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Iran Sanctions Iran Sanctions Updated January 4, 2019 Congressional Research Service https://crsreports.congress.gov RS20871 {222A0E69-13A2-4985-84AE-73CC3D FF4D02}- RS-048044163098222232140238255021054168155246022026112079081144080116141042000141076242222124196162214089179213131247242198067057058070197232223159149235082053167227015117047146049185221227214157147041229233230070250208206233104195087061084080 Iran Sanctions Summary U.S. sanctions have been used extensively by successive Administrations to try to achieve change in Iran’s behavior. Sanctions had a substantial effect on Iran’s economy and on some major strategic decisions, but little or no effect on Iran’s regional malign activities. During 2012-2015, when the global community was relatively united in pressuring Iran, Iran’s economy shrank by 9% per year, crude oil exports fell from about 2.5 million barrels per day (mbd) to about 1.1 mbd, and Iran was unable to repatriate more than $120 billion in reserves held in banks abroad. The 2015 multilateral nuclear accord (Joint Comprehensive Plan of Action, or JCPOA) provided Iran broad relief from the international and U.S. secondary sanctions as the U.S. Administration waived relevant sanctions, revoked relevant executive orders (E.O.s), and corresponding U.N. and EU sanctions were lifted. Remaining in place were a general ban on U.S. trade with Iran and sanctions imposed on Iran’s support for regional governments and armed factions, its human rights abuses, its efforts to acquire missile and advanced conventional weapons capabilities, and the Islamic Revolutionary Guard Corps (IRGC). Under U.N. Security Council Resolution 2231, nonbinding U.N. restrictions on Iran’s development of nuclear-capable ballistic missiles and a binding ban on its importation or exportation of arms remain in place for several years. However, Iran has continued to support regional armed factions and to develop ballistic missiles despite the U.N. restrictions, and did so even when strict international economic sanctions were in place during 2010-2015. JCPOA sanctions relief enabled Iran to increase its oil exports to nearly pre-sanctions levels, regain access to foreign exchange reserve funds and reintegrate into the international financial system, achieve about 7% yearly economic growth, attract foreign investments in key sectors, and buy new passenger aircraft. The sanctions relief contributed to Iranian President Hassan Rouhani’s reelection in the May 19, 2017, vote. Yet, perceived economic grievances have sparked sporadic unrest since December 2017. On May 8, 2018, President Trump announced that the United States would no longer participate in the JCPOA and that all U.S. secondary sanctions would be reimposed after a maximum “wind- down period” of 180 days (ending November 4, 2018). With that time period expired, all U.S. sanctions, including those on energy or banking transactions with Iran, went back into effect on November 5, 2018. The reimposition of U.S. sanctions has begun to harm Iran’s economy as major companies exit the Iranian economy rather than risk being penalized by the United States. Iran’s oil exports are decreasing and difficulties paying Iran for oil with hard currency are evident. The value of Iran’s currency has sharply declined and economic-based unrest has continued, although not to the point where the regime is threatened. But it remains uncertain how extensively Iran’s economy will be damaged, because the European Union and other countries are trying to keep the economic benefits of the JCPOA flowing to Iran in order to persuade Iran to remain in the JCPOA. And, on November 5, 2018, the Administration granted exceptions to eight countries that the Administration asserts significantly reduced oil imports from Iran. Exceptions were provided to China and India even though the two countries combined continued to import over 1 million barrels per day of Iranian crude oil in October, thwarting the Administration’s goal of reducing Iranian oil exports “as close to zero as possible.” 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 and Objectives ................................................................................................................ 1 Blocked Iranian Property and Assets ............................................................................................... 1 Executive Order 13599 Impounding Iran-Owned Assets .......................................................... 3 Sanctions for Iran’s Support for Terrorism and Regional Activities ............................................... 4 Sanctions Triggered by Terrorism List Designation .................................................................. 4 Exception for U.S. Humanitarian Aid ................................................................................. 5 Sanctions on States “Not Cooperating” Against Terrorism ...................................................... 5 Executive Order 13224 Sanctioning Terrorism-Supporting Entities ......................................... 6 Use of the Order to Target Iranian Arms Exports ............................................................... 6 Application to the Revolutionary Guard by the Countering America’s Adversaries through Sanctions Act (CAATSA, P.L. 115-44) .............................................................. 6 Implementation ................................................................................................................... 6 Sanctions on Iran’s Malign Regional Activities ........................................................................ 6 Ban on U.S. Trade and Investment with Iran .................................................................................. 7 JCPOA-Related Easing and Reversal ................................................................................. 8 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.................................................................................................. 11 The Iran Sanctions Act (and Triggers added by other Laws) ................................................... 11 Key Sanctions “Triggers” Under ISA ................................................................................ 11 Mandate and Time Frame to Investigate ISA Violations .................................................. 15 Interpretations of ISA and Related Laws .......................................................................... 17 Implementation of Energy-Related Iran Sanctions ........................................................... 18 Iran Oil Export Reduction Sanctions: Section 1245 of the FY2012 NDAA Sanctioning Transactions with Iran’s Central Bank ............................................................. 20 Implementation ................................................................................................................. 21 Iran Foreign Bank Account “Restriction” Provision ......................................................... 22 Sanctions on Weapons of Mass Destruction, Missiles, and Conventional Arms Transfers ........... 23 Iran-Iraq Arms Nonproliferation Act and Iraq Sanctions Act ................................................. 23 Anti-Terrorism and Effective Death Penalty Act of 1996 ....................................................... 25 Proliferation-Related Provision of the Iran Sanctions Act ...................................................... 25 Iran-North Korea-Syria Nonproliferation Act ......................................................................... 25 Executive Order 13382 on Proliferation-Supporting Entities ................................................. 26 Arms Transfer and Missile Sanctions in the Countering America’s Adversaries through Sanctions Act (CAATSA, P.L. 115-44) ................................................................... 26 Foreign Aid Restrictions for Named Suppliers of Iran............................................................ 27 Sanctions on “Countries of Diversion Concern” ..................................................................... 28 Financial/Banking Sanctions ......................................................................................................... 28 Targeted Financial Measures ................................................................................................... 28 Ban on Iranian Access to the U.S. Financial System/Use of Dollars ...................................... 29 Implementation ................................................................................................................. 29 CISADA: Sanctioning Foreign Banks That Conduct Transactions with Sanctioned Iranian Entities ..................................................................................................................... 30 Implementation of Section 104: Sanctions Imposed ......................................................... 31 Iran Designated a Money-Laundering Jurisdiction/FATF ....................................................... 31 Congressional Research Service Iran Sanctions Use of the SWIFT System ......................................................................................................
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