IRGC Research and Self-
May 22, 2018
Sufficiency Jihad Organization to improve Houthi missile capabilities
Bank Tejarat (for providing servides to support Bank Sepah); Trade Capital Bank (Belarus); Morteza Nov. 5, 2018
Ahmadali Behzad (for acting on behalf of Pishro Company.
31 individuals/entities connected to Iran’s Organization of Defense Innovation and
March 22, 2019
Research (SPND), Shahid Karimi Group (missiles and explosives); Mohammad Reza Mehdipur,
Akbar Motallebizadeh, Jalal Emami Gharah Hajjlu, and Sa’id Borji. Shahid Chamran Group (electron
acceleration, pulse power, wave generation); Sayyed Ashgar Hashemitabar. Shahid Fakhar
Moghaddam Group (explosion simulators, neutron monitoring systems): Ruhol ah 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
Congressional Research Service
74

Iran Sanctions

Entity
Date Named
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. For
acting on behalf of SPND: Gholam Reza Eta’ati, Mansur Asgari, and Reza Ebrahimi. SPND front
companies and officials: Pulse Niru and officials Mohammad Mahdi Da’emi Attaran and Mohsen
Shafa’i; Kimiya Pakhsh Shargh and officials Mehdi Masoumian, and Mohammad Hossein Haghighian;
and Paradise Medical Pioneers Company.
Petrochemicals Network: Persian Gulf Petrochemical Industries Company (PGPIC), for
June 7, 2019
supporting Khatem ol-Anbiya, and 39 PGPIC subsidiaries and agents: Arvand Petrochemical Co.;
Bandar Imam Abniroo Petrochemical Co (PC).; Bandar Imam Besparan PC; Bandar Imam
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
Nuclear managers: Majid Agha’i, managing director of AEOI and Amjad Sazgar – for engaging in
May 27, 2020
activities involving uranium enrichment in Iran
Iran Shipping Companies: Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping
June 8, 2020
Company (Shanghai). For transporting items related to Iran’s ballistic missile program. Designations
(effective date)
took effect after a 180 day delay to allow Iran to find alternative sources to ship food and medicine.

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 Hezbol ah and PIJ; Goodwil Charitable Organization, a Martyr’s Foundation office in
Dearborn, Michigan; Al Qard Al Hassan—part of Hezbol ah’s financial infrastructure (and associated
with previously designated Hezbol ah entities Husayn al-Shami, Bayt al-Mal, and Yousser Company
for Finance and Investment); Qasem Aliq—Hezbol ah official, director of Martyr’s Foundation
Lebanon branch, and head of Jihad al-Bina (Lebanese construction company run by Hezbol ah);
Ahmad al-Shami (liaison between Hezbol ah and Martyr’s Foundation chapter in Michigan).
IRGC-Qods Force and Bank Saderat (allegedly used to funnel Iranian money to Hezbol ah, 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
Congressional Research Service
75

Iran Sanctions

Entity
Date Named
Khoshnevis, for supporting Lebanese Hezbol ah; Imam Khomeini Relief Committee Lebanon branch,
and its director Ali Zuraik; Razi Musavi, a Syrian based Iranian official supporting Hezbol ah.
Liner Transport Kish (for providing shipping services to transport weapons to Lebanese Hezbol ah)
December 21, 2010
Qasem Soleimani (Qods Force commander); Hamid Abdol ahi (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; Behineh Air (Iranian trading company); Ali Abbas Usman Jega
(Nigeria); Qods Force officers: Esmail Ghani, Sayyid Ali Tabatabaei, and Hosein Aghajani.
Mohammad Minai, senior Qods Force member involved in Iraq; Karim Muhsin al-Ghanimi, leader of
November 8, 2012
Kata’ib Hezbol ah (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 il icit
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), front for Mahan Air;
Hamid Arabnejad, managing director of Mahan Air.
Several persons/entities in UAE aiding Mahan Air (see above): Blue Sky Aviation FZE; Avia Trust
February 6, 2014
FZE; Hamidreza Malekouti Pour; Pejman Mahmood Kosrayanifard; and Gholamreza Mahmoudi.
Several IRGC-Qods Force offices in Afghanistan: Sayyed Kamal Musavi; Alireza Hemmati; Akbar
Seyed Alhosseini; and Mahmud Afkhami Rashidi.
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); Caspian Air (transporting personnel and weapons to
August 29, 2014
Syria); Sayyed Jabar Hosseini (manager of Liner Transport Kish which IRGC uses); Pioneer Logistics
(Turkey, helps Mahan Air); Asian Aviation Logistics (Thailand, helps Mahan Air). Pouya Air
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 Hezbol ah); Muhammad Abd-al-Amir
Farhat; Yahya al-hajj; Maher Trading and Construction Company (laundering funds and smuggling
goods to Hezbol ah); Reem Phamaceutical; Mirage for Engineering and Trading; Mirage for Waste
Management and Environmental Services. Ali Sharifi (procuring 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 (financial activities for IRGC-QF); Mohammadreza Valadzaghard, Meghdad
Amini, and Foad Salehi (il icit financial assistance to the IRGC-QF). Entities: Jahan Aras Kish
(transferring funds for the IRGC-QF, Rashed Exchange (converting currency for the IRGC-QF), and
Khedmati and Company Joint Partnership, for being owned by Khedmati and Khoda’i.
Persons and entities providing IRGC-QF funds to Hezbollah: Central Bank Governor
May 15, 2018
Valiol ah Seif; Aras Habib and his Iraq-based Al Bilad Islamic Bank; and Muhammad Qasir
Congressional Research Service
76

Iran Sanctions

Entity
Date Named
Four persons for helping the Houthi missile program through the IRGC Aerospace
May 22, 2018
Forces Al 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 (including Basij firms that fund child soldiers in Syria):
October 16, 2018
Bonyad Taavon Basij (economic conglomerate); 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; Taktar Investment Company; Iran’s Zinc Mines Development Company;
Calcimin (owned by Iran Zinc Mines; 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 in Middle East); Andisheh Mehvaran
Investment Company; Parsian Bank; Sina Bank; and Bahman Group.
IRGC-QF personnel supporting the Taliban: Mohammad Ebrahim Owhadi and Esma’il Razavi
October 23, 2018
Banks and other Entities. Many of these were also redesignated under EO13382. Bank Melli;
November 5, 2018
Arian Bank; Bank Kargoshaee; Melli Bank PLC; Tose-E Develoment Company; Behshahr Industrial
(in concert with
Development Corp.; Cement Industry and Development Company; Melli International Building and
reimposition of
Industry Company; BMIIC International General Trading LLC; Shomal Cement Company; Persian
JCPOA-related
Gulf Sabz Karafarinan; Mir Business Bank; Export Development Bank of Iran (EDBI); EDBI Stock
sanctions)
Exchange; EDBI Exchange Brokerage; Banco Internacional de Desarrol o, C.A.; Iran-Venezuela Bi-
National Bank; Day Bank; Atieh Sazan Day; Buali Investment Company; Tejarat Gostar Fardad; Day
Exchange Company; Day Leasing Co.; Day Brokerage Co.; Tose-e Didar Iran Holding Co.; Royay-e
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 Hezbol ah 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 and funds
November 20, 2018
Hezbollah and Hamas: Mohamed Amer Alchwiki (also designated under E.O. 13582 for providing
financial support to Syria); Global Vision Group (also designated under E.O. 13582); Rasul Sajjad and
Hossein Yaghoobi (for assisting the IRGC-QF); and Muhammad Qasim al-Bazzal (for assisting
Hezbol ah).
Also designated under E.O. 13582 as part of the network: Promsyrioimport; Andrey Dogaev; Mir
Business Bank; and Tadbir Kish Medical and Pharmaceutical Company
Iran-recruited Afghan and Pakistani-staffed militia entities fighting in Syria: Fatemiyoun
January 24, 2019
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 funds via the IRGC-controlled Ansar Bank
March 26, 2019
and Ansar Exchange: MODAFL; Ansar Bank, its managing director Ayatol ah 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 Asadolah Seifi;
Seifi-owned UAE firm The Best Leader General Trading; Sulayman Sakan and his firm Atlas Doviz
Ticaret A.S. (Turkey) for assisting Atlas Exchange; Ali Shams Mulavi—Turkey-based facilitator for
Ansar Exchange and UAE-based Naria General Trading; Lebra Moon General Trading (UAE).
Iraq-based entities facilitating IRGC-QF access to Iraq’s financial system: South Wealth
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
Congressional Research Service
77

Iran Sanctions

Entity
Date Named
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);
Yadol ah Badin (district 3); Mansur Ravankar (district 4); and Ali Ozma’I (district 5)
Hezbollah Parliamentarians: Two Hezbol ah parliamentarians for using their parliamentary
July 9, 2019
positions to advance Hezbol ah objectives and “bolstering Iran’s malign activities”: Amin Sherri and
Muhammad Hasan Ra’d (who is also a member of Hezbol ah’s Shura Council). Also designated: head
of Hezbol ah 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.
Persons and Entities Facilitating Funding from IRGC-QF Muhammad Sa’id Izadi (head of
September 10, 2019
Palestinian Office of the IRGC-QF contingent in Lebanon); Zaher Jabarin (Turkey-based Hamas
liaison with the IRGC-QF); Redin Exchange (Turkey-based financial channel for IRGC-QF funding of
Hamas and Hezbol ah); Marwan Mahdi Salah Al Rawi (CEO of Redin Exchange); Ismael Tash (deputy
CEO of Redin and facilitator of money transfers from Iran to Hamas); SMART (Ithalat Ihracat Dis
Ticaret Limited Sirketi, import-export company associated with Redin)
Central Bank. Central Bank of Iran, National Development Fund of Iran, and Etemad Tejarate Pars
September 20, 2019
Co. For funneling funds to the IRGC. MODAFL, and Lebanese Hezbol ah. National Development
Fund, a sovereign wealth fund, is primarily involved in rural electrification and development.
IRGC-QF Shipping Network to Yemen: Abdolhossein Khedri; Khedri Jahan Darya Co;
December 11, 2019
Maritime Silk Road LLC. Mahan Air Sales Agents: Gatewick LLC (Dubai); Jahan Destination Travel
and Tourism LLC (Dubai); and Gomei Ai Services Co. (Hong Kong)
Hezbollah Individuals and Entities: Three individuals and 12 entities linked to the Martyr’s
February 26, 2020
Foundation, which is part of Hezbol ah’s support network. Entities sanctioned included Atlas
Holdings and its affiliates involved in medical equipment, pharmaceuticals, paints, and tourism
Iran and Iraq-based front companies controlled or supporting the IRGC-QF Individuals
March 26, 2020
and entities including: Reconstruction Organization of the Holy Shrines in Iraq; Kosar Company;
Alireza Fadakar (IRGC-QF commander in Najaf); Al Khamael Maritime Services (partly owned by
QF); Mada’in Novin Traders; Sayyed Yaser Musavir (QF official helping Iraqi Shia militias); Shaykh
Adnan al-Hamidawi (special operations commander for Kata’ib Hezbol ah militia);

Table D-3. Determinations and Sanctions under the Iran Sanctions Act
Entity
Date Named
Total SA (France); Gazprom (Russia); and Petronas (Malaysia)—$2 bil ion 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. Violation determined but
sanctions waived.
Congressional Research Service
78

Iran Sanctions

Entity
Date Named
Naftiran Intertrade Co. (NICO), Iran and Switzerland. Sanctioned for activities to develop Iran’s energy
Sept. 30, 2010
sector.
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 mil ion 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).
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).
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. U.S.-based subsidiaries of PDVSA, such as Citgo, were not sanctioned.
Zhuhai Zhenrong Co. (China); Kuo Oil Pte Ltd. (Singapore); FAL Oil Co. (UAE)
January 12, 2012
Sanctioned for brokering sales or making sales to Iran of gasoline.
Sytrol (Syria), for sales of gasoline to Iran.
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.
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 il icitly sell Iranian crude oil.
Dettin SPA (Italy) For providing goods and services to Iran’s petrochemical industry.
August 29, 2014

Table D-4. Entities Sanctioned Under the Iran North Korea Syria Nonproliferation
Act or Executive Order 12938 for Iran-Specific Violations
These designations expired after two years, unless redesignated. The designations included in this table
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 (removed May
January 8, 1999
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
Congressional Research Service
79

Iran Sanctions

Entity
Date Named
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 artil ery shells to Iran. (Also
September 17,
designated under Executive Order 12938)
2003
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, sanctioned previously. Others
and January 2005
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
Zibo Chemical, China National Aerotechnology, and China National Electrical (China). Korean Mining and
Industrial Development (North Korea) for WMD/advanced weapons sales to Iran and Syria.
14 entities, including Lebanese Hezbol ah. Some were penalized for transactions with Syria. For assisting
April 17, 2007
Iran: 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/Yul in 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
Congressional Research Service
80

Iran Sanctions

Entity
Date Named
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
(China); Marine Industries Organization (Iran); Milad Jafari (Iran); Poly Technologies (China); Scientific and
Industrial Republic Unitary Enterprise (Belarus); SMT Engineering (Sudan); TM Services Ltd. (Belarus);
Venezuelan Military Industry Co. (CAVIM, Venezuela).
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.
Technologies (Sudan); Military Industrial Corps. (Sudan); Yarmouk Industrial Complex (Sudan); Venezuelan
Military Industry Co. (CAVIM, Venezula)
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); Hezbol ah; Eliya General Trading (UAE). (Designations
that applied to Syria or North Korea not included.)
Asaib Ahl Haq (Iraqi Shi te militia); Katai’b Hezbol ah (Iraqi militia); IRGC; Shahid Moghadam-Yazd Marine
June 28, 2016
Industries (Iran); Shiraz Electronic Industries (Iran); Hezbol ah; Military Industrial Corp. (Sudan); Khartoum

Industrial Complex (Sudan); Khartoum Military Industrial Complex (Sudan); Luwero Industries (Uganda)
11 entities sanctions for transfers of sensitive items to Iran’s ballistic missile program (all China except as
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 Shi te militia
fighters; Abu Mustafa al-Sheibani. Iran based leader of network that funnels Iranian arms to
Shi te militias in Iraq; Isma’il al-Lami (Abu Dura). Shi te militia leader, breakaway from Sadr
Mahdi Army; Al Zawra Television Station and its owner, Mishan al-Jabburi.
Abdul Reza Shahlai, a deputy commander of the Qods Force; Akram Abbas Al Kabi, leader
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
Congressional Research Service
81

Iran Sanctions

Entity
Date Named
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).
Khata’ib Hezbol ah (Mahdi splinter group); Abu Mahdi al-Muhandis. (Muhandis was kil ed in
July 2, 2009
the U.S. strike of January 3, 2020, that kil ed IRGC-Qf commander Qasem Soleimani.)

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 Intelligence 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 Abdol ah 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 fol owing 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 Hezbol ah internal security militia designations: Ansar-e Hezbol ah; 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
Abdolreza Rahmani Fazli (Interior Minister); LEF officials Hossain Ashtari Fard, Ayoub
May 20, 2020
Soleimani, Mohsen Fathi Zadeh, Yahya Mahmoodzadeh, Hamidreza Ashraq, and Mohammad
Ali Noorinajad; Hassan Shavarpour Najafabadi (IRGC Vali Asr base commander): LEF
Cooperative Foundation and its manager Habil Darvis.
Congressional Research Service
82

Iran Sanctions

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
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

Table D-9. Iranian Entities Sanctioned Under Executive Order 13606 (GHRAVITY,
April 23, 2012))
Entity
Date Named
Ministry of Intelligence and Security (MOIS); IRGC (Guard Cyber Defense Command); Law
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

Table D-10. Entities Sanctioned Under Executive Order 13608 Targeting Sanctions
Evaders (May 1, 2012)
Entity
Date Named
Ferland Company Ltd. for helping NITC deceptively sel 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
February 7, 2019
Iran

Table D-11. Entities Named as Iranian Government Entities Under Executive Order
13599 (February 5, 2012)
Hundreds of entities—many of which are names and numbers of individual ships and aircraft—were
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.
Congressional Research Service
83

Iran Sanctions

Entity
Date Named
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.
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
Congressional Research Service
84

Iran Sanctions

Entity
Date Named
Arya Company; Hormuz Oil Refining Company; Ghaed Bassir Petrochemical Products Company;
Persia Oil and Gas Industry Development Company; Pars Oil Company; Commercial Pars Oil
Company; Marjan Petrochemical Company; Ghadir Investment Company; Sadaf Petrochemical
Assaluyeh Company; Polynar Company; Pars MCS; Arman Pajouh Sabzevaran Mining Company;
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, in keeping with the reimposition of U.S. sanctions.
November 5, 2018
Five unnamed Iranian ship captains for delivering gasoline to Venezuela
June 24, 2020

Table D-12. Entities Sanctioned Under Executive Order 13622 for Oil and
Petrochemical Purchases from Iran (July 30, 2012)
Entity
Date Named
Jam Petrochemical Company (for purchasing petrochemical products from Iran); 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 mil ion 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-13. Entities Sanctioned under the Iran Freedom and Counter-Proliferation
Act (IFCA, P.L. 112-239)
Entity
Date Named
Goldentex FZE (UAE)
August 29, 2014
Zhuhai Zhenrong (China) for purchasing oil from Iran
July 22, 2019
Global Industrial and Engineering Supply Ltd. (China and Hong Kong) For transferring
June 25, 2020
graphite to IRISL

Table D-14. Entities Designated as Human Rights Abusers under Executive Order
13628 (October 9, 2012, pursuant to ITRSHRA)
Entity
Date Named
Ali Fazli, deputy commander of the Basij; Reza Taghipour, Minister of Communications and
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, (censorship
equipment); PekyAsa, another company owned by Jalili, to develop telecom software.
Congressional Research Service
85

Iran Sanctions

Entity
Date Named
Islamic Republic of Iran Broadcasting (IRIB) and Ezzatol ah Zarghami (director and head of
February 6, 2013
IRIB); Iranian Cyber Police (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 blocking cellphones of opposition leaders Mir Hosein Musavi and
May 23, 2014
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).
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 (Secretary of the
Committee to Determine Instances of Criminal Conduct (oversees Internet censorship)

Table D-15. Entities Designated under E.O. I3645 on Auto production, Rial Trading,
Precious Stones, and Support to NITC (June 3, 2013)
Entity
Date Named
Five entities/persons supporting NITC: 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-16. Entities Designated under Executive Order 13581 on Transnational
Criminal Organizations (July 24, 2011)
Entity
Date Named
Four individuals/entities: Ajily Software Procurement Group, Andisheh Vesal Middle East
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.
Congressional Research Service
86

Iran Sanctions

Table D-17. 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, Saj ad Tamasebi, Abdol ah Karima, Abuzr Gohair Moqadam. Roozbeh Sabahi,
Mohammed Reza Sabai, Behzad Mesri.
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-18. Entities Designated under E.O.13846 Reimposing Sanctions
(August 6, 2018)
Entity
Date Named
Ayandeh Bank (for materially assisting IRIB).
November 5, 2018
Subsidiaries of China’s COSCO Shipping Corp. Ltd and persons for involvement September 25,
in oil shipments from Iran: China Concord Petroleum Ltd.; COSCO Shipping Tanker
2019
(Dalian) Ltd.; COSCO Shipping Tanker (Dalian) Seaman and Ship Management Co. Ltd.;
Kunlun Holding Co Ltd.; Kunlun Shipping Co. Ltd; Pegasus 88 Ltd.; Yi Li; Yu Hua Mao;
Luqian Shen; Bin Xu; Yazhou Xu.
Under Section 7 of the E.O. (Human Rights related provision sanctioning persons who limit
December 19, 2019
freedom of expression in Iran): Abolghassem Salavati, Mohammad Moghisseh (judges
presiding over branches of the regime’s Revolutionary Court)
Several petrochemical companies for brokering sales of Iranian oil and other
January 23, 2020
petroleum products to China and UAE: Sanctioned by Treasury: Triliance
Petrochemical Co. Ltd (Hong Kong); Sage Energy HK Limited (Hong Kong); Peakview
Industry Co. Ltd (Shanghai); and Beneathco DMCC (Dubai). Sanctioned by State Dept.:
Shandong Qiwangda Petrochemical Co. Ltd (China); Jiaxing Industry Hong Kong Ltd.; Ali
Bayandarian; and Zhiqing Wang
Entities involved in petrochemical transactions with Iran SPI International
March 18, 2020
Proprietary Ltd. and Main Street 1095 (South Africa). McFly Plastic HK Ltd.; Saturn Oasis
Co.; and Sea Charming Shipping Co. Ltd (Hong Kong). Dalian Golden Sun Import and
Export Co. and Tianyin International Co. Ltd (Dalian, China). Aoxing Ship Management Ltd.
(Shanghai). Armed Forces Social Security Investment Company (Iran). Mohammad Hassan
Toulai (managing director of Armed Forces Social Security Investment Company); Hossein
Tavakkoli; and Rea Ebadzadeh Semnani.
UAE Companies facilitating Iran petrochemical and oil sales Petro Grand FZE;
March 19, 2020
Alphabet International DMCC; Swissol Trade DMCC; Alam Althrwa General Trading LLC;
and Alwaneo LLC Co.
For facilitating Iran petrochemical transactions: Triliance Petrochemical Co. Ltd
January 23, 2020
(Hong Kong); Sage Energy HK Limited (Hong Kong); Peakview Industry Co. Limited
(Shanghai); and Beneathco DMCC (UAE)
Congressional Research Service
87

Iran Sanctions

Table D-19. Executive Order 13871 on Metals and Minerals (May 8, 2019)
Entity
Date Named
Pamchel Trading Beijing Ltd; Power Anchor Ltd (Seychelles); Hongyuan Marine Co.;
January 10. 2020
Mobarakeh Steel Company (Iran, previously designated under E.O 13224); Saba Steel;
Hormozgan Steel Co.; Esfahan Steel Co.; Oxin Steel Co.; Khorasan Steel Co.; South Kaveh
Steel Co.; Iran Alloy Steel Co; Golgohar Mining and Industrial Co,; Chadormalu Mining and
Industrial Co.; Arfa Iron and Steel Co.; Khouzestan Steel Co.; Iranian Ghadir Iron and Steel
Co.; Reputable Trading Source LLC (Oman); Iran Aluminum Co.; Al Mahdi Aluminum Co.;
National Iranian Copper Industries; and Khalagh Tadbir Pars Co.
Affiliates of Iran’s Mobarakeh Steel Company: Iran – Metil Steel; South Aluminum
June 25, 2020
Company; Sirjan Jahan Steel Complex; and Iran Central Iron Ore Company. Others: Tara
Steel GmbH (Germany); UAE - Pacific Steel FZE; Better Future General Trading Co LLC;
and Tuka Metal Trading DMCC.

Table D-20. Entities Designated as Gross Human Rights Violators under Section
7031(c) of Foreign Aid Appropriations
Entity
Date Named
Two Iranian prisons: Great Tehran Penitentiary; Qarchak Prison
December 5, 2019
Hassan Shahvarpour - IRGC commander of Vali Asr unit
January 18, 2020
Abdolreza Rahmani Fazli (Interior Minister), and Ali Fallahian (Intelligence head during 1989-
May 20, 2020
1997)

Table D-21. Entities Designated under E.O. 13876 on the Supreme Leader and his
Office (June 24, 2019)
Entity
Date Named
Foreign Minister Mohammad Javad Zarif
July 31, 2019
Ten High-Ranking Officials/Personalities and One Major Entity: Ebrahim Raisi (head of the
November 4, 2019
judiciary); Mojtaba Khamene’i (second son of the Supreme Leader, and liaison with the
IRGC-QF and Basij); Mohammad Mohammadi Golpayegani (chief of staff to the Supreme
Leader); Vahid Haghanian (top aide to the Supreme Leader); Ali Akbar Velayati (former
Foreign Minister and top foreign policy adviser to the Supreme Leader); Gholam-Ali
Hadad-Adel (former Majles Speaker, adviser to the Supreme Leader); Mohammad Bagheri
(head of the Armed Forces General Staff); Iran Armed Forces General Staff; Hossein
Dehghan (military aide to the Supreme Leader, former Defense Minister, and former
commander of the IRGC-QF contingent in Lebanon); Gholam Ali Rashid (head of Khatem
ol-Anbiya Central Headquarters, a major military headquarters).
Ali Shamkhani—Secretary General of Iran Supreme National Security Council;
January 10, 2020
Gholamreza Soleimani—commander of the Basij; Mohsen Reza’i—Expediency Council
member and IRGC commander-in-chief 1981-1997; Mohammad Reza Naqdi—former
Basij commander; Mohammad Reza Ashtiani—deputy chief of staff of the Armed Forces;
IRGC Brig. Gen. Ali Abdol ahi—coordination deputy for the Armed Forces General Staff;
Ali Asghar Hejazi—chief of Supreme Leader security; Mohsen Qomi—advisor to the
Supreme Leader on international communications
Congressional Research Service
88

Iran Sanctions

Members of Council of Guardians and Elections Supervision Committee (for
February 20, 2020
manipulating Iran’s parliamentary elections): Ahmad Jannati (head of the Council of
Guardians); Mohammad Yazdi; Siamak Rahpeyk; Abbas Ali Kadkhodaie (Council speaker);
and Mohammad Hasan Sadeghi Moghadam

Table D-22. Executive Order 13818 Implementing the Global Magnitsky Act
(December 20, 2017)
Entity
Date Named
Iran-backed Iraqi militia figures: Qais al-Khazali (head of
December 6, 2019
Asa’ib Ahl Al Haq militia); Laith al-Khazali; Husayn Falih
al-Lami

Author Information

Kenneth Katzman

Specialist in Middle Eastern Affairs

Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
shared staff to congressional committees and Members of Congress. It operates solely at the behest of and
under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not
subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in
its entirety without permission from CRS. However, as a CRS Report may include copyrighted images or
material from a third party, you may need to obtain the permission of the copyright holder if you wish to
copy or otherwise use copyrighted material.

Congressional Research Service
RS20871 · VERSION 307 · UPDATED
89