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Iran Sanctions Iran Sanctions Kenneth Katzman Specialist in Middle Eastern Affairs April 26, 2012 Congressional Research Service 7-5700 www.crs.gov RS20871 CRS Report for Congress Prepared for Members and Committees of Congress Iran Sanctions Summary The objective of sanctions—to compel Iran to verifiably demonstrate that its nuclear program is for purely peaceful uses—may be on its way to achievement but has not been accomplished to date. The international coalition that is imposing progressively strict economic sanctions on Iran has broadened and deepened, producing significant effects on Iran’s economy. U.S. officials believe that these sanctions—which are now targeting Iran’s oil export lifeline—caused Iran to return to the nuclear bargaining table in April 2012 with greater seriousness and intent toward peaceful resolution. Many judge that Iran needs an easing of sanctions because the energy sector provides nearly 70% of Iran’s government revenues. Iran’s worsening economic situation is caused by: • A decision by the European Union on January 23, 2012, to wind down purchases of Iranian crude oil by July 1, 2012. EU countries buy about 20% of Iran’s oil exports. This action took into consideration an International Atomic Energy Agency (IAEA) report on Iran’s possible efforts to design a nuclear explosive device, and diplomatic and financial rifts with Britain, which caused the storming of the British Embassy in Tehran on November 30, 2011. • Decisions by other Iranian oil purchasers, particularly Japan, to reduce purchases of Iranian oil. Those decisions are intended to comply with a provision of the FY2012 National Defense Authorization Act (P.L. 112-81, signed December 31, 2011) that prevents the opening of U.S. accounts by foreign banks that conduct transactions with Iran’s Central Bank—unless the parent country reduces substantially its purchases of Iranian oil. • The willingness of other oil producers with spare capacity, particularly Saudi Arabia, a strategic rival, to sell additional oil to countries cutting Iranian oil buys. • Industry sources said in late March 2012 that Iran’s oil sales for March have fallen dramatically from prior levels. Once the EU embargo is fully implemented, Iran’s oil sales might fall by as much as 40% (1 million barrels per day reduction out of 2.5 million barrels per day of sales). Iran is widely assessed as unable to economically sustain that level of lost oil sales. The signs of economic pressure on Iran are multiplying. The value of Iran’s rial has dropped precipitously since September 2011. Iran is virtually cut off from the international banking system and is increasingly trading through barter arrangements rather than hard currency exchange. The pullout from Iran by major international firms has slowed Iran’s efforts to modernize its energy sector and other sectors, rendering Iran unable to increase its oil production above 4.1 million barrels per day. Still, Iran has small amounts of natural gas exports; it had none at all before Iran opened its fields to foreign investment in 1996. Still, relatively high world oil prices have reduced some of the effects of the sanctions. Despite the imposition of what many now consider to be “crippling” sanctions, some in Congress believe that economic and diplomatic pressure on Iran needs to increase further and faster. In the 112th Congress, legislation, such as S. 1048, H.R. 1905, and S. 2101, would enhance both the economic sanctions and human rights-related provisions of a previous Iran sanctions laws However, movement on new sanctions might be on hold pending the outcome of a second round of nuclear talks slated for May 23 in Baghdad. For a broader analysis of policy on Iran, see CRS Report RL32048, Iran: U.S. Concerns and Policy Responses, by Kenneth Katzman. Congressional Research Service Iran Sanctions Contents Overview.......................................................................................................................................... 1 Sanctions Targeting Foreign Energy Involvement in Iran: The Iran Sanctions Act (ISA), CISADA, and a November 2011 Executive Order....................................................................... 1 The Iran Sanctions Act and CISADA Amendments.................................................................. 1 Key “Triggers” .................................................................................................................... 2 Mandate and Time Frame to Investigate Violations............................................................ 4 Available Sanctions Under ISA........................................................................................... 5 Waivers, Exemptions, and Termination Authority .............................................................. 6 Termination Requirements and Sunset Provisions.............................................................. 7 Interpretations of ISA and CISADA.......................................................................................... 7 Non-Application to Crude Oil or Natural Gas Purchases from Iran or to Official Credit Guarantee Agencies............................................................................................... 7 Application to Energy Pipelines.......................................................................................... 8 Application to Iranian Firms or the Revolutionary Guard ................................................ 10 Application to Liquefied Natural Gas ............................................................................... 10 Implementation of ISA and CISADA...................................................................................... 11 ISA Sanctions Determinations: September 2010 to the Present........................................ 11 Ban on U.S. Trade and Investment With Iran ................................................................................ 14 Implementation........................................................................................................................ 16 Non-Application to Foreign Refined Oil With Iranian Content........................................ 16 Non-Application to Foreign Subsidiaries of U.S. Firms ................................................... 17 Financial Sanctions: CISADA and Sanctions on Dealings with Iran’s Central Bank.................... 19 Early Efforts: Targeted Financial Measures ............................................................................ 19 Banking Provisions of CISADA ............................................................................................. 20 Sanctions Imposed?........................................................................................................... 20 Section 311 of the Patriot Act..................................................................................................20 Sanctioning Dealings With Iran’s Central Bank/Section 1245 of the FY2012 National Defense Authorization Act (P.L. 112-81) ............................................................................. 21 Implementation/Exemptions Issued .................................................................................. 22 February 5, 2012, Executive Order on the Central Bank .................................................. 23 Terrorism List Sanctions: Ban on Aid and Other Programs........................................................... 23 Executive Order 13224: Sanctioning Terrorism Supporting Entities ...................................... 24 Proliferation-Related U.S. Sanctions............................................................................................. 24 Iran-Iraq Arms Nonproliferation Act....................................................................................... 25 Iran-North Korea-Syria Nonproliferation Act ......................................................................... 25 Executive Order 13382............................................................................................................ 25 Foreign Aid Restrictions for Suppliers of Iran ........................................................................ 26 U.S. Efforts to Promote Divestment ..............................................................................................26 U.S. Sanctions Intended to Support Democratic Change in Iran or Alter Iran’s Foreign Policy.......................................................................................................................................... 26 Expanding Internet and Communications Freedoms............................................................... 26 Implementation and Further Administration Action ......................................................... 27 Measures to Sanction Human Rights Abuses and Promote the Opposition ............................ 28 Congressional Research Service Iran Sanctions Executive Order 13438 and 13572: Sanctioning Iranian Involvement in the Region .................................................................................................................. 28 Separate Visa Ban.............................................................................................................. 29 Blocked Iranian Property and Assets.............................................................................................29 U.N. Sanctions............................................................................................................................... 30 International Implementation and Compliance.............................................................................
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