Iran Sanctions Updated November 18 2020 Congressional Research Service https crsreports congress gov RS20871 SUMMARY Iran Sanctions Successive Administrations and Congresses have used economic sanctions to try to change Iran’s behavior U S sanctions on Iran which are primarily “secondary sanctions” on firms that conduct certain transactions with Iran have adversely affected Iran’s economy but have arguably not to date altered Iran’s pursuit of core strategic objectives including its support for regional armed factions and its development of missiles 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 RS20871 November 18 2020 Kenneth Katzman Specialist in Middle Eastern Affairs 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 eased the relevant sanctions 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 nonbinding restriction on Iran’s development of nuclear-capable ballistic missiles until October 18 2023 The sanctions relief enabled Iran’s economy to return to growth and allowed Iran to order some new passenger aircraft On May 8 2018 President Trump ended U S participation in the JCPOA and reimposed all secondary sanctions by November 6 2018 The re-imposed sanctions and additional sanctions imposed since have 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 Iran’s economy to fall 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 figures in regional pro-Iranian factions and militias 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 presumptive winner of the 2020 presidential election former Vice President Joseph Biden stated in September 2020 an intent to rejoin the JCPOA if elected a step that would require revoking those sanctions reimposed and imposed since 2018 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 and it has offered assistance to help Iran deal with COVID-19 but Iran has refused the U S aid 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 Contents Overview 1 Blocked Iranian Property and Assets 1 Executive Order 13599 Impounding Iran-Owned Assets 3 Sanctions for Iran’s Regional Armed Factions 3 Sanctions Triggered by Terrorism List Designation 3 Exception for U S Humanitarian Aid 5 Sanctions on States “Not Cooperating” Against Terrorism 5 Executive Order 13224 Sanctioning Terrorism-Supporting Entities 5 Implementation of E O 13224 5 Foreign Terrorist Organization FTO Designations 6 Other Sanctions on Iran’s Support for Regional Armed Factions 6 Executive Order 13438 on Threats to Iraq’s Stability 6 Executive Order 13572 on Repression of the Syrian People 6 Hezbollah-Specific Financial Sanctions 7 Ban on U S Trade and Investment with Iran 7 What U S -Iran Trade Is Allowed or Prohibited 8 Application to Foreign Subsidiaries of U S Firms 10 Sanctions on Iran’s Energy Sector 10 The Iran Sanctions Act 11 Key Sanctions “Triggers” Under ISA 11 Mandate and Time Frame to Investigate ISA Violations 14 Interpretations of ISA and Related Laws 15 Implementation of Energy-Related Iran Sanctions 16 Oil Export Sanctions FY2012 NDAA Sanctioning the Central Bank 17 Implementation SREs Issued and Ended 18 Waiver and Termination 19 Iran Foreign Account “Restriction” Provision 19 Sanctions on Arms and Weapons-Related Technology Transfers 20 Iran-Iraq Arms Nonproliferation Act and Iraq Sanctions Act 21 Banning Aid to Countries that Aid or Arm Terrorism List States Anti-Terrorism and Effective Death Penalty Act of 1996 21 Proliferation-Related Provision of the Iran Sanctions Act 22 Iran-North Korea-Syria Nonproliferation Act 22 Executive Order 13382 on Proliferation-Supporting Entities 22 Arms Transfer and Missile Sanctions The Countering America’s Adversaries through Sanctions Act CAATSA P L 115-44 23 Executive Order 13949 on Sales of Arms September 21 2020 23 Foreign Aid Restrictions for Named Suppliers of Iran 23 Sanctions on “Countries of Diversion Concern” 24 Financial Banking Sanctions 25 Targeted Financial Measures 25 Ban on Iranian Access to the U S Financial System Use of Dollars 25 Punishments Fines Implemented against Some Banks 26 CISADA Sanctioning Foreign Banks That Conduct Transactions with Sanctioned Iranian Entities 27 Congressional Research Service Iran Sanctions Implementation 27 Waiver and Termination 27 Iran Designated a Money-Laundering Jurisdiction 28 Financial Action Task Force FATF 28 “SWIFT” Electronic Payments System 29 Sanctions on Iran’s Non-Oil Industries and Sectors 29 The Iran Freedom and Counter-Proliferation Act IFCA 29 Implementation 30 Waiver and Termination 30 Executive Order 13645 13846 Iran’s Automotive Sector Rial Trading and Precious Stones 30 Executive Order 13871 on Iran’s Minerals and Metals Sectors 31 Executive Order 13902 on the Construction Mining Manufacturing and Textiles Sector January 10 2020 31 Executive Order 13608 on Sanctions Evasion 32 Sanctions on Cyber and Criminal Activities 32 Executive Order 13581 32 Executive Order 13694 32 U S State-Level Sanctions 32 Sanctions Supporting Democracy Human Rights 32 Expanding Internet and Communications Freedoms 33 Measures to Sanction Human Rights Abuses Promote Civil Society 34 Non-Iran Specific Human Rights Laws 35 Sanctions on Iran’s Leadership 36 Executive Order 13876 36 U N Sanctions 36 Resolution 2231 and U N Sanctions Eased 36 Sanctions Application under Nuclear Agreements 38 Sanctions Eased by the JPoA 38 Sanctions Easing under the JCPOA and U S Re-imposition 38 U S Sanctions that Remained in Place under the JCPOA 40 Sanctions Imposed Subsequent to the U S Exit from the JCPOA 41 International Implementation and Compliance 42 European Union EU 42 European Special Purpose Vehicle INSTEX 43 SWIFT Electronic Payments System 44 China and Russia 44 Japan Korean Peninsula Other East Asian Countries 45 Other East Asian Countries 45 India and Pakistan 46 Turkey 46 Iraq and Persian Gulf States 47 Syria and Lebanon 48 Venezuela 48 International Financial Institutions World Bank IMF and WTO 48 WTO Accession 49 Effectiveness of Sanctions 49 Congressional Research Service Iran Sanctions Effect on Iran’s Nuclear Program and Strategic Capabilities 49 Effects on Iran’s Regional Influence 50 Iranian Domestic Political Effects 50 Economic Effects 51 Iran’s Economic Coping Strategies 52 Effect on Energy Sector Development 53 Human Rights-Related Effects 54 Humanitarian Effects 54 U S COVID Response 54 Air Safety 55 Post-JCPOA Sanctions Legislation 55 114th Congress 56 Iran Nuclear Agreement Review Act P L 114-17 56 Visa Restriction 56 Iran Sanctions Act Extension 57 Reporting Requirement on Iran Missile Launches 57 Some of the 114th Congress Legislation that was not Enacted 57 The Trump Administration and Iran Sanctions Legislation 58 The Countering America’s Adversaries through Sanctions Act of 2017 CAATSA P L 115-44 58 Major Legislation in the 115th Congress that was not Enacted 58 116th Congress 58 Other Possible U S and International Sanctions 59 Figures Figure 1 Economic Indicators 53 Tables Table 1 Iran Crude Oil Sales 20 Table 2 Major Settlements Fines Paid by Banks for Violations 26 Table 3 Summary of Provisions of U N Resolutions on Iran Nuclear Program 1737 1747 1803 1929 and 2231 37 Table D-1 Entities Designated Under U S Executive Order 13382 Proliferation 70 Table D-2 Iran-Related Entities Sanctioned Under Executive Order 13224 Terrorism Entities 75 Table D-3 Determinations and Sanctions under the Iran Sanctions Act 78 Table D-4 Entities Sanctioned Under the Iran North Korea Syria Nonproliferation Act or Executive Order 12938 for Iran-Specific Violations 79 Table D-5 Entities Designated under the Iran-Iraq Arms Non-Proliferation Act of 1992 81 Table D-6 Entities Designated as Threats to Iraqi Stability under Executive Order 13438 July 17 2007 81 Congressional Research Service Iran Sanctions Table D-7 Iranians Designated Under Executive Order 13553 on Human Rights Abusers September 29 2010 81 Table D-8 Iranian Entities Sanctioned Under Executive Order 13572 for Repression of the Syrian People April 29 2011 82 Table D-9 Iranian Entities Sanctioned Under Executive Order 13606 GHRAVITY April 23 2012 83 Table D-10 Entities Sanctioned Under Executive Order 13608 Targeting Sanctions Evaders May 1 2012 83 Table D-11 Entities Named as Iranian Government Entities Under Executive Order 13599 February 5 2012 83 Table D-12 Entities Sanctioned Under Executive Order 13622 for Oil and Petrochemical Purchases from Iran July 30 2012 85 Table D-13 Entities Sanctioned under the Iran Freedom and Counter-Proliferation Act IFCA P L 112-239 85 Table D-14 Entities Designated as Human Rights Abusers under Executive Order 13628 October 9 2012 pursuant to ITRSHRA 85 Table D-15 Entities Designated under E O I3645 on Auto production Rial Trading Precious Stones and Support to NITC June 3 2013 86 Table D-16 Entities Designated under Executive Order 13581 on Transnational Criminal Organizations July 24 2011 86 Table D-17 Entities Designated under Executive Order 13694 on Malicious Cyber Activities April 1 2015 86 Table D-18 Entities Designated under E O 13846 Reimposing Sanctions August 6 2018 87 Table D-19 Executive Order 13871 on Metals and Minerals May 8 2019 88 Table D-20 Entities Designated as Gross Human Rights Violators under Section 7031 c of Foreign Aid Appropriations 88 Table D-21 Entities Designated under E O 13876 on the Supreme Leader and his Office June 24 2019 88 Table D-22 Executive Order 13818 Implementing the Global Magnitsky Act December 20 2017 89 Table D-23 Executive Order 13902 on the Construction Textiles and other Sectors January 10 2020 89 Table D-24 Executive Order 13949 on Conventional Arms to Iran September 21 2020 89 Table D-25 Entities Sanctions Under CAATSA 90 Appendixes Appendix A U S U N EU and Allied Country Sanctions 60 Appendix B Post-1999 Major Investments in Iran’s Energy Sector 63 Appendix C Entities Sanctioned Under U N Resolutions and EU Decisions 67 Appendix D Entities Sanctioned under U S Laws and Executive Orders 70 Congressional Research Service Iran Sanctions Contacts Author Information 90 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 coincident with JCPOA taking 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” hereinafter “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 New York City office building and properties in Texas California Virginia Maryland and other parts of New York City An Iranian entity the Alavi Foundation 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 legal control over the New York office building  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 State Department officials told CRS in November 2012 that the United States later arranged to provide a substitute used aircraft to Iran in lieu of paying Iran for the Airbus 3 http www treasury gov resource-center sanctions Documents tar2010 pdf 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 4 Congressional Research Service 2 Iran Sanctions 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 Numerous designations have been made under Executive Order 13599 including the June 4 2013 naming of 38 entities 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 controlling “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 such transactions In concert with the U S withdrawal from the JCPOA in 2018 virtually all of the 13599-designated entities were relisted 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 Regional Armed Factions 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 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 5 Department of Treasury Treasury Targets Assets of Iranian Leadership June 4 2013 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 6 Congressional Research Service 3 Iran Sanctions      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 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 95118 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 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 defines two different requirements for a President to remove a country from the list depending on whether the country’s regime has changed If the country’s regime has changed the President can remove a country from the list immediately by certifying that regime change in a report to Congress If the country’s regime has not changed the President must report to Congress 45 days in advance of the effective date of removal The President must certify that 1 the country has not supported international terrorism within the preceding six months and 2 the country has provided assurances it will not do so in the future In this latter circumstance Congress has the opportunity to block the removal by enacting a joint resolution to that effect The President has the option of vetoing the joint resolution and blocking the removal then requires a veto override Congressional Research Service 4 Iran Sanctions Exception for U S Humanitarian Aid The terrorism list designation as well as virtually all other U S sanctions laws do not bar U S humanitarian aid to Iran 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 The U S military flew 68 000 kilograms of supplies to Bam The Trump Administration has offered Iran assistance via the World Health Organization to help it battle the COVID-19 outbreak in early 2020 but Iran refused the aid 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 antiterrorism 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 provision was enacted April 1996 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 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 after the September 11 2001 attacks on the United States targeted Al Qaeda but it has subsequently been used to sanction 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 11544 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 designated the IRGC under E O 13224 on October 13 2017 Implementation of E O 13224 Successive Administrations have used the order to sanction Iran-related entities including members of Iran-allied organizations that finance or facilitate Iran’s regional interventions 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 In part because of the inter-agency process required to conclude that an entity is no longer involved in terrorism no entities designated under E O 13224 were delisted to implement the JCPOA The Iran-related entities designated under the order are shown in the tables later in the report 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-ordermodernizing-sanctions-combat-terrorism Congressional Research Service 5 Iran Sanctions 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 PFLPGC Leftwing secular Palestinian group based mainly in Syria Al Ashtar Brigades Bahrain militant opposition group Other Sanctions on Iran’s Support for Regional Armed Factions 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  The July 7 2007 order blocks U S -based property of persons determined to “have committed or pose a significant risk of committing” acts of violence that threaten the peace and stability of Iraq or that undermine efforts to promote economic reconstruction or political reform in Iraq Persons sanctioned to date include IRGC-Qods Force officers Iraqi Shiite militia-linked figures and other entities some of which are prominent roles in Iraq’s parliament and politics Executive Order 13572 on Repression of the Syrian People  The April 29 2011 order blocks the U S -based property of persons determined to be responsible for repression of the Syrian people The IRGC-Qods Force IRGC-QF IRGC-QF commanders and others are sanctioned under this order “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 10 Congressional Research Service 6 Iran Sanctions 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 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 – an apparent reference to 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 It superseded and broadened Executive Order 12957 which was issued two months earlier March 15 1995 barring 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 has renewed the “state of emergency ” 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 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 the JCPOA the ban on U S importation of the Iranian luxury goods discussed above carpets caviar nuts etc was again relaxed but general U S -Iran trade remained prohibited Non-sanctioned Iranian airlines Iran was also permitted to buy U S commercial aircraft 13 The Trump Administration restored the ban on importation of Iranian carpets and other luxury goods effective August 6 2018 in implementing the pullout from the JCPOA 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 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 Congressional Research Service 7 Iran Sanctions 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 including 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 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 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 Preexisting licensing restrictions went back into effect on August 6 2018 Sales of 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 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 8 Iran Sanctions      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 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 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 Congressional Research Service 9 Iran Sanctions 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 The President has authority under IEEPA to license transactions with Iran the ITRSHRA notwithstanding 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 Trump Administration revoked General License H and restored the pre-JCPOA licensing policy “Statement of Licensing Policy ” SLP on November 6 2018 Trade Ban Easing and Termination Termination Section 401 of the Comprehensive Iran Sanctions Accountability and Divestment Act of 2010 CISADA P L 111-195 provides for the President to terminate the trade ban if the Administration certifies to Congress that Iran no longer satisfies the requirements to be designated as a state sponsor of terrorism and that Iran has ceased pursuing and has dismantled its nuclear biological and chemical weapons and ballistic missiles and related launch technology 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 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 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 10 Iran Sanctions 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 that is subject to sanctions However the Trump Administration used various terrorism-related provisions to sanction some Iranian oil shipments and persons involved in shipping Iranian oil arguing 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 The Iran Sanctions Act This section 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 ISA does not sanction purchasing crude oil from Iran 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 that were waived during JCPOA implementation were reinstated in 2018 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 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 energyrelated 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 related to 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 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 11 Iran Sanctions 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 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 Trigger 4 Provision of Equipment 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 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 201227642 pdf 23 Congressional Research Service 12 Iran Sanctions  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 to transportation of oil to countries that have received exemptions under Section 1245 of 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 ISA—require the application of ISA menu 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 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 In 2012 the Department of the Treasury determined that NIOC and NITC are affiliates of the IRGC and it designated NIOC as a proliferation entity under Executive Order 13382 The designations triggered in accordance with Section 104 of CISADA a ban on any foreign bank determined to have dealt directly with NIOC or NIOC bank account 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 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 24 Congressional Research Service 13 Iran Sanctions E O 13622 also blocked U S -based property of entities determined to have  assisted or provided goods or services to NIOC NICO or the Central Bank of Iran  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 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 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 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 says that 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 exercise oversight over Administration investigations of 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 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 follows 1 denial of Export-Import Bank loans credits or credit guarantees for U S exports to the sanctioned entity 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 moneylaundering for use to further WMD programs Congressional Research Service 14 Iran Sanctions original ISA 2 denial of licenses for the U S export of military or militarily useful technology to the entity original ISA 3 denial of U S bank loans exceeding $10 million in one year to the entity original ISA 4 if the entity is a financial institution a prohibition on its service as a primary dealer in U S government bonds and or a prohibition on its serving as a repository for U S government funds each counts as one sanction 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 controlling shareholders of a sanctioned firm added by ITRSHRA 12 imposition of any of the ISA sanctions on principal offices of a sanctioned firm added by ITRSHRA Mandatory Sanction Prohibition on Contracts with the U S Government CISADA §102 b added a requirement in ISA that companies as a condition of obtaining a U S government contract certify to the relevant U S government agency that the firm—and any companies it owns or controls—are not violating ISA Regulations to implement this requirement were issued on September 29 2010 Executive Order 13574 of May 23 2011 and E O 13628 of October 9 2012 specify which sanctions are to be imposed E O 13574 stipulated that when an entity is sanctioned under Section 5 of ISA the penalties to be imposed are numbers 3 6 7 8 and 9 above E O 13628 updated that specification to also include ISA sanctions numbers 11 and 12 The orders also clarify that it is the responsibility of the Department of the Treasury to implement those ISA sanctions that involve the financial sectors E O 13574 and 13628 were revoked by E O 13716 on Implementation Day in accordance with the JCPOA They were reinstated and superseded by E O 13846 of August 6 2018 which mandated that when ISA sanctions are to be imposed that the sanctions include ISA sanctions numbers 3 6 7 8 9 10 and 12 Interpretations of ISA and Related Laws The sections below provide information on how key ISA provisions have been applied Application to Energy Pipelines ISA’s definition of “investment” has been consistently interpreted to include construction of energy pipelines to or through Iran because pipelines help Iran develop its petroleum oil and natural gas sector 26 Application to Purchases from Iran of Natural Gas ISA and other laws such as IFCA exclude from sanctions natural gas transactions with Iran However construction of gas pipelines involving Iran is subject to ISA sanctions And sanctions on financial transactions with Iran might impede gas transactions with Iran 26 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 “Tough US warning on Iran gas pipeline ” Dawn March 1 2012 Congressional Research Service 15 Iran Sanctions 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 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 However another law CISADA see below 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 Iran has not developed an LNG export capability to date 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 because these agencies are arms of their parent governments 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 16 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 followed prior sunset extensions to December 31 2011 by P L 109-293 December 31 2006 P L 107-24 August 3 2001 and August 5 2001 original law In December 2016 P L 114-277 extended the law as is until December 31 2026 P L 107-24 also required an Administration report on ISA’s effectiveness within 24 to 30 months of enactment with the report to include an administration recommendation 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 17 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 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 encourage countries to reduce their purchases of Iranian oil 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 18 Iran Sanctions SREs Ended in May 2019 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 and 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 201932 in order to “apply maximum pressure” on Iran by driving its 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 33 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 However 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 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 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 “U S to warn shippers against storing Iranian oil ” State Department official Reuters March 9 2020 31 Congressional Research Service 19 Iran Sanctions Table 1 Iran Crude Oil Sales average daily volumes in barrels per day Country Bloc 2011 JPA period average 2014-2016 European Union particularly Italy Spain Greece 600 000 negligible 520 000 100 000 UNKNOWN U China 550 000 410 000 700 000 838 000 U Japan 325 000 190 000 133 000 0 U India 320 000 190 000 620 000 354 000 U South Korea 230 000 130 000 100 000 0 U Turkey 200 000 120 000 200 000 161 000 U South Africa 80 000 negligible negligible 0 U Other Asia Malaysia Sri Lanka Indonesia 90 000 negligible negligible Taiwan 35 000 10 000 67 000 0 U Singapore 20 000 negligible negligible 33 000 U 0 negligible 33 000 96 000 U 55 000 negligible 100 000 21 000 U 2 5 1 06 2 45 1 60 05-1 5 est Syria Other Unknown Iraq and UAE swaps other Total mbd At U S JCPOA Exit May ‘18 At SRE Determination Oct ‘18 Sept 2020 post-SRE termination U Explanation and Sources As of November 2020 this report will contain ranges for daily Iranian oil exports Reported figures vary wildly as Iranian tankers have sought to evade U S sanctions through various methods including ship-to-ship transfers and deactivating tanker tracking locator devices Petroleum Intelligence Weekly reported on October 2 2020 that various energy industry sources reported Iran’s daily oil exports for September 2020 to be as low as 50 000 bpd or as high as 1 5 mbd Some figures include and others exclude Iranian exports 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 million 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 the JCPOA Congressional Research Service 20 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 ”34 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 34 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 21 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 menu 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 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 35 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 35 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 22 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 during U S implementation of the JCPOA are in italics 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 and mandates that the same sanctions as provided for in that order 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 requires an Administration report every 180 days on persons contributing to Iran’s ballistic missile program Section 107 mandates the E O 13382 sanctions 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 on arms and missiles have been implemented through additional designations for sanctions SDNs under the executive orders referenced in CAATSA Executive Order 13949 on Sales of Arms September 21 2020 Executive Order 13949 was issued after it became clear that the U N Security Council would not support U S efforts to extend the Resolution 2231 ban on arms transfers to and from Iran which was set to expire on October 18 2020 The order blocks U S property of any entity determined to have “materially contribute d to the supply sale transfer directly or indirectly to or from Iran or for the use in or benefit of Iran of arms or related material including spare parts ” The provision applies to any entity or person determined to have facilitated or financed such as transaction with Iran as well as to persons determined to have helped or financed a person or entity sanctioned under the order The order appeared to largely restate the provisions of CAATSA discussed above although lacking the specific listing of arms that are stipulated by CAATSA The United States considers the U N arms transfer ban to be in effect pursuant to the U S assertion that it triggered a “snapback” of all U N sanctions that existed prior to the JCPOA However the Security Council as a whole opposes the U S position and does not consider the U N sanctions to be back in effect See CRS In Focus IF11429 U N Ban on Iran Arms Transfers and Sanctions Snapback by Kenneth Katzman 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 Congressional Research Service 23 Iran Sanctions 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 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 re-exported 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 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 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 controlled by the IRGC such as the large engineering firm Khatam ol-Anbia  The IRGC has been named as a proliferation-supporting entity under Executive Order 13382 a human rights abuser under E O 13553 and in accordance with the Countering America’s Adversaries through Sanctions Act P L 115-44 it was named a terrorism-supporter under E O 13224 October 13 2017 The IRGCQods Force IRGC-QF the unit of the IRGC that assists pro-Iranian movements abroad is named as a terrorism-supporting entity under Executive Order 13324 and a repressor of the Syrian people under E O 13572 Hundreds of IRGC-linked entities—companies facilitators and financial partners and commanders— are designated for sanctions under those and other orders as noted in the tables at the end of this report  IFCA Section 1244 mandates that any entity that knowingly conducts transactions with a designated Iranian entity is subject to having its U S -based assets blocked  ITRSHRA Section 302 imposes at least 5 out of 12 ISA sanctions on persons that materially assist with financing or technology the IRGC or assist or engage in “significant” transactions with any of its affiliates that are sanctioned under Executive Order 13382 13224 or similar executive orders—or which are determined to be affiliates of the IRGC Section 302 did not amend ISA  ITRSHRA Section 311 requires a certification by a contractor to the U S government that it is not knowingly engaging in a significant transaction with the IRGC or any of its agents or affiliates that have been sanctioned under several executive orders discussed below A contract may be terminated if it is determined that the company’s certification of compliance was false  ITRSHRA Section 301 requires the President to identify “officials agents or affiliates” of the IRGC and to impose sanctions in accordance with Executive Order 13382 or 13224 Some of these designations including of National Iranian Oil Company NIOC were made by the Treasury Department on November 8 2012  ITRSHRA Section 303 requires the imposition of sanctions on agencies of foreign governments that provide technical or financial support or goods and services to sanctioned under U S executive orders or U N resolutions members or affiliates of the IRGC Sanctions include a ban on U S assistance or credits for that foreign government agency a ban on defense sales to it a ban on U S arms sales to it and a ban on exports to it of controlled U S technology Congressional Research Service 24 Iran Sanctions  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 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 transactions with Iran During the effort 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 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 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 As of November 6 2008 the regulations have also barred foreign banks or persons from accessing the U S financial system through a U S correspondent account to acquire dollars for any transaction involving Iran “U-turn transactions” 36 There is no blanket ban on foreign banks or persons paying Iran for goods using U S dollars provided they do not access the U S financial system to replenish their supply of dollars to accomplish their transactions with Iran These regulations 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 36 For text of the OFAC ruling barring U-Turn transactions see https www treasury gov resource-center sanctions Documents fr73_66541 pdf Congressional Research Service 25 Iran Sanctions considered licensing transactions by foreign clearinghouses to acquire dollars that might facilitate transactions with Iran but the Administration did not take that step 37 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 38 The FY2016 Consolidated Appropriation P L 114-113 provided for use of the proceeds of the settlements compensate victims of Iranian terrorism Table 2 Major Settlements Fines Paid by Banks for Violations Bank Date Amount Paid Violation UBS Switzerland 2004 $100 million Unauthorized movement of U S dollars to Iran and others ABN Amro Netherlands December 2005 $80 million Failing to fully report financial transactions involving Bank Melli Credit Suisse Switzerland December 2009 $536 million Illicitly processing Iranian transactions with U S banks ING Netherlands June 2012 $619 million Concealing movement of billions of dollars through the U S financial system for Iranian and Cuban clients Standard Chartered UK August 2012 $340 million Settlement paid to New York State for processing transactions on behalf of Iran Clearstream Luxembourg January 2014 $152 million Helping Iran evade U S banking restrictions Bank of Moscow Russia January 2014 $9 5 million Illicitly allowing Bank Melli to access the U S financial system BNP Paribas June 2014 $9 billion Amount forfeited for helping Iran and Sudan and Cuba violate U S sanction Standard Chartered UK April 2019 $639 million Dubai branch of Standard Chartered processed Iran-related transactions to or through Standard Chartered–New York Unicredit AG Germany Austria Italy April 2019 $1 3 billion For illicitly processing transactions through 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 Washington Institute for Near East Policy “Potential U S Clarification of Financial Sanctions Regulations ” by Katharine Bauer April 5 2016 38 Analyst conversations with U S banking and sanctions experts 2010-2015 37 Congressional Research Service 26 Iran Sanctions 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” cancel existing such accounts for39     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 FTOs 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 during U S implementation of the JCPOA 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 during JCPOA implementation many entities with which transactions would have triggered sanctions under Section 104 were “delisted” as Specially Designated Nationals SDNs as provided by the JCPOA On October 8 2020 in order to more comprehensively shut Iran’s banks out of the international financial system the Administration designated many of Iran’s remaining un-sanctioned banks for sanctions under E O 13902 A general license L was issued concurrently in order to make purely humanitarian transactions with the newly-designated banks permissible 40 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 39 Foreign banks that do not have operations in the United States typically establish correspondent accounts or payablethrough 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 40 Department of the Treasury October 8 2020 Congressional Research Service 27 Iran Sanctions 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 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 to circumvent U S 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 41 Federal Register Finding That the Islamic Republic of Iran Is a Jurisdiction of Primary Money Laundering Concern November 25 2011 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 28 Iran Sanctions “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 nonoil industries and sectors of Iran’s economy The targeted sectors include Iran’s automotive production sector which is Iran’s second-largest industry after energy 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 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 Congressional Research Service 29 Iran Sanctions   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 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 production 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 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 Congressional Research Service 30 Iran Sanctions 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    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 January 10 2020 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 re-melting 46 45 Statement by President Trump Imposing Sanctions on Iron Steel Aluminum and Copper Sectors of Iran May 8 2019 46 Dept of State Findings Pursuant to the Iran Freedom and Counter-Proliferation Act IFCA of 2012 October 31 2019 Congressional Research Service 31 Iran Sanctions 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 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 Congressional Research Service 32 Iran Sanctions visas to enter the United States the State Department interprets the provisions to apply to all members of the designated entity 47 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 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 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 a General License was provided for the provision to Iranians of free mass market software 49 In March 2012 the general license was expanded to include additional types of software and information technology products provided the products were 47 U S Department of the Treasury Office of Public Affairs Treasury Sanctions Iranian Security Forces for Human Rights Abuses June 9 2011 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 Congressional Research Service 33 Iran Sanctions available at no cost to the user 50 The items included personal communications personal data storage browsers plug-ins document readers and free mobile applications related to personal communications On May 30 2013 a further expansion of the General License applied to the cash sale 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 after the June 2009 uprising 2 ceased violence unlawful detention torture and abuse of citizens who engaged in peaceful protest 3 fully investigated abuses of political activists after the 2009 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 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     Executive Order 13846 August 6 2018 The Executive Order that reimposed pre-JCPOA sanctions Iranian human rights abusers and corrupt officials No sanctions imposed for such behaviors 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 The State Department has refused visas for some 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 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 35 Iran Sanctions 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 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 July 20 2015 contained the provisions below 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 Iranian civilian nuclear entities sanctioned under Resolutions 1737 and subsequent resolutions and named in an 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 36 Iran Sanctions   attachment to the Annex were “delisted” on Implementation Day Those not listed on the attachment continue to be sanctioned until Transition Day October 18 2023 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 The Security Council deems the ban to have expired on October 18 2020 as planned a position that the Trump Administration disputes See CRS In Focus IF11429 U N Ban on Iran Arms Transfers and Sanctions Snapback 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 collected and disseminated information on Iranian violations and other entities involved in banned activities A “panel of experts” was empowered by Resolution 1929 to assist the 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 37 Iran Sanctions Iran Compliance Status Until August 2019 U N and International Atomic Energy Agency reports 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 See CRS Report R43333 Iran Nuclear Agreement and U S Exit by Paul K Kerr and Kenneth Katzman 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 mediumrange missile launches as violations of the resolution Iran has not been able to buy major combat systems during the period that the arms transfer ban has been in effect but it repeatedly violated the U N ban on exportation of arms as analyzed in CRS In Focus IF11429 U N Ban on Iran Arms Transfers and Sanctions Snapback by Kenneth Katzman 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 with waivers of Section 1244c 1 of IFCA ITRSHRA and ISA  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 Re-imposition 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 2 financial sector sanctions and 3 sanctions on Iran’s auto sector and trading in the rial The 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 Congressional Research Service 38 Iran Sanctions 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 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 during the period of U S implementation of the JCPOA          Iran Sanctions Act The WMD-related provision of ISA was not waived FY2012 NDAA Section 1245 d sanctioning banks of countries that do not reduce Iran oil imports was waived ITRSHRA Iranian economy provisions waived Human rights-related provisions were not waived IFCA Sections 1244 1245 1246 and 1247 of the act sanctioning transactions with SDNs and with named economic sectors were waived Executive Orders 13574 13590 13622 13645 and Sections 5-7 and 15 of Executive Order 13628 were revoked outright by Executive Order 13716 The core provision of CISADA that sanctions foreign banks was not waived but most listed Iranian banks were “delisted ” Other Iranian economic entities and personalities listed in Attachment III of the JCPOA were delisted 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 all U S sanctions that were eased were reimposed within two “wind down” periods – a 90 day wind down ending on August 6 2018 and a 180 day wind down ending on November 4 2018 Even though it reimposed all U S sanctions on Iran the Trump Administration      initially gave 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 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 these waivers during 2019-2020 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 has issued the permitted IFCA exception for Afghan reconstruction to enable India to continue work at Iran’s Chahbahar Port 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 Congressional Research Service 39 Iran Sanctions 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 Proliferation-related sanctions laws the Iran-Iraq Arms Non-Proliferation Act the Iran-North Korea-Syria Non-Proliferation Act INKSNA 55 and the section of ISA that sanctions WMD- and arms-related transactions with Iran E O 13438 on Iran’s interference in Iraq and E O 13572 on repression in Syria Executive Orders E O 13606 and E O 13628 and the provisions of CISADA ITRSHRA and IFCA that pertain to human rights or democratic change in Iran all sanctions on the IRGC military proliferation-related and human rights- and terrorism-related entities which were not “delisted” from sanctions 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 56 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 ” The Trump Administration asserted that Resolution 2231 allows the United States to trigger the snap-back because it remains legally a “participant” in Resolution The Administration formally triggered the snapback provision and asserted that on September 19 2020 U N sanctions had been re-imposed However the Security Council members overwhelmingly rejected the U S argument and the U N considers U N sanctions still ended The Council also considers the U N ban or arms transfers to and from Iran to have expired as scheduled on October 18 2020 55 The JCPOA committed the United States to terminate sanctions on some entities designated under INKSNA 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 56 Congressional Research Service 40 Iran Sanctions Sanctions Imposed Subsequent to the U S Exit from the JCPOA In a September 13 2020 editorial the presumptive winner of the 2020 election former Vice President Joseph Biden expressed an intent to rejoin the JCPOA if Iran comes back into compliance 57 Rejoining the agreement will in all likelihood require again easing those sanctions that were suspended during the 2016-2018 period of U S implementation of the JCPOA And Iran is almost certain to demand that the additional economic sanctions imposed by the Trump Administration subsequent to 2018 must be eased as well as a condition of Iran’s return to full compliance with the terms of the accord Trump Administration officials say they will continue adding sanctions on Iran as long as the administration is in office 58 The following sanctions will likely be the subject of negotiations on a U S return to JCPOA implementation noting as discussed above that arms and proliferation terrorism-related and human rights-related sanctions were not eased as part of the JCPOA On the other hand the Trump Administration has designated several Iranian economic entities including its Central Bank as terrorism-supporting entities and Iran is likely to demand that any economic entity be “de-listed” from U S sanctions as part of a U S return to the JCPOA 59 A U S return to the JCPOA would likely require “de-listing” not only all the entities de-listed for sanctions in 2016 but also the hundreds of entities listed since the U S exit from the JCPOA and the entities listed under the economy-centric executive orders issued since 2018 And Iran and the United Nations considers the U N ban on arms transfers to and from Iran to have expired on October 18 2020 in accordance with Resolution 2231 60 and it is possible Iran might demand that sanctions related to arms transfers be eased in a revised JCPOA The post-JCPOA sanctions U S sanctions include       The Countering America’s Adversaries through Terrorism Sanctions Act CAATSA Enacted in August 2017 Most provisions focus on arms missiles and human rights and might not necessarily require easing in a revived JCPOA The designation of the IRGC as an FTO April 2019 As noted above no IRGC sanctions were lifted to implement the JCPOA Executive Order 13871 sanctioning Iran’s minerals and metals sector May 2019 Executive Order 13876 sanctioning the office of Iran’s Supreme Leader June 2019 Even though human rights related sanctions were not required to be eased as part of the JCPOA it can be argued that Iranian negotiators will insist on the revocation of this order in negotiations on a revised JCPOA because of the political sensitivity of his position in Iran’s hierarchy Central Bank named as a terrorism entity under E O 13224 September 2019 Because of the centrality of the Central Bank to Iran’s financial system Iran might demand that this designation be revoked Executive Order 13902 sanctioning the construction manufacturing mining and textile sector January 2020 As noted numerous Iranian banks not sanctioned Joseph R Biden editorial “Joe Biden There’s a smarter way to be tough on Iran ” CNN September 13 2020 Secretary of State Michael Pompeo Statement The Importance of Sanctions on Iran November 18 2020 59 “Trump Administration Hopes to Make Iran Pressure Campaign Harder to Reverse ” Wall Street Journal October 23 2020 60 “U S says Iran sanctions back on but the world is ignoring Washington ” CBS News September 21 2020 57 58 Congressional Research Service 41 Iran Sanctions  under other orders were designated for sanctions under this order in October 2020 Executive Order 13949 sanctioning entities that facilitate sales of conventional weaponry to Iran September 2020 U S sanctions on conventional weapons were not required to be eased in implementation of the JCPOA 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 below 61 European Union EU After the passage of Resolution 1929 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 62 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 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 and 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   An embargo on sales to Iran of arms missile technology other proliferationsensitive 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 re-impose sanctions on Iran after the U S withdrawal from the JCPOA many European firms ceased Iran-related transactions or exited the Iran market 63 See CRS Report R44017 Iran’s Foreign and Defense Policies by Kenneth Katzman 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 63 “Iran Nuclear Deal The EU’s Billion-Dollar Deals at Risk ” BBC News May 11 2018 61 62 Congressional Research Service 42 Iran Sanctions        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 In August 2018 Daimler Mercedes Benz announced suspension of business in Iran Scania of Sweden ended an effort to establish a bus factory in Iran 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 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 EuropaischeIranische Handlesbank EIH which is partly owned by Iran 64 Energy No EU state is known to have bought Iranian oil since U S energy sanctions went back into effect in November 2018 Total SA of France 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 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 65 European Special Purpose Vehicle INSTEX The EU countries continue to support the JCPOA while assailing Tehran’s violations of its nuclear commitments—despite 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 re-imposed 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 66 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 Germany’s Central Bank Imposes Rule to Stop Cash Delivery to Tehran Jerusalem Post August 6 2018 “U S Grants BP Serica License to Run Iran-Owned North Sea Field ” Reuters October 9 2018 66 Joint Statement on the New Mechanism to Facilitate Trade with Iran January 31 2019 64 65 Congressional Research Service 43 Iran Sanctions 2020 On March 31 2020 INSTEX completed its first transaction—for about $540 000 worth of medical equipment 67 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 did not advance 68 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 and Italy have denied landing rights to Iran’s Mahan Air which the United States has designated as a terrorism-supporting entity SWIFT Electronic Payments System The management of the Brussels-based Swift electronic payments system has sought to balance financial risks with the policies of the EU governments In March 2012 SWIFT acceded to an EU request to expel 14 EU-sanctioned Iranian banks 69 Some Iranian banks were still able to conduct electronic transactions with the European Central Bank via the “Target II” system Even though the EU has not re-imposed 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 are designated 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 help Iran circumvent U S sanctions 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 by reducing 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 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 currencydenominated payments from Iran 70 A state-owned China firm CNPC withdrew from a major phase of Iran’s South Pars gas field perhaps to avoid U S sanctions “EU Ramps up Trade System with Iran despite U S Threats ” Wall Street Journal March 31 2020 “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 69 Avi Jorish “Despite Sanctions Iran’s Money Flow Continues ” Wall Street Journal June 25 2013 70 “As U S Sanctions Loom China’s Bank of Kunlun to Stop Receiving Iran Payments—Sources ” Reuters October 67 68 Congressional Research Service 44 Iran Sanctions Since mid-2019 the Administration has sanctioned numerous Chinese economic entities for transactions with Iran 71 On July 23 2019 the Administration sanctioned under IFCA a small Chinese firm Zhuhai Zhenrong Company Ltd for buying oil from Iran 72 Prior to the expiration of the SREs China had stockpiled 20 million barrels of Iranian oil at its Dalian port 73 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 74 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 75 China and Iran reportedly have finalized or nearly finalized the agreement which might include arms sales to Iran and other strategic ties and including China’s purchases of Iranian oil at discounted prices 76 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 However both countries—and their companies—have historically been unwilling to undertake transactions with Iran that could violate U S sanctions and both ended their Iranian oil purchases after their SREs were ended 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 77 Iran reportedly has sued South Korean banks for refusing to release Iran’s funds to buy humanitarian items there Other East Asian Countries North Korea like Iran has been subject to significant international sanctions and North Korea has not pledged to abide by international sanctions against Iran The two countries reportedly share information on a wide range of strategic ventures particularly the development of ballistic 23 2018 71 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 72 “The United States to Impose Sanctions on Chinese Firm Zhuhai Zhenrong Company Limited for Purchasing Oil from Iran Department of State July 22 2019 73 “Boxed In $1 billion of Iranian Crude Sits at China’s Dalian Port ” Reuters May 1 2019 74 Thomas Erdbrink “China’s Push to Link East and West Puts Iran at ‘Center of Everything ’” New York Times July 25 2017 75 “China and Iran Flesh out Strategic Partnership ” Petroleum Economist September 3 2019 76 “Defying U S China and Iran near Trade and Military Partnership ” New York Times July 11 2020 77 Author conversations with South Korean officials January-December 2019 Congressional Research Service 45 Iran Sanctions 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 78 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 India paid Iran the $6 5 billion it owed for oil purchased during 2012-2016 79 India has not imported Iranian oil since its SRE ended in May 2019 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 nonperformance of contracts to exclude the country from further work on the railway at the port 80 In October 2020 Iran excluded India ONGC Videsh from the development of Farzad-B gas field in the Persian Gulf for its failure to move forward on the project 81 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 data Turkey also buys natural gas from Iran via a pipeline built in 1997 which at first was used for a swap “The Military Relationship between Iran and North Korea ” Inside Sources January 27 2020 “India Seeks to Pay $6 5 Billion to Iran for Oil Imports ” Economic Times of India May 16 2016 80 “Iran drops India from Chabahar rail project cites funding delay ” The Hindu July 14 2020 81 “India loses giant gas field in Iran – even though 3 Indian companies discovered the field ” Oil and Gas 360 October 21 2020 78 79 Congressional Research Service 46 Iran Sanctions arrangement under which gas from Turkmenistan was exported to Turkey Direct Iranian gas exports to Turkey through the line began in 2001 82 No ISA sanctions were imposed on the pipeline on the grounds that the gas supplies were crucial to Turkey’s energy security There have been some indications that banks in Turkey including Halkbank have continued to allow Iran to obtain hard currency including in the form of gold in return for Iranian currency oil and other commodities U S prosecutions have occurred against Halkbank and various individuals for alleged violations of U S sanctions on Iran 83 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 but they all maintain relatively normal trade with Iran The UAE has a large presence of Iranian firms and several UAE-based firms have been sanctioned by the United States including for facilitating Iranian oil and petrochemicals exports 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 the 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 84 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 “Iran Clears 40% of Gas Fine to Turkey ” Financial Tribune June 13 2017 Department of Justice Turkish Bank Charged In Manhattan Federal Court For Its Participation In A MultibillionDollar Iranian Sanctions Evasion Scheme October 15 2019 84 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 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 83 Congressional Research Service 47 Iran Sanctions has limited the waiver to shorter increments and requires that the funds due to Iran are held in escrow at Iraq’s Trade Bank 85 However in October 2020 Iraq and Iran reached an agreement under which Iran would access the funds in escrow to purchase food and medical goods in Iraq 86 Syria and Lebanon Iran has extensive economic relations with and political influence in both Syria and Lebanon 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 The Trump Administration has sanctioned some Lebanese banks and Lebanese politicians for supporting Hezbollah and Iran 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 87 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 88 In July 2019 Gibraltar diverted an Iranian tanker delivering oil to 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 89 The United States subsequently took legal action to impound those four shipments Additional shipments reportedly arrived in September 2020 90 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 91 85 Department of State Waiver Transmittal Letter April 27 2020 Iranian official says Iraq agrees to release Iran’s frozen assets Xinhua October 13 2020 87 “Pompeo We are trying to prevent Iran from selling crude oil to Hezbollah ” Arab News July 9 2020 88 Iran Signs Phone Gas Deals with Syria Agence France Presse January 17 2017 89 Comments by Ambassador Brian Hook at Hudson Institute Seminar on Iran-Venezuela relations July 10 2020 90 “Venezuela and Iran continue to defy U S oil sanctions with new shipments ” World Oil September 28 2020 91 “Pompeo Reiterates US Opposition To IMF Loan For Iran ” Radio Farda April 15 2020 86 Congressional Research Service 48 Iran Sanctions 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 have “worked ”92although it is arguable that Iran’s policies and behavior have not changed dramatically The following sections assess the effectiveness of Iran sanctions according to a number of criteria Effect on Iran’s Nuclear Program and Strategic Capabilities The international sanctions regime of 2011-2015 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 Trump Administration insisting that the United States provide JCPOA sanctions relief as a precondition to talks 93 Still even though sanctions during 2011-2015 might have made Iranian leaders more willing to negotiate nuclear limits sanctions did not prevent Iran from advancing its nuclear program during that time or since 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 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 expired on October 18 2020 according to the U N Security Council U S intelligence directors have testified that Iran continues to develop its own increasingly advanced naval mines submarines and attack craft 94 “U S envoy says Iran sanctions working warns against nuclear breaches ” Reuters June 27 2019 “Iran says pandemic will not force talks with the US ” Al Monitor April 20 2020 94 Worldwide Threat Assessment of the U S Intelligence Community January 29 2019 92 93 Congressional Research Service 49 Iran Sanctions 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 20112015 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 95 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 96 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 97 On October 16 2019 the State Department Special 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 98 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 Iranian 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 95 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 96 “Sanctions on Iran are Hitting Hezbollah ” Washington Post May 19 2019 97 Statement from the President on the Reimposition of United States Sanctions with Respect to Iran August 6 2018 98 Testimony of Special Representative Brian Hook Senate Foreign Relations Committee October 16 2019 Congressional Research Service 50 Iran Sanctions 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 elections99 and many of the potentially strong candidates in the June 2021 presidential election apparently are hardliners to varying degrees Economic Effects There is little dispute that U S sanctions imposed 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 relief enabled Iran to achieve 7% annual growth during 2016-2018 100 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 101 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 down significantly See oil export chart earlier in this report 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 exited again or limited their transactions with Iran after the U S re-imposed 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 stood at about $115 billion 102 Iran was able to access the funds during 2016-2018 but Iran’s foreign reserves again became restricted by reimposed U S sanctions in 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 103 “Iran’s Hardliners Win Election by Large Margin Mehr Says ” Bloomberg News February 23 2020 “Foreign Investors Flock to Iran as U S Firms Watch on the Sidelines ” Wall Street Journal March 27 2017 101 The World Bank Islamic Republic of Iran economy overview and outlook May 1 2020 102 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 103 “Iran Cut Off From Vital Cash Reserves Faces Deeper Economic Peril U S Says ” Wall Street Journal December 3 2019 99 100 Congressional Research Service 51 Iran Sanctions     Currency Decline During the period of U S JCPOA implementation 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 in September 2020 to about 265 000 to the dollar 104 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 as of 2019 according to Iran’s Central Bank governor 105 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 106 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 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 Iran has promoted sales of petrochemicals and nonoil products and they constitute a steadily growing percentage of Iran’s revenue 107 Iran’s March 2020-2021 budget assumes that Iran will earn minimal oil revenues 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 108 Rouhani has sought to push the IRGC out of Iran’s economy through divestment but with limited success “Iran’s rial hits new low against dollar as economy reels ” Reuters September 15 2020 Ibid 106 Figures in this paragraph is from the U S Census Bureau Foreign Trade Statistics database 107 Testimony of Patrick Clawson before the Senate Banking Committee January 21 2015 108 “How Trump’s terrorist designation of Iran’s revolutionary guard impacts its economy ” CNBC April 12 2019 104 105 Congressional Research Service 52 Iran Sanctions  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 109 Figure 1 Economic Indicators Sources IMF 2019 U S Energy Information Administration OPEC Effect on Energy Sector Development Since 2011 there has been little foreign-led development activity at Iran’s various oil and gas development sites many foreign investors have 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 its “Iran Petroleum Contract ”110 Some new development agreements were signed but as noted above major energy firms divested again in response to the U S exit from the JCPOA 109 110 Patrick Clawson testimony January 21 2015 op cit Thomas Erdbrink “New Iran Battle Brews over Foreign Oil Titans ” New York Times February 1 2016 Congressional Research Service 53 Iran Sanctions 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 slowed Iran’s efforts to develop a liquefied natural gas LNG export business 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 virtually no improvement in Iran’s practices in recent years 111 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 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 112 Other reports in 2019 indicated that global food traders halted supplying Iran because of the absence of trade financing 113or 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 114 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 COVID19 pandemic and in the process perhaps parry calls to broadly ease sanctions on Iran 115  In January 2020 before the COVID-19 spread 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 111 Department of State 2019 Country Reports on Human Rights Released in 2020 “Trump’s Sanctions Are Proving a Bitter Pill for Iran’s Sick ” Bloomberg News November 20 2018 113 “Global Traders Halt New Iran Food Deals as U S Sanctions Bite ” Reuters December 21 2018 114 State Department Iran’s Sanctions Relief Scam April 6 2020 115 For further analysis see CRS Insight IN11279 COVID-19 and U S Iran Policy by Kenneth Katzman 112 Congressional Research Service 54 Iran Sanctions    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 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 has apparently prevailed on other members of the IMF executive board to deny Iran the requested $5 billion loan for its COVID-19 response Some Members of Congress have called on the Administration to support it 116 The IMF has not announced a loan decision 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 before U S sanctions again took effect Post-JCPOA Sanctions Legislation JCPOA oversight and implications have been the subject of legislation 116 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 55 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 re-imposed 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 The Trump Administration has not made any of the required certification reports under the law since ceasing U S participation in the JCPOA in May 2018 It is not clear whether an administration of the presumptive winner of the 2020 election former Vice President Joseph Biden would resume implementing all provisions of the INARA law if it were to accomplish its stated intent to rejoin the JCPOA or whether negotiated modifications to the JCPOA would affect a resumption of INARA implementation     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 requires the 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 No certification reports have been issued since the Trump Administration took the United States out of the JCPOA in May 2018 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 requires an Administration report every 180 days on Iran’s nuclear program including not only Iran’s compliance with its nuclear commitments but also whether Iranian banks are involved in terrorism financing Iran’s ballistic missile advances and whether Iran 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 Congressional Research Service 56 Iran Sanctions 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 the Senate by 99-0 President Obama allowed the bill to become law without signing it P L 114277 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 Some of the 114th Congress Legislation that was not Enacted      Sanctions designations The IRGC Terrorist Designation Act H R 3646 S 2094 required a report on whether the IRGC should be designated 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 nonstate groups The IRGC Sanctions Act H R 4257 would have required certification that any entity to be “delisted” from sanctions is not a member agent affiliate or owned by the IRGC 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 Financial Transactions H R 4992 which passed the House on July 14 2016 by a vote of 246-181would require foreign financial institutions to obtain a license for dollar transactions with Iran H R 3728 would amend ITRSHRA to make mandatory sanctions against electronic payments systems such as SWIFT if they were used by Iran Proliferation The Iran Ballistic Missile Sanctions Act of 2016 S 2725 would have required that several major Iranian economic sectors 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 passed the House on July 14 2016 by a vote of 246-179 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 117 Several bills and amendments in the 114th Congress sought to block financing for the sale of the Boeing aircraft to Iran H R 5715 H R 5711 and sections of the FY2017 Financial Services and General Government Appropriations Act H R 117 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 57 Iran Sanctions 5485 H R 5711 passed by the House on November 17 2016 by a vote of 243174 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 A Senate bill S 722 which initially contained only Iran-related sanctions was reported out by the Senate Foreign Relations Committee after incorporating sanctions on Russia 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 and its implementation are discussed above Section 108 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 Major Legislation in the 115th Congress that was not Enacted    H R 1638 In November 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 The Committee also reported H R 4324 Strengthening Oversight of Iran’s Access to Finance Act requiring Administration reports on whether financing of Iranian commercial aircraft purchases posed money-laundering proliferation or terrorism risks 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 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  Several bills would impose sanctions on Iranian proxies in Iraq and elsewhere These include H R 361 the Iranian Proxies Terrorist Sanctions Act of 2019 and H R 571 the Preventing Destabilization of Iraq Act of 2019 Congressional Research Service 58 Iran Sanctions     The Iranian Revolutionary Guard Corps Exclusion Act S 925 similar to H R 5132 in the 115th Congress see above 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 Sanctions118 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 118 See CRS In Focus IF10801 Possible Additional Sanctions on Iran by Kenneth Katzman Congressional Research Service 59 Iran Sanctions Appendix A U S U N EU and Allied Country Sanctions U S Sanctions U N Sanctions EU and Other Allied Countries General Observation Most sweeping sanctions on Iran of virtually any country in the world As of 2010 U N sanctions were intended to give countries justification to cooperate with U S secondary sanctions Post-JCPOA Resolution 2231 is the only operative Resolution on Iran Note In October 2020 the Trump Administration triggered the “snapback” of U N sanctions but the Security Council and broader United Nations does not recognize and has not implemented the snapback EU closely aligned its sanctions tightening with that of the United States Most EU sanctions lifted in accordance with the JCPOA although some sanctions on arms dual-use items and human rights remain Japan and South Korea sanctions became extensive but were almost entirely lifted in concert with the JCPOA Ban on U S Trade with Investment in and Financing for Iran Executive Order 12959 and CISAD ban U S firms from exporting to Iran importing from Iran or investing in Iran U N sanctions did not ban civilian trade with Iran or general civilian sector investment in Iran No comprehensive EU ban on trade in civilian goods with Iran was imposed at any time Japan and South Korea did not ban normal civilian trade with Iran Sanctions on Foreign Firms that Do Business with Iran’s Energy Sector Several laws and orders mandate sanctions on virtually any type of transaction with in Iran’s energy sector No U N equivalent However Resolution 1929 “not es the potential connection between Iran’s revenues derived from its energy sector and the funding of Iran’s proliferation-sensitive nuclear activities ” This is interpreted as providing U N support for countries to impose economic sanctions on Iran The EU banned almost all dealings with Iran’s energy sector after 2011 These sanctions now lifted but no oil imports from Iran since 2018 Japanese and South Korean measures banned new energy projects in Iran These sanctions now lifted but no Iranian oil being imported by either Ban on Foreign Assistance U S foreign assistance to Iran— other than purely humanitarian aid—is banned under §620A of the Foreign Assistance Act Iran is also routinely denied direct U S foreign aid under the annual foreign operations appropriations acts No U N equivalent EU measures of July 2010 banned grants aid and concessional loans to Iran and financing of enterprises involved in Iran’s energy sector These sanctions now lifted Japan and South Korea did not ban aid or lending to Iran Ban on Arms Exports to Iran Iran is ineligible for U S arms exports under several laws as discussed in the report As per Resolution 1929 paragraph 8 as superseded by Resolution 2231 Security Council approval is required to sell Iran major weapons systems U N Security Council as a whole deems ban to have expired as scheduled on October 18 2020 EU policy bans sale to Iran of all types of military equipment regardless of U N resolutions Japan and South Korean do not export arms to Iran Congressional Research Service 60 Iran Sanctions U S Sanctions U N Sanctions EU and Other Allied Countries Restriction on Exports to Iran of “Dual Use Items” Primarily under §6 j of the Export Administration Act P L 96-72 and §38 of the Arms Export Control Act there is a denial of license applications to sell Iran goods that could have military applications U N resolutions on Iran banned the export of many dual-use items to Iran Resolution 2231 set up a procurement network for the P5 1 to approve of all purchases for Iran’s ongoing nuclear program EU bans the sale to Iran of dual use items to Iran including ballistic missile technology in line with U N resolutions Japan and S Korea have announced full adherence to strict export control regimes Sanctions Against Lending to Iran Under §1621 of the International Financial Institutions Act P L 95118 U S representatives to international financial institutions such as the World Bank are required to vote against loans to Iran by those institutions Resolution 1747 paragraph 7 requested but did not mandate that countries and international financial institutions refrain from making grants or loans to Iran except for development and humanitarian purposes The July 2010 measures prohibited EU members from providing grants aid and concessional loans to Iran including through international financial institutions Sanctions lifted post-JCPOA Japan and South Korea banned medium- and long-term trade financing and financing guarantees Short-term credit was still allowed These lifted post-JCPOA Sanctions Against the Sale of Weapons of Mass DestructionRelated Technology to Iran Several laws and regulations provide for sanctions against entities Iranian or otherwise that are determined to be involved in or supplying Iran’s WMD programs asset freezing ban on transaction with the entity Resolution 1737 oper paragraph 12 imposed a worldwide freeze on the assets and property of Iranian WMD-related entities named in an Annex to the resolution Each subsequent resolution expanded the list of Iranian entities subject to these sanctions The EU measures imposed July 27 2010 commit the EU to freezing the assets of WMD-related entities named in the U N resolutions as well as numerous other named Iranian entities Most of these restrictions remain Japan and South Korea froze assets of U N -sanctioned entities Most of these restrictions have been lifted Ban on Transactions with Terrorism Supporting Entities FTO and E O 13224 designations ban transactions with entities determined by the Administration to be supporting terrorism Numerous entities including some of Iranian origin have been designated No direct equivalent but Resolution 1747 oper paragraph 5 bans Iran from exporting any arms Resolution 2231 continued that restriction until October 18 2020 No direct equivalent but many of the Iranian entities named as blocked by the EU Japan and South Korea overlap or complement Iranian entities named by the United States Human Rights Sanctions U S laws prohibi travel to the U S blocking of U S -based property and ban on transactions with Iranians determined to be involved in serious human rights abuses or who sell Iran equipment to commit such abuses No U N sanctions were imposed on Iran for terrorism or human rights abuses The EU retains a ban on providing equipment that can be used for internal repression and has sanctioned nearly 100 Iranians for human rights abuses Japan and South Korea sanction named Iranians involved in WMD programs Congressional Research Service No longer applicable 61 Iran Sanctions EU and Other Allied Countries U S Sanctions U N Sanctions Restrictions on Iranian Shipping Under Executive Order 13382 the U S Department of the Treasury has named Islamic Republic of Iran Shipping Lines and several affiliated entities as entities whose U S -based property is to be frozen Resolution 1803 and 1929 authorize countries to inspect cargoes carried by Iran Air and Islamic Republic of Iran Shipping Lines IRISL —or any ships in national or international waters—if there is an indication that the shipments include goods whose export to Iran is banned These resolutions no longer apply The July 2010 EU measures banned Iran Air Cargo from access to EU airports and froze the EU-based assets of IRISL and its affiliates Insurance and reinsurance for Iranian firms are banned These sanctions were lifted with JCPOA Japan and South Korean measures took similar action against IRISL and Iran Air Sanctions now lifted Banking Sanctions Iranian banks have been named as proliferation or terrorism supporting entities under Executive Orders 13382 and 13224 and CISADA prohibits banking relationships with U S banks for any foreign bank that conducts transactions with Iran’s Revolutionary Guard or with sanctioned Iranian entities FY2012 Defense Authorization P L 112-81 prevents U S accounts with foreign banks that process transactions with Iran’s Central Bank with specified exemptions No direct equivalent However two Iranian banks were named as sanctioned entities under the U N Security Council resolutions U N restrictions on Iranian banking now lifted The EU froze Iran Central Bank assets January 23 2012 and banned all transactions with Iranian banks unless authorized on October 15 2012 Brussels-based SWIFT expelled sanctioned Iranian banks from the electronic payment transfer system This restriction was lifted but then reimposed when the U S left the JCPOA South Korea imposed the 40 000 Euro threshhold requiring authorization Japan and S Korea froze the assets of Iranian banks These sanctions lifted with JCPOA Ballistic Missiles U S proliferations laws provide for sanctions against foreign entities that help Iran with its nuclear and ballistic missile programs Resolution 2231 “calls on” Iran not to develop or launch ballistic missiles designed to be capable of carrying a nuclear weapon Expires October 18 2023 EU measures of July 2010 required adherence to this provision of Resolution 1929 EU has retained ban on providing ballistic missile technology to Iran in post-JCPOA period Congressional Research Service 62 Iran Sanctions Appendix B Post-1999 Major Investments in Iran’s Energy Sector Date Field Project Company ies Stat us If Known Value Output Goal Feb 1999 Doroud oil Total and ENI received “special rule” ISA exemption Total France ENI Italy $1 billion 205 000 bpd Apr 1999 Dec May 2016 Balal oil Initial development completed in 2004 Dec 2016 Thailand PTTEP signed agreement with NIOC to study further development Total Bow Valley Canada ENI Thailand PTTEP $300 million 40 000 bpd Nov 1999 Soroush and Nowruz oil Royal Dutch received special rule ISA exemption Royal Dutch Shell Netherlands Japex Japan $800 million 190 000 bpd Apr 2000 Anaran bloc oil Lukoil and Statoil invested in 2000 but abandoned work in 2009 Lukoil considering returning Lukoil Russia and Statoil Norway $105 million 65 000 Jul 2000 South Pars Phases 4 and 5 gas On stream in 2005 ENI given special rule exemption ENI $1 9 billion 2 billion cu ft day cfd Mar 2001 Caspian Sea oil exploration—construction of submersible drilling rig for Iranian partner GVA Consultants Sweden $225 million NA Jun 2001 Darkhovin oil ENI exited in 2013 and doing so enabled the firm to be exempted from U S sanctions ENI Field in production $1 billion 100 000 bpd May 2002 Masjid-e-Soleyman oil Sheer Energy Canada CNPC China Naftgaran Engineering Iran $80 million 25 000 bpd Sept 2002 South Pars Phases 9 and 10 gas On stream as of early 2009 GS Engineering and Construction Corp South Korea $1 6 billion 2 billion cfd Oct 2002 South Pars Phases 6 7 and 8 Field began producing late 2008 operational control handed to NIOC in 2009 Statoil got special rule Statoil Norway $750 million 3 billion cfd Jan 2004 Dec 2016 Azadegan oil —South and North Inpex Japan sold stake in 2010 CNPC China —N Azadegan operator vice Inpex Royal Dutch Shell Petronas Malaysia —MoU to develop S Azadegan CNPC—N Azadegan $200 million Inpex stake China $2 5 billion 260 000 bpd of which 80 000 is from N Azadegan Jan 2004 Tusan Block Oil found in block in Feb 2009 but not in commercial quantity according to the firm Petrobras Brazil $178 million Oct 2004 Yadavaran oil Sinopec China deal finalized Dec 9 2007 $2 billion Congressional Research Service 300 000 bpd 63 Iran Sanctions Date Field Project Company ies Stat us If Known Value Output Goal 2005 Saveh bloc oil GAO report cited below PTT Thailand Jun 2006 Garmsar bloc oil Deal finalized in June 2009 Sinopec China $20 million Jul 2006 Arak Refinery expansion Sinopec China JGC Japan Work continued by Hyundai Heavy Industries S Korea $959 million major initial expansion Expansion to produce 250 000 bpd Sept 2006 Khorramabad block oil Seismic data gathered but no production is planned Statoil factsheet May 2011 Norsk Hydro and Statoil Norway $49 million no estimates Dec 2006 North Pars Gas Field offshore gas Includes gas purchases Work suspended in 2011 resumed 2016 but current status of work unclear China National Offshore Oil Co $16 billion 3 6 billion cfd Feb 2007 LNG Tanks at Tombak Port Contract to build three LNG tanks at Tombak 30 miles north of Assaluyeh Port Daelim S Korea $320 million 200 000 ton capacity Feb 2007 South Pars Phases 13 and 14 Deadline to finalize May 2009 not met firms 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 Royal Dutch Shell Repsol Spain $4 3 billion Mar 2007 Esfahan refinery upgrade Daelim S Korea Jul 2007 S Pars Phases 22 23 and 24 Pipeline to transport Iranian gas to Turkey and on to Europe and building three power plants in Iran Turkish Petroleum Company TPAO $12 billion 2 billion cfd Dec 2007 Golshan and Ferdowsi onshore and offshore gas and oil fields and LNG plant Contract modified but reaffirmed December 2008 GAO reports Oil Daily January 14 2008 Petrofield Subsidiary of SKS Ventures Malaysia $15 billion 3 4 billion cfd of gas 250 000 bpd of oil Belarusneft Belarus under contract to Naftiran No production to date $500 million 40 000 bpd 2007 Jofeir Field oil GAO report cited below Belarusneft a subsidiary of Belneftekhim sanctioned under ISA on March 29 2011 Naftiran sanctioned on September 29 2010 NA 2008 Dayyer Bloc Persian Gulf offshore oil GAO reports Edison Italy $44 million Feb 2008 Lavan field offshore natural gas PGNiG Polish Oil and Gas Company Poland divested to Iranian firms in 2011 $2 billion Mar 2008 Danan Field on-shore oil “PVEP Wins Bid to Develop Danan Field ” Iran Press TV March 11 2008 Petro Vietnam Exploration and Production Co Vietnam Congressional Research Service 64 Iran Sanctions Date Field Project Company ies Stat us If Known Value Apr 2008 Iran’s Kish Gas Field Includes pipeline from Iran to Oman Oman cofinancing of project $7 billion Apr 2008 Moghan 2 onshore oil and gas Ardebil province INA Croatia but firm withdrew in 2014 $40-$140 million 2008 Kermanshah petrochemical plant new construction GAO reports Uhde Germany Jun 2008 Resalat Oilfield Status of work unclear Amona Malaysia Joined in June 2009 by CNOOC and another China firm COSL Jan 2009 Bushehr Polymer Plants Production of polyethelene at two polymer plants in Bushehr Province Product exported Sasol South Africa but firm withdrew in 2014 Mar 2009 Phase 12 South Pars gas —Incl LNG terminal construction and Farsi Block gas field Farzad-B bloc Oil and Natural Gas Corp of India ONGC Oil India Ltd India Oil Corp Ltd with Sonanagol Angola and PDVSA Venezuela $8 billion Iran expelled Indian firms from the field development in October 2020 for nonperformance of contract Output Goal 1 billion cfd 300 000 metric tons yr $1 5 billion 47 000 bpd Capacity is 1 million tons per year 20 million tonnes of LNG annually by 2012 Aug 2009 Abadan refinery Upgrade and expansion building a new refinery at Hormuz on the Persian Gulf coast Sinopec Up to $6 billion if new refinery is built Oct 2009 South Pars Gas Field—Phases 6-8 Gas Sweetening Plant Contract signed but abrogated by S Korean firm G and S Engineering and Construction South Korea $1 4 billion Nov 2009 South Pars Phase 12—Part 2 and Part 3 Daelim S Korea — Part 2 Tecnimont Italy —Part 3 $4 billion $2 bn each part Feb 2010 July 2017 South Pars Phase 11 Awarded to CNPC in 2010 but in July 2017 Total took over as operator with CNPC as minority partner 30% In November 2018 Total exited and CNPC became operator CNPC exited in Oct 2019 CNPC China with Iran Petropars $4 7 billion 1 8 billion cu ft day 2011 Azar Gas Field Iran later cancelled Gazprom’s contract due to Gazprom’s failure to fulfill its commitments Gazprom Russia Dec 2011 Zagheh Oil Field Preliminary deal signed December 2011 Tatneft Russia $1 billion 55 000 barrels per day Jul 2016 Aban Oil Field Zarubezhneft signed a MoU to assess the field Zarubezhneft Russia Jul 2016 Paydar Garb Oil Field Zarubezhneft signed a MoU to assess the field Zarubezhneft Russia Congressional Research Service 65 Iran Sanctions Date Field Project Company ies Stat us If Known Nov 2016 Parsi and Rag E-Sefid Schlumberger signed a MoU to assess the fields Schlumberger France Nov 2016 Sumar Oil Field PGNiG signed MoU to assess the field for six months PGNiG Poland Nov 2016 Karanj International Pergas Consortium signed a MoU to assess this field Pergas consortium of firms from Norway Britain and Iran Dec 2016 Changuleh Oil Field Companies signed MoU’s to assess field Gazprom Russia PTTEP Thailand and DNO Norway Dec 2016 Kish Gas Field Royal Dutch Shell signed MoU to assess the field Royal Dutch Shell Dec 2016 Chesmekosh Gas Field Gazprom signed MoU to assess the field Gazprom Russia and Petronas Malaysia Mar 2017 Shadegan Oil Field Khuzestan province producing about 65 000 bpd Tatneft Russia Value Output Goal 500 000 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 66 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 program - Defense Industries Organization DIO - 7th of Tir DOI subordinate - Shahid Hemmat Industrial Group SHIG —missile program - Shahid Bagheri Industrial Group SBIG —missile program - Fajr Industrial Group—missile program - Gen Mohammad Mehdi Nejad Mouri Malak Ashtar University of Defense Technology rector - Bahmanyar Morteza Bahmanyar AIO official - Reza Gholi Esmaeli AOI official - Ahmad Vahid Dastjerdi Head of AOI - Maj Gen Yahya Rahim Safavi Commander in Chief IRGC - Gen Hosein Salimi Commander IRGC Air Force - Atomic Energy Organization of Iran AEIO - Mesbah Energy Company Arak supplier - Mohammad Qanadi AEIO Vice President - Behman Asgarpour Arak manager - Ehsan Monajemi Natanz manager - Jafar Mohammadi Adviser to AEIO - Dawood Agha Jani Natanz official - Ali Hajinia Leilabadi Director of Mesbah Energy Entities Persons Added by Resolution 1747 resolution no longer active - Ammunition and Metallurgy Industries Group controls 7th of Tir - Parchin Chemical Industries branch of DIO - Sanam Industrial Group subordinate to AIO - Ya Mahdi Industries Group - Sho’a Aviation produces IRGC light aircraft for asymmetric warfare - Qods Aeronautics Industries produces UAV’s para-gliders for IRGC asymmetric warfare - Pars Aviation Services Company maintains IRGC Air Force equipment - Gen Mohammad Baqr Zolqadr IRGC officer and deputy Interior Minister - Brig Gen Mohammad Hejazi Basij commander - Brig Gen Qasem Soleimani Qods Force commander - Fereidoun Abbasi-Davani senior defense scientist - Mohasen Fakrizadeh-Mahabai defense scientist - Mohsen Hojati head of Fajr Industrial Group - Ahmad Derakshandeh head of Bank Sepah - Brig Gen Mohammad Reza Zahedi IRGC ground forces commander - Naser Maleki head of SHIG Brig Gen Morteza Reza’i Deputy commander-in-chief IRGC - Vice Admiral Ali Akbar Ahmadiyan chief of IRGC Joint Staff - Karaj Nuclear Research Center - Novin Energy Company Cruise Missile Industry Group - Kavoshyar Company subsidiary of AEIO - Bank Sepah and Bank Sepah International PLC funds AIO and subordinate entities in missile activities - Esfahan Nuclear Fuel Research and Production Center and Esfahan Nuclear Technology Center - Seyed Jaber Safdari Natanz manager - Amir Rahimi head of Esfahan nuclear facilities Mehrdada Akhlaghi Ketabachi head of SBIG 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 67 Iran Sanctions Entities Added by Resolution 1803 resolution no longer active Requires that countries report when the following persons enter or transit their territories - Amir Moayyed Alai centrifuge program management - Mohammad Fedai Ashiani Natanz complex technician - Abbas Rezaee Ashtiani senior AEIO official - Haleh Bakhtiar - Morteza Behzad centrifuge component production - Mohammad Eslami Defense Industries Training and Research Institute - Seyyed Hussein Hosseini AEIO involved in Arak - M Javad Karimi Sabet head of Novin Energy - Hamid-Reza Mohajerani manager at Esfahan uranium conversion facility - Brig Gen Mohammad Reza Naqdi military official for trying to circumvent U N sanctions - Houshang Nobari Natanz - Abbas Rashidi Natanz - 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 - Abzar Boresh Kaveh Co centrifuge production - Barzaganin Tejaral Tavanmad Saccal - Jabber Ibn Hayan AEIO laboratory - Khorasan Metallurgy Industries - Niru Battery Manufacturing Co Makes batteries for Iranian military and missile systems - Ettehad Technical Group AIO front co - Industrial Factories of Precision - Joza Industrial Co - Pishgam Pioneer Energy Industries -Tamas Co uranium enrichment - Safety Equipment Procurement AIO front missiles 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 Industries Group - Defense Technology and Science Research Center owned or controlled by Ministry of Defense - Doostan International Company - Farasakht Industries - First East Export Bank PLC - Kaveh Cutting Tools Company - M Babaie Industries -Shahid Karrazi Industries - Malek Ashtar University subordinate of Defense Technology and Science Research Center above - Ministry of Defense Logistics Export sells Iranian made arms to customers worldwide - Mizan Machinery Manufacturing - Pejman Industrial Services Corp - Sabalan Company Sahand Aluminum Parts Industrial Company - Shahid Sattari Industries -Shahid Sayyade Shirazi Industries acts on behalf of the DIO -Special Industries Group DIO subordinate -Tiz Pars cover name for SHIG -Yazd Metallurgy Industries - Modern Industries Technique Company - Nuclear Research Center for Agriculture and Medicine research component of the AEIO The following IRGC-affiliated firms several are subsidiaries of Khatam ol-Anbiya the main Guard construction affiliate - Fater Institute - Garaghe Sazendegi Ghaem - Gorb Karbala - Gorb Nooh - Hara Company - Sepasad Engineering Company - Imensazan Consultant Engineers Institute - Khatam ol-Anbiya - Makin - Omran Sahel - Oriental Oil Kish - Rah Sahel - Rahab Engineering Institute - Sahel Consultant Engineers - Sepanir The following entities determined to be owned or controlled by Islamic Republic of Iran Shipping Lines IRISL Irano Hind Shipping Company IRISL Benelux and South Shipping Line Iran European Union Iran Designations Terrorism-related Hamid Abdollahi Mansoor Arbabsiar—for alleged plot to assassinate Saudi Ambasador in Washington Asadollah 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 68 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 Hezbollah Military Wing Palestinian Islamic Jihad Human-Rights Related 87 persons mostly IRGC Basij Law Enforcement Forces commanders as well as security militia chiefs such as Hossein Allahkaram of Ansar-e-Hezbollah List also includes judicial officials such as Seyeed Hassan Shariati head of Mashhad judiciary Ghorban Ali Dorri-Najafabadi former prosecutor-general officials of Tehran revolutionary court Supreme Court officials Evin prison officials province-level prosecutors and others The full list is at https eur-lex europa eu legal-content EN TXT HTML uri CELEX 02011D0235-20180413 qid 1555351537619 from EN Congressional Research Service 69 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 U N designations Entity Date Named Shahid Hemmat Industrial Group Iran Shahid Bakeri Industrial Group Iran Atomic Energy Organization of Iran AEOI AEOI and 23 subsidiaries remained delisted for secondary sanctions under E O 13382 but still designated as Iran-owned or controlled entities June 2005 Novin Energy Company Iran and Mesbah Energy Company Iran January 2006 Four Chinese entities Beijing Alite Technologies LIMMT Economic and Trading Company China Great Wall Industry Corp and China National Precision Machinery Import Export Corp June 2006 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 Group Iran missile program Mizan Machine Manufacturing Group missile program June 2007 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 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 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 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 October 21 2007 Future Bank Bahrain-based but allegedly controlled by Bank Melli March 12 2008 Yahya Rahim Safavi former IRGC Commander in Chief Mohsen Fakrizadeh-Mahabadi senior 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 July 8 2008 Karaj Nuclear Research Center Esfahan Nuclear Fuel Research and Production Center NFRPC Jabber Ibn Hayyan reports to AEIO Safety Equipment Procurement Company Joza Industrial Company front company for SHIG August 12 2008 Congressional Research Service 70 Iran Sanctions Entity Date Named Islamic Republic of Iran Shipping Lines IRISL and 18 affiliates including Val Fajr 8 Kazar Irinvestship Shipping Computer Services Iran o Misr Shipping Iran o Hind IRISL Marine Services Iriatal Shipping South Shipping IRISL Multimodal Oasis IRISL Europe IRISL Benelux IRISL China Asia Marine Network CISCO Shipping and IRISL Malta September 10 2008 Firms affiliated to the Ministry of Defense Armament Industries Group Farasakht Industries Iran Aircraft Manufacturing Industrial Co Iran Communications Industries Iran Electronics Industries and Shiraz Electronics Industries SEI September 17 2008 Export Development Bank of Iran EDBI Provides financial services to Iran’s Ministry of Defense and Armed Forces Logistics Banco Internacional de Desarollo C A Venezuelan-based Iranian bank sanctioned as an affiliate of the Export Development Bank October 22 2008 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 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 March 3 2009 IRGC General Rostam Qasemi head of Khatem ol-Anbiya and several linked entities Fater Engineering Institute Imensazen Consultant Engineers Institute Makin Institute and Rahab Institute February 10 2010 Mohammad Ali Jafari IRGC Commander-in-Chief IRGC Air Force IRGC Missile Command Rah 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 controlled by Iran under E O 13599 June 16 2010 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 Services SA Ali Afzali high official of First East Export Bank IRISL front companies Ashtead Shipping Byfleet Shipping Cobham Shipping Dorking Shipping Effingham Shipping Farnham Shipping 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 November 30 2010 Bonyad foundation Taavon Sepah for providing services to the IRGC Ansar Bank for providing financial services to the IRGC Mehr Bank same justification as above Moallem Insurance Company for providing marine insurance to IRISL Islamic Republic of Iran Shipping Lines December 21 2010 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 Company Fulmen Group Yasa Part By Treasury—Javad Rahiqi Modern Industries Technique Company Iran Centrifuge Technology Company TESA Neka Novin Parto Sanat Paya Partov Simatic Development Co November 21 2011 Iran Maritime Industrial Company SADRA owned by Khatem-ol-Anbiya with offices in Venezuela 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 March 28 2012 Electronic Components Industries Co ECI and Information Systems Iran ISIRAN Advanced 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 July 12 2012 Congressional Research Service 71 Iran Sanctions Entity Date Named National Iranian Oil Company Tehran Gostaresh company owned by Bonyad Taavon Sepah Imam Hossein University IRGC Baghyatollah Medical Sciences University services to IRGC November 8 2012 Atomic Energy Organization of Iran AEOI chief Fereidoun Abbasi Davani Seyed Jaber Safdari of Novin Energy affiliate of AEOI Morteza Ahmadi Behzad services to AEOI Pouya Control— 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 December 13 2012 SAD Import Export Company for shipping arms and other goods to Syria’s armed forces Marine Industries Organization affiliate of Iran Ministry of Defense and Armed Forces Logistics Mustafa Esbati acting for 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 December 21 2012 Babak Morteza Zanjani—chairmen of Sorinet Group that finances Iran oil sales abroad International Safe Oil—provides support to NIOC and NICO Sorinet Commercial Trust Bankers Dubai and First Islamic Investment Bank Malaysia —finance NIOC and NICO Kont Kosmetik and Kont Investment Bank—controlled by Babak Zanjani Naftiran Intertrade Company Ltd owned by NIOC April 11 2013 Iranian-Venezuelan Bi-National Bank IVBB for activities on behalf of the Export Development Bank 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 May 9 2013 For supporting Iran Air the IRGC and NIOC Aban Air Ali Mahdavi part owner of Aban Air DFS 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 May 23 2013 Bukovnya AE Ukraine for leasing aircraft to Iran Air May 31 2013 Several Iranian firms and persons Eyvaz Technic Manufacturing Company The Exploration and Nuclear Raw Materials Company Maro Sanat Company Navid Composite Material 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 December 12 2013 Ali Canko Turkey and Tiva Sanat Group IRGC-Navy boats Advance Electrical and 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 February 6 2014 Eight China-based front companies and Karl Lee aka Li Fangwei Sinotech Industry Co Ltd 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 April 29 2014 By State Organization of Defensive Innovation and Research nuclear research Nuclear Science and Technology Research Institute Arak reactor Jahan Tech Rooyan Pars and Mandegar Baspar Kimiya Company carbon fiber for Iran’s nuclear program 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 April 29 2014 by both State and Treasury 11 ballistic missile-related entities Mabrooka Trading Co LLC UAE Hossein Pournaghshband Chen Mingfu Anhui Land Group Hong Kong Candid General Trading Rahim Reza Farghadani Sayyed Javad Musavi Seyed Mirahmad Nooshin Sayyed Medhi Farahi deputy January 17 2016 Congressional Research Service 72 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 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 March 24 2016 17 ballistic missile-related Entities Abdollah Asgharzadeh Network supporting SHIG Abdollah Asgharzadeh Tenny Darian East Start Company Ofog Sabze Company Richard Yue China Cosailing Business Trading Company China Jack Qin China Ningbo New Century Import and Export Co Ltd China and Carol Zhou China Gulf-Based Rostamian Network supporting SHIG and AIO MKS International Kambiz Rostamian Royal Pearl General Trading Iran-Based Network Working with Navid Composite and Mabrooka Trading Ervin Danesh Aryan Company Mostafa Zahedi Mohammad Magham Ghodrat Zargair and Zist Tajhiz Pooyesh Company supporting Mabrooka Trading Ghodrat Zargari and Zist Tajhiz Pooyesh Company February 3 2017 Ballistic missile-related entities Rahim Ahmadi linked to Shahid Bakeri Industrial Group 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 May 17 2017 12 IRGC military and ballistic missile entities Treasury Rayan Roshd Afzar Company IRGC 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 July 18 2017 Missile entities related to Iran Simorgh space launch six subordinates to Shahid Hemmat Industrial Group SHIG Shaid Karimi Industries Shahid Rastegar Industries Shahid Cheraghi Industries Shahid Varamini Industries Shahid Kalhor Industries and Amir Al Mo’Menin Industries July 28 2017 Suppliers to Iran’s Naval Defence Missile Industry Group SAIG Shahid Alamolhoda Industries Rastafann Ertebat Engineering Company Fanamoj For supporting Iran’s military Wuhan Sanjiang Import and Export Company October 13 2017 Five ballistic missile entities owned or controlled by Shahid Bakeri Industrial Group SBIG Shahid Kharrazi Industries Shahid Sanikhani Industries Shahid Moghaddam Industries Shahid Eslami Research Center and Shahid Shustari Industries January 4 2018 Green Wave Telecommunications Malaysia and Morteza Razavi for supporting Fanamoj 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 January 12 2018 Sayyed Mohammad Ali Haddadnezhad Tehrani for supporting the IRGC Research and SelfSufficiency Jihad Organization to improve Houthi missile capabilities May 22 2018 Bank Tejarat for providing servides to support Bank Sepah Trade Capital Bank Belarus Morteza Ahmadali Behzad for acting on behalf of Pishro Company Nov 5 2018 31 individuals entities connected to Iran’s Organization of Defense Innovation and 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 Ruhollah Ghaderi Barmi and Mohammad Javad Safari Ten entities that research lasers plasma technology satellites biotechnology and other technologies for SPND Sheikh Baha’i Science and Technology Research March 22 2019 Congressional Research Service 73 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 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 June 7 2019 Missile Proliferation Entities Hamid Dehghan Pishtazan Kavosh Gostar Boshra LLC PKGB 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 August 28 2019 Iranian Space Entities Astronautics Research Institute Iran Space Agency Iran Space Research Center September 3 2019 Nuclear managers Majid Agha’i managing director of AEOI and Amjad Sazgar—for engaging in activities involving uranium enrichment in Iran May 27 2020 Iran Shipping Companies Islamic Republic of Iran Shipping Lines IRISL and E-Sail Shipping Company Shanghai For transporting items related to Iran’s ballistic missile program Designations took effect after a 180 day delay to allow Iran to find alternative sources to ship food and medicine June 8 2020 For Ilicit Procurement of Electronic Components Hoda Trading Iran Proma Industry Co Ltd Hong Kong DES International Co Ltd UAE Singapore Taiwan Mohammad Soltanmohammadi Naz Technology Co Ltd China Soltech Industry Co Ltd Brunei Shis Mei Amber Sun Chin-Hua Jinee Huang Mohammad Banihashemi Artin San’at Tabaan Company Nov 10 2020 Entities Affiliated with or Subordinate to Iran’s Atomic Energy Organization AEIO AEIO affiliates—Nuclear Science and Technology Research Institute NSTRI Advanced Technologies Company of Iran IATC Mesbah Energy Company Missile entities Mammut Industrial Group Mammut Industries and its subsidiary Mammut Diesel Numerous individuals employed by these entities October 8 2020 Congressional Research Service 74 Iran Sanctions 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 support to Hezbollah and PIJ Goodwill Charitable Organization a Martyr’s Foundation office in Dearborn Michigan Al Qard Al Hassan—part of Hezbollah’s financial infrastructure and associated with previously designated Hezbollah entities Husayn al-Shami Bayt al-Mal and Yousser Company for Finance and Investment Qasem Aliq—Hezbollah official director of Martyr’s Foundation Lebanon branch and head of Jihad al-Bina Lebanese construction company run by Hezbollah Ahmad al-Shami liaison between Hezbollah and Martyr’s Foundation chapter in Michigan July 25 2007 IRGC-Qods Force and Bank Saderat allegedly used to funnel Iranian money to Hezbollah Hamas PIJ and other Iranian supported terrorist groups October 21 2007 Al Qaeda operatives in Iran Saad bin Laden Mustafa Hamid Muhammad Rab’a al-Bahtiyti Alis Saleh Husain January 16 2009 Qods Force senior officers Hushang Allahdad Hossein Musavi Hasan Mortezavi and Mohammad Reza Zahedi Iranian Committee for the Reconstruction of Lebanon and its director Hesam Khoshnevis for supporting Lebanese Hezbollah Imam Khomeini Relief Committee Lebanon branch and its director Ali Zuraik Razi Musavi a Syrian based Iranian official supporting Hezbollah August 3 2010 Liner Transport Kish for providing shipping services to transport weapons to Lebanese Hezbollah December 21 2010 Qasem Soleimani Qods Force commander Hamid Abdollahi Qods force Abdul Reza Shahlai Qods Force Ali Gholam Shakuri Qods Force Manssor Arbabsiar alleged plotter October 11 2011 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 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 March 27 2012 Mohammad Minai senior Qods Force member involved in Iraq Karim Muhsin al-Ghanimi leader of Kata’ib Hezbollah KH militia in Iraq Sayiid Salah Hantush al-Maksusi senior KH member and Riyad Jasim al-Hamidawi Iran based KH member November 8 2012 Ukraine-Mediterranean Airlines Um Air Ukraine for helping Mahan Air and Iran Air conduct illicit 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 May 31 2013 Several persons entities in UAE aiding Mahan Air see above Blue Sky Aviation FZE Avia Trust 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 February 6 2014 Meraj Air for delivering weapons to Syria Caspian Air transporting personnel and weapons to 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 August 29 2014 Al Naser Airlines Iraq for transferring nine aircraft to Mahan Air which is a 13224 designee Issam Shamout a Syrian businessman and his company Sky Blue Bird Aviation for the same transaction May 21 2015 Four U K -based and two UAE-based entities for supporting Mahan Air U K Jeffrey John James 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 March 24 2016 Eight IRGC-QF and Hezbollah-related entities Lebanon-Based IRGC-QF Network Hasan Dehghan Ebrahimi IRGC-QF operative in Beirut supporting Hezbollah Muhammad Abd-al-Amir February 3 2017 Congressional Research Service 75 Iran Sanctions Entity Date Named Farhat Yahya al-hajj Maher Trading and Construction Company laundering funds and smuggling goods to Hezbollah Reem Phamaceutical Mirage for Engineering and Trading Mirage for Waste Management and Environmental Services Ali Sharifi 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 Printing ForEnt Technik and Printing Trade Center GmbH Germany Mahmoud Seif Tejarat Almas Mobin Holding parent of Rayan Printing November 20 2017 Nine individuals and entities disrupted by U S -UAE joint action attempting to acquire 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 illicit 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 May 10 2018 Persons and entities providing IRGC-QF funds to Hezbollah Central Bank Governor Valiollah Seif Aras Habib and his Iraq-based Al Bilad Islamic Bank and Muhammad Qasir May 15 2018 Four persons for helping the Houthi missile program through the IRGC Aerospace Forces Al Ghadir Missile Command Mahmud Bagheri Kazemabad Mohammad Agha Ja’fari Javad Bordbar Shir Amin and Mehdi Azarpisheh IRGC-QF affiliate May 22 2018 Twenty-one entities linked to the Basij including Basij firms that fund child soldiers in Syria 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 October 16 2018 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 Arian Bank Bank Kargoshaee Melli Bank PLC Tose-E Develoment Company Behshahr Industrial Development Corp Cement Industry and Development Company Melli International Building and Industry Company BMIIC International General Trading LLC Shomal Cement Company Persian Gulf Sabz Karafarinan Mir Business Bank Export Development Bank of Iran EDBI EDBI Stock Exchange EDBI Exchange Brokerage Banco Internacional de Desarrollo C A Iran-Venezuela BiNational 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 November 5 2018 in concert with reimposition of JCPOA-related sanctions Four Hezbollah and IRGC-QF-related individuals who operate in Iraq Shibl Mushin ‘Ubayd AlZaydi Yusuf Hashim Adnan Hussein Kawtharani Muhammad ‘Abd-Al-Hadi Farhat November 13 2018 Individuals involved in a network through which Iran provides oil to Syria and funds 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 Hezbollah Also designated under E O 13582 as part of the network Promsyrioimport Andrey Dogaev Mir Business Bank and Tadbir Kish Medical and Pharmaceutical Company November 20 2018 Iran-recruited Afghan and Pakistani-staffed militia entities fighting in Syria Fatemiyoun Division and Zaynabiyoun Brigade Qeshm Fars Air and Flight Travel LLC—Mahan Air affiliates—for weapons deliveries into Syria Congressional Research Service January 24 2019 76 Iran Sanctions Entity Date Named Iraq-related entities Harakat al-Nujaba HAN Iraqi Shia militia and HAN leader Akram Abbas al-Kabi previously sanctioned in 2008 when he headed a Mahdi Army “special group” militia March 5 2019 25 individuals and entities that illicitly moved funds via the IRGC-controlled Ansar Bank and Ansar Exchange MODAFL Ansar Bank its managing director Ayatollah Ebrahimi and affiliates Iranian Atlas Company Ansar Bank Brokerage Company and Ansar Information Technology Ansar Exchange its managing director Alireza Atabaki and UAE-based facilitators Reza Sakan Mohammad Vakili and the Vakili-owned Atlas Exchange Zagros Pardis Kish for helping MODAFL acquire vehicles in UAE and its manager Iman Sedaghat Sakan General Trading UAE its owner Rez Sakan and Iran-based affiliate Sakan Exchange Hital Exchange and its owner Seyyed Mohammad Reza Ale Ali Golden Commodities General Trading UAE its owner 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 March 26 2019 Iraq-based entities facilitating IRGC-QF access to Iraq’s financial system South Wealth Resources Company aka Manabea Tharwat al-Janoob General Trading Co Makki Kazim ‘Abd l Hamid Al Asadi and Muhammed Husayn Salih al-Hasani June 12 2019 Eight IRGC Commanders IRGC Navy Commander Ali Reza Tangsiri IRGC Aerospace Commander Amirali Hajizadeh IRGC Ground Forces Commander Mohammad Pakpour and five IRGC Navy district commaners Abbas Gholamshahi district 1 Ramezan Zirahi district 2 Yadollah Badin district 3 Mansur Ravankar district 4 and Ali Ozma’I district 5 June 24 2019 Hezbollah Parliamentarians Two Hezbollah parliamentarians for using their parliamentary positions to advance Hezbollah objectives and “bolstering Iran’s malign activities” Amin Sherri and Muhammad Hasan Ra’d who is also a member of Hezbollah’s Shura Council Also designated head of Hezbollah security and liaison to Lebanon’s security services Wafiq Safa July 9 2019 Financial Institutions used by Hezbollah all in Lebanon Jammal Trust Bank SAL Trust Insurance SAL Trust Insurance Services SAL Trust Life Insurance Company SAL August 29 2019 Financial Facilitators Moving Funds from IRGC-QF to Hamas Muahmmad Sarur Kamal Abdelrahman Aref Awad Fawaz Mahmud Ali Nasser Muhammad Al-Ayy Designations made in partnership with the Sultanate of Oman August 29 2019 Oil Tanker Seized and Released by Gibraltar Adrian Darya 1 and Akhilesh Kumar ship and captain for carrying oil to Syria August 30 2019 Iran Oil Shipping Network 16 entities and 10 persons including Rostam Qasemi former Oil 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 September 4 2019 Persons and Entities Facilitating Funding from IRGC-QF Muhammad Sa’id Izadi head of 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 Hezbollah 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 September 10 2019 Central Bank Central Bank of Iran National Development Fund of Iran and Etemad Tejarate Pars Co For funneling funds to the IRGC MODAFL and Lebanese Hezbollah National Development Fund a sovereign wealth fund is primarily involved in rural electrification and development September 20 2019 IRGC-QF Shipping Network to Yemen Abdolhossein Khedri Khedri Jahan Darya Co 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 December 11 2019 Congressional Research Service 77 Iran Sanctions Entity Date Named Hezbollah Individuals and Entities Three individuals and 12 entities linked to the Martyr’s Foundation which is part of Hezbollah’s support network Entities sanctioned included Atlas Holdings and its affiliates involved in medical equipment pharmaceuticals paints and tourism February 26 2020 Iran and Iraq-based front companies controlled or supporting the IRGC-QF Individuals 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 Hezbollah militia March 26 2020 For Supporting Mahan Airlines Parthia Cargo UAE Delta Parts Supply FZC and Parthia owner Amin Mahdavi August 19 2020 Former Lebanese Ministers for supporting Hezbollah Yusuf Finyanus and Ali Hassan Khalil September 8 2020 Hezbollah Companies and Person Arch Consulting Meamar Construction Hezbollah Executive Council member Sultan Khalifah As’ad September 17 2020 Hezbollah Central Council Members Nabil Qaouk and Hassan al-Baghdadi October 22 2020 Oil Sector Entities Supporting the IRGC-QF Gas Shipments to Venezuela Iran Ministry of Petroleum National Iranian Oil Company NIOC National Iranian Tanker Company NITC two UAE based-front companies Atlas Ship Management and Atlantic Ship Management Minister of Petroleum Bijan Zanganeh NIOC senior officials including Director Masoud Karbasian and various Ministry of Petroleum Affililiates For shipments to Venezuela Mobin International Ltd UAE Mobin Holding Ltd UK and Oman Fuel Trading Ltd UK October 26 2020 Table D-3 Determinations and Sanctions under the Iran Sanctions Act Entity Date Named Total SA France Gazprom Russia and Petronas Malaysia —$2 billion project to develop South Pars gas 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 May 18 1998 Naftiran Intertrade Co NICO Iran and Switzerland Sanctioned for activities to develop Iran’s energy sector September 30 2010 Total France Statoil Norway ENI Italy and Royal Dutch Shell Exempted under ISA “special rule” for pledging to wind down work on Iran energy fields September 30 2010 Inpex Japan Exempted under the Special rule for divesting its remaining 10% stake in Azadegan oil field November 17 2010 Belarusneft Belarus subsidiary of Belneftekhim Sanctioned for $500 million contract with NICO see above to develop Jofeir oil field Other subsidiaries of Belneftekhim were sanctioned in 2007 under E O 13405 Belarus sanctions March 29 2011 Petrochemical Commercial Company International PCCI of Bailiwick of Jersey and Iran Royal Oyster 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 May 24 2011 Congressional Research Service 78 Iran Sanctions Entity Date Named Zhuhai Zhenrong Co China Kuo Oil Pte Ltd Singapore FAL Oil Co UAE Sanctioned for brokering sales or making sales to Iran of gasoline January 12 2012 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 Insurance of Iran CII Iran Sanctioned under ISA provision on owning vessels that transport Iranian oil or providing insurance for the shipments March 14 2013 Tanker Pacific SAMAMA and Allvale Maritime Sanctions lifted Special rule applied after “reliable assurances” they will not engage in similar activity in the future April 12 2013 Ferland Co Ltd Cyprus and Ukraine Sanctioned for cooperating with National Iranian Tanker Co to illicitly sell Iranian crude oil May 31 2013 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 both designations revoked in 2010 July 30 1998 D Mendeleyev University of Chemical Technology of Russia and Moscow Aviation Institute removed May 21 2010 January 8 1999 Changgwang Sinyong Corp North Korea January 2 2001 Changgwang Sinyong Corp North Korea and Jiangsu Yongli Chemicals and Technology Import-Export China June 14 2001 Three entities from China for proliferation to Iran January 16 2002 Armen Sargsian and Lizen Open Joint Stock Co Armenia Cuanta SA and Mikhail Pavlovich Vladov Moldova and eight China entities for proliferation involving Iran May 9 2002 Norinco China For alleged missile technology sale to Iran May 2003 Taiwan Foreign Trade General Corporation Taiwan July 4 2003 Tula Instrument Design Bureau Russia For alleged sales of laser-guided artillery shells to Iran Also designated under Executive Order 12938 September 17 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 Prasad Russia Spain and Ukraine September 23 2004 14 entities mostly from China for supplying of Iran’s missile program Designations included North Korea’s Changgwang Sinyong and China’s Norinco and Great Wall Industry Corp sanctioned previously Others sanctioned included North Korea’s Paeksan Associated Corporation and Taiwan’s Ecoma Enterprise Co December 2004 and January 2005 Nine entities including from China Norinco Hondu Aviation Dalian Sunny Industries Zibo Chemet Equipment India Sabero Organicx Chemicals and Sandhya Organic Chemicals and Austria Steyr Mannlicher Gmbh Sanctions against Dr Surendar of India see September 29 2004 were ended because of information exonerating him December 23 2005 Congressional Research Service 79 Iran Sanctions Entity Date Named Two Indian chemical companies Balaji Amines and Prachi Poly Products two Russian firms Rosobornexport and aircraft manufacturer Sukhoi two North Korean entities Korean Mining and Industrial Development and Korea Pugang Trading and one Cuban entity Center for Genetic Engineering and Biotechnology July 28 2006 Abu Hamadi Iraq Aerospace Logistics Services Mexico Al Zargaa Optical and Electronics Sudan Alexey Safonov Russia Arif Durrani Pakistan China National Aero Technology Import-Export China 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 December 28 2006 Rosobornexport Tula Design and Komna Design Office of Machine Building and Alexei Safonov Russia Zibo Chemical China National Aerotechnology and China National Electrical China Korean Mining and Industrial Development North Korea for WMD advanced weapons sales to Iran and Syria January 2007 14 entities including Lebanese Hezbollah Some were penalized for transactions with Syria For assisting 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 April 17 2007 China Xinshidai Co China Shipbuilding and Offshore International Corp Huazhong CNC China IRGC Korea Mining Development Corp North Korea Korea Taesong Trading Co NK Yolin Yullin Tech Inc South Korea Rosoboronexport Russia sate arms export agency Sudan Master Technology Sudan Technical Center Co Army Supply Bureau Syria R and M International FZCO UAE Venezuelan Military Industries Co CAVIM Rosoboronexport removed May 21 2010 October 23 2008 BelTechExport Belarus Dalian Sunny Industries China Defense Industries Organization Iran Karl Lee Shahid Bakeri Industries Group SBIG Shanghai Technical By-Products International China Zibo Chemet Equipment China July 14 2010 16 entities Belarus Belarusian Optical Mechanical Association Beltech Export China Karl Lee Dalian 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 May 23 2011 Belvneshpromservice Belarus Dalian Sunny Industries China Defense Industries Organization Iran Karl Lee China SAD Import-Export Iran Zibo Chemet Equipment Co Iran F December 20 2011 Al Zargaa Engineering Complex Sudan BST Technology and Trade Co China China Precision Machinery 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 February 5 2013 Al Zargaa Engineering Complex Sudan Belvneshpromservice Belarus HSC Mic NPO Mashinostroyenia Russia Russian Aircraft Corporation MiG Giad Heavy Industries Complex Sudan Sudan Master Technologies Sudan Military Industrial Corps Sudan Yarmouk Industrial Complex Sudan Venezuelan Military Industry Co CAVIM Venezula December 19 2014 BST Technology and Trade Co China Dalian Sunny Industries China Li Fang Wei China Tianjin Flourish Chemical Co China Qods Force Commander Qasem Soleimani IRGC Rock Chemie Iran Polestar Trading Co Ltd North Korean entity in China RyonHap-2 North Korea Tula Instrument Design Bureau Russia Joint Stock Co Katod Russia JSC Mic NPO Mashinostroyenia Russia Rosoboronexport Russia Russian Aircraft Corp MiG Russia Sudanese Armed Forces Sudan Vega Aeronautics Sudan Yarmouk Complex Sudan Hezbollah Eliya General Trading UAE Designations that applied to Syria or North Korea not included August 28 2015 Asaib Ahl Haq Iraqi Shiite militia Katai’b Hezbollah Iraqi militia IRGC Shahid Moghadam-Yazd Marine Industries Iran Shiraz Electronic Industries Iran Hezbollah Military Industrial Corp Sudan Khartoum Industrial Complex Sudan Khartoum Military Industrial Complex Sudan Luwero Industries Uganda June 28 2016 Congressional Research Service 80 Iran Sanctions Entity Date Named 11 entities sanctions for transfers of sensitive items to Iran’s ballistic missile program all China except as 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 March 21 2017 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 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 July 9 2002 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 fomenting sectarian violence in Iraq and of organizing training in Iran for Iraqi Shiite militia fighters Abu Mustafa al-Sheibani Iran based leader of network that funnels Iranian arms to Shiite militias in Iraq Isma’il al-Lami Abu Dura Shiite militia leader breakaway from Sadr Mahdi Army Al Zawra Television Station and its owner Mishan al-Jabburi January 8 2008 Abdul Reza Shahlai a deputy commander of the Qods Force Akram Abbas Al Kabi leader of Mahdi Army “Special Groups” Harith Al Dari Sunnis Islamist leader Secretary General of the Muslim Scholars’ Association Ahmad Hassan Kaka Al Ubaydi ex-Baathist leader of Sunni insurgents 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 September 16 2008 Khata’ib Hezbollah Mahdi splinter group Abu Mahdi al-Muhandis Muhandis was killed in the U S strike of January 3 2020 that killed IRGC-Qf commander Qasem Soleimani July 2 2009 Table D-7 Iranians Designated Under Executive Order 13553 on Human Rights Abusers September 29 2010 These persons are named in a semiannual report to Congress required under CISADA Virtually all of the persons on this list and those listed under Executive order 13628 below are designated as human rights abusers by the European Union whose list contains 87 individuals including several province-level prosecutors Entity Eight persons IRGC Commander Mohammad Ali Jafari Minister of Interior at time of June 2009 elections Sadeq Mahsouli Minister of Intelligence at time of elections Qolam Hossein Mohseni-Ejei Tehran Prosecutor General at time of elections Saeed Mortazavi Minister of Congressional Research Service Date Named September 29 2010 81 Iran Sanctions Entity Date Named 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 indicting large numbers of protesters Basij forces commander Mohammad Reza Naqdi headed Basij intelligence during 2009 protests February 23 2011 Four entities Islamic Revolutionary Guard Corps IRGC Basij Resistance Force Law Enforcement Forces LEF LEF Commander Ismail Ahmad Moghadam June 9 2011 Two persons Chairman of the Joint Chiefs of Staff Hassan Firouzabadi Deputy IRGC Commander Abdollah Araghi December 13 2011 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 providing material support to the IRGC and MOIS May 30 2013 One entity Abyssec for training the IRGC in cyber tradecraft and supporting its development of offensive information operations capabilities December 30 2014 One entity and One person Tehran Prisons Organization For severe beating of prisoners 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 April 13 2017 Persons and entities designated following repression of December 2017-January 2018 protests Judiciary head Sadeq Amoli Larijani highest-ranking Iranian official sanctioned by the United States Rajaee Shahr Prison and Gholmreza Ziaei January 12 2018 Ansar-e Hezbollah internal security militia designations Ansar-e Hezbollah Ansar leaders Abdolhamid Mohtasham Hossein Allahkaram and Hamid Ostad Evin Prison May 30 3018 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 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 May 20 2020 For Cyber violations against Iranian dissidents and perceived threats Advanced Persistent Threat 39 Rana Intelligence Computing and 45 individuals associated with the activity September 17 2020 Minister of Intelligence and Security Mahmoud Alavi November 18 2020 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 operations and training May 18 2011 Ministry of Intelligence and Security MOIS February 16 2012 Congressional Research Service 82 Iran Sanctions 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 Enforcement Forces Datak Telecom April 23 2012 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 sell Iranian crude oil May 31 2013 Three persons based in the Republic of Georgia Pourya Nayebi Houshang Hosseinpour and 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 February 6 2014 Evren Kayakiran Turkey for directing employees to provide U S products and services to Iran February 7 2019 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 Company 20 Petroleum and Petrochemical Entities MSP Kala Naft Co Tehran Kala Limited Kala Pension Trust Limited National Iranian Oil Company PTE Ltd Iranian Oil Company U K Ltd NIOC International Affairs London Ltd Naftiran Trading Services Co NTS Ltd NICO Engineering Ltd National Petrochemical Company Iran Petrochemical Commercial Company NPC International Ltd Intra Chem Trading Gmbh Petrochemical Commercial Company International Ltd P C C Singapore Private Ltd Petrochemical Commercial Company FZE Petrochemical Commercial Company U K Ltd PetroIran Development Company PEDCO Ltd Petropars Ltd Petropars International FZE Petropars U K Ltd June 16 2010 Central Bank of Iran aka Bank Markazi February 12 2012 Shipping Companies Arash Shipping Enterprises Ltd Arta Shipping Enterprises Ltd Asan 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 July 12 2012 Congressional Research Service 83 Iran Sanctions Entity Date Named 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 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 March 14 2013 Sambouk Shipping FZC which is tied to Dr Dimitris Cambis and his network of front companies May 9 2013 Eight petrochemicals companies Bandar Imam Bou Ali Sina Mobin Nouri Pars Shahid Tondgooyan Shazand and Tabriz May 31 2013 Six individuals including Seyed Nasser Mohammad Seyyedi director of Sima General Trading 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 September 6 2013 Execution of Imam’s Order EIKO and entities under its umbrella designated for hiding assets on behalf of the government of Iran’s leadership Tosee e Eqtesad Ayandehsazan Company TEACO Tadbir Economic Development Company Tadbir Group Tadbir Investment Company Modaber Tadbir Construction Development Company Tadbir Energy Development Group Amin Investment Bank Pardis Investment Company Mellat Insurance Company Rey Investment Company Reyco GmbH MCS International GmbH Mannesman Cylinder Systems MCS Engineering Efficient Provider Services GmbH Golden Resources Trading Company L L C GRTC Cylinder System Ltd Cylinder System DDO One Vision Investments 5 Pty Ltd One Class Properties Pty Ltd Iran and Shargh Company Iran and Shargh Leasing Company Tadbir Brokerage Company Rafsanjan Cement Company Rishmak Productive and Exports Company Omid Rey Civil and Construction Company Behsaz Kashane Tehran Construction Company Royal Arya Company Hormuz Oil Refining Company Ghaed Bassir Petrochemical Products Company Persia Oil and Gas Industry Development Company Pars Oil Company Commercial Pars Oil Company Marjan Petrochemical Company Ghadir Investment Company Sadaf Petrochemical Assaluyeh Company Polynar Company Pars MCS Arman Pajouh Sabzevaran Mining Company Oil industry Investment Company Rey Niru Engineering Company January 4 2013 Five Iranian banks Khavarmianeh Bank Ghavamin Bank Gharzolhasaneh Bank Kish International Bank and Kafolatbank Tajikistan August 29 2014 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 Congressional Research Service 84 Iran Sanctions 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 and Beverage JLT for receiving payments on behalf of Jam Petrochemical May 31 2013 Asia Bank for delivering from Moscow to Tehran of $13 million in U S bank notes paid to representatives of the Iranian government August 29 2014 Five individuals and one company for helping Iran acquire U S banknotes Hossein Zeidi Seyed Kamal Yasini Azizullah Qulandary Asadollah Seifi Teymour Ameri and Belfast General Trading Anahita Nasirbeik—Asia Bank official see above December 30 2014 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 graphite to IRISL June 25 2020 China and Hong Kong Entities Supporting Islamic Republic of Iran Shipping Lines IRISL Reach Holdings Shanghai Reach Shipping Lines Delight Shipping Co Ltd Gracious Shipping Co Ltd Noble Shipping Co Ltd Supreme Shipping Co Ltd and officials of these firms October 19 2020 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 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 November 8 2012 Islamic Republic of Iran Broadcasting IRIB and Ezzatollah Zarghami director and head of 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 February 6 2013 Committee to Determine Instances of Criminal Content for engaging in censorship 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 May 30 2013 Morteza Tamaddon for blocking cellphones of opposition leaders Mir Hosein Musavi and Mehdi Karrubi when Tamaddon was governor-general of Tehran Province in 2009 May 23 2014 Congressional Research Service 85 Iran Sanctions Entity Date Named Douran Software Technologies for acting on behalf of the Committee to Determine Instances of Criminal Content see above December 30 2014 Two entities that blocked social media sites and websites Supreme Council for Cyberspace and National Cyberspace Center January 12 2018 IRIB Director General Abdulali Ali-Asgari see above Abolhassan Firouzabadi Secretary of the Supreme Council of Cyberspace and Abdolsamad Khoramabadi Secretary of the Committee to Determine Instances of Criminal Conduct oversees Internet censorship May 30 3018 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 Siqiriya Maritime Philippines Ferland Company Limited previously designated under other E O Vitaly Sokolenko general manager of Ferland December 12 2012 Three entities persons for deceptive Iran oil dealings Saeed Al Aqili co-owner of Al Aqili 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 April 29 2014 Faylaca Petroleum for obscuring the origin of Iranian sales of gas condensates Lissome 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 August 29 2014 Table D-16 Entities Designated under Executive Order 13581 on Transnational Criminal Organizations July 24 2011 Entity Four individuals entities Ajily Software Procurement Group Andisheh Vesal Middle East 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 Date Named July 18 2017 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 U S banks acting on behalf of the IRGC and Ahmad Fathi Amin Shokohi and Hamid 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 September 14 2017 Ten individuals and one entity for theft of data from U S and third-country universities Mabna Institute Gholamreza Rafatnejad Ehsan Mohammadi Seyed Ali Mirkarimi Mostafa March 23 2018 Congressional Research Service 86 Iran Sanctions Entity Date Named Sadeghi Sajjad Tamasebi Abdollah Karima Abuzr Gohair Moqadam Roozbeh Sabahi Mohammed Reza Sabai Behzad Mesri Ali Khorashadizadeh and Mohammad Ghorbaniyan For helping exchange bitcoin digital currency into Iranian rials on behalf of Iranian cyber actors involved with a “SamSam” ransomware scheme November 28 2018 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 in oil shipments from Iran China Concord Petroleum Ltd COSCO Shipping Tanker 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 September 25 2019 Under Section 7 of the E O Human Rights related provision sanctioning persons who limit freedom of expression in Iran Abolghassem Salavati Mohammad Moghisseh judges presiding over branches of the regime’s Revolutionary Court December 19 2019 Several petrochemical companies for brokering sales of Iranian oil and other 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 January 23 2020 Entities involved in petrochemical transactions with Iran SPI International 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 March 18 2020 UAE Companies facilitating Iran petrochemical and oil sales Petro Grand FZE Alphabet International DMCC Swissol Trade DMCC Alam Althrwa General Trading LLC and Alwaneo LLC Co March 19 2020 For facilitating Iran petrochemical transactions Triliance Petrochemical Co Ltd Hong Kong Sage Energy HK Limited Hong Kong Peakview Industry Co Limited Shanghai and Beneathco DMCC UAE January 23 2020 For Enabling the Shipment and Sale of Iranian Petrochemicals By Treasury Zagros Petrochemical Co Iran Petrotech FZE UAE Jingho Technology Co Ltd Hong Kong Dynapex Energy Ltd Hong Kong Trio Energy DMCC UAE Dinrin Ltd Hong Kong By State Abadan Refining Co Zhihang Ship Management China New Fars International Logistics LLC China Sino Energy Shipping Ltd China Chemtrans Petrochemicals Trading LLC UAE and several Chines and Iranian employees of these firms September 3 2020 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 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 January 10 2020 Affiliates of Iran’s Mobarakeh Steel Company Iran—Metil Steel South Aluminum 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 June 25 2020 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 1989-1997 May 20 2020 IRGC Brig Gen Heidar Abasszadeh IRGC Colonel Reza Papi – for involvement in the killing of protesters in the town of Mahshar in November 2019 November 18 2020 Table D-21 Entities Designated under E O 13876 on the Supreme Leader and his Office June 24 2019 Entity Foreign Minister Mohammad Javad Zarif Date Named July 31 2019 Ten High-Ranking Officials Personalities and One Major Entity Ebrahim Raisi head of the 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 November 4 2019 Ali Shamkhani—Secretary General of Iran Supreme National Security Council 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 Abdollahi—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 January 10 2020 Congressional Research Service 88 Iran Sanctions Entity Date Named Members of Council of Guardians and Elections Supervision Committee for 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 February 20 2020 Bonyad Mostazafan economic conglomerate and affiliates Bonyad Mostazafan its president and IRGC conduit Parviz Fattah several Bonyad board members Bonyad affiliate companies – Sina Energy Development Co SEDCO SEDCO subordinates in the energy drilling and financial sector Behran Oil Kaveh Pars Mining Industries Development Co and steel aluminum and financial subordinates including Turkey-based Turira Co Bank Sina and affiliates Omran va Maskan Iran Company and Paya Saman Pars Co Persian Tourism and Recreational Centers Co and subordinates ex Bonyad Shipping Agencies Co Sina Paya Sanat Development Co and subordinates Other subsidiaries Iran Electronic Development Co Rah Negar Middle East Pars Co and Peyvand Tejarat Atieh Iranian Co November 18 2020 Table D-22 Executive Order 13818 Implementing the Global Magnitsky Act December 20 2017 Entity Iran-backed Iraqi militia figures Qais al-Khazali head of Asa’ib Ahl Al Haq militia Laith al-Khazali Husayn Falih al-Lami Date Named December 6 2019 Table D-23 Executive Order 13902 on the Construction Textiles and other Sectors January 10 2020 Entity Iranian Banks not sanctioned under other orders Amin Investment Bank Bank Keshavarzi Iran Bank Maskan Bank Refah Kargaran Banke-e Shahr Eghtesad Novin Bank Gharzolhasaneh Resalat Bank Hekmat Iranian Bank Iran Zamin Bank Islamic Regional Cooperation Bank Karafarin Bank Khavarmianeh Bank Mehr Iran Credit Union Bank Pasargad Bank Saman Bank Sarmayeh Bank Tosee Taavon Bank Tourism Bank Date Named October 8 2020 Table D-24 Executive Order 13949 on Conventional Arms to Iran September 21 2020 Entity Iran Ministry of Defense and Armed Forces Logistics MODAFL Defense Industries Organization Nicholas Maduro Congressional Research Service Date Named September 21 2020 89 Iran Sanctions Table D-25 Entities Sanctions Under CAATSA Entity Pursuant to CAATSA Section 106 on human rights abuses for gross violations of human rights Various Iranian judges and prison entities—Judge Seyyed Mahmoud Sadati Judge Mohammad Soltani Branch 1 of the Revolutionary Court of Shiraz Adelabad Orumiyeh and Vakilabad Prisons Date Named September 24 2020 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 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