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Iran sanctions.

Japan/Korean Peninsula/Other East Asia

Since 2010, in part in deference to their alliances with the United States, Japan and South Korea have imposed trade, banking, and energy sanctions on Iran--similar to those of the EU. Both countries have cut imports of Iranian oil sharply since 2011. Some South Korean firms have been active in energy infrastructure construction in Iran but, on December 16, 2011, South Korea banned sales to Iran of energy sector equipment. The main South Korean refiners that import Iranian crude are SK Energy and Hyundai Oilbank.

The U.S. sanctions that require on oil buyers pay Iran in local accounts to avoid U.S. sanctions--a requirement that took effect on February 6, 2013--have not affected Japan and South Korea's trading patterns with Iran significantly. South Korea pays Iran's Central Bank through local currency accounts at its Industrial Bank of Korea and Woori Bank, and its main exports to Iran have been iron and steel, as well as consumer electronics and appliances made by companies such as Samsung and LG. Japan exports to Iran significant amounts of chemical and rubber products, as well as consumer electronics. These exports are continuing using local currency accounts. The two countries also have remitted a large portion of the direct hard currency payments to Iran that are provided for by the JPA.

North Korea

North Korea is an ally of Iran and, like Iran, is a subject of international sanctions. North Korea generally does not comply with international sanctions against Iran, and reportedly cooperates with Iran on a wide range of WMD-related ventures. Press reports in April 2013 said that Iran might supply oil directly to North Korea, but it has not been reported that any such arrangement was finalized. Currently, according to experts, a portion of China's purchases of oil from Iran and other suppliers is re-exported to North Korea.

Singapore and Taiwan

Singapore and Taiwan are U.S. allies and both have cut substantially or ended entirely their oil purchases from Iran since 2012. Iran reportedly has ordered from Singapore (Yangzijiang Shipbuilding Holdings Ltd.) 10 ships that Iran (IRISL) is expected to use to transport iron ore and copper to foreign buyers. (34) The purchased could potentially violate IFCA provisions discussed above.


India has implemented U.N.-mandated sanctions against Iran but its cultural, economic, and historic ties to Iran--and their common interests in Afghanistan--have made the Indian government hesitant to impose sanctions on Iran to the extent the United States and EU have. Yet, India's private sector has come to view Iran as a "controversial market"--a term used by many international firms to describe markets that entail reputational and financial risks.

India began reducing economic relations with Iran in 2010, when India's central bank ceased using a Tehran-based regional body, the Asian Clearing Union, to handle transactions with Iran. In January 2012, Iran agreed to accept India's local currency, the rupee, to settle 45% of its sales to India. That local account funds the sale to Iran of Indian wheat, pharmaceuticals, rice, sugar, soybeans, auto parts, and other products. Still, there is a large trade imbalance, because the oil Iran exports to India are worth far more than the value of the products that India sells to an.

Even though purchases of Iranian oil are financially advantageous because of the barter nature of their trade, India has reduced its imports of Iranian oil substantially since 2011 in an effort to conform to U.S. and EU policy. By mid-2013, Iran was only supplying about 6% of India's oil imports (down from over 16% in 2008)--reflecting significant investment to retrofit refineries that were handling Iranian crude. During a visit to India on June 24, 2013, Secretary of State John Kerry praised India's Iranian oil import cuts as an "important step" in bringing pressure on Iran over its nuclear program. India has received and maintained an exemption from Section 1245 (P.L. 112-81) sanctions, as discussed. As shown in the table later in this report, some Indian firms have ended their investment activity in Iranian oil and gas fields since 2012.

India's weak economy in 2014 could cause U.S.-India differences on Iran sanctions. In mid-August 2013, India's finance minister said that India wants to increase oil imports from Iran. (35) Because Indian firms can pay for Iranian oil partly with rupees, buying Iranian oil helps India conserve its supply of dollars. India reportedly increased shipments from Iran during January-March 2014 to about 320,000 bpd, but U.S. officials say India plans to make cuts during April-June 2014 to bring average purchases in line with the pre-JPA level of about 200,000 bpd.

In 2009, India dissociated itself from an Iran-Pakistan gas pipeline project, discussed below, over concerns about the security of the pipeline, the location at which the gas would be transferred to India, pricing of the gas, and tariffs. During economic talks in early July 2010, Iranian and Indian officials reportedly raised the issue of constructing an underwater natural gas pipeline, which would avoid going through Pakistani territory. However, such a route would be much more expensive to construct than would be an overland route.


A test of Pakistan's compliance with sanctions is a pipeline project intended to carry Iranian gas to Pakistan. Agreement on the $7 billion project was finalized on June 12, 2010, and construction was formally inaugurated in a ceremony attended by the Presidents of both countries on March 11, 2013. With a formally agreed completion date of mid-2014, Iran reportedly has completed the pipeline on its side of the border. Potentially complicating the construction on the Pakistani side of the border is that Pakistan has had difficulty arranging about $1 billion in financing for the project. The day of the ceremony, the State Department reiterated comments during the Bush and Obama Administrations that the project might be sanctioned under ISA. In March 2014, possibly in part because of a Saudi grant to Pakistan that might have been intended to persuade Pakistan to distance itself from Iran, Pakistani officials said U.S. sanctions precluded construction on the Pakistan side of the border. (36) Still, Pakistan is obligated to begin buying gas from Iran as of January 1, 2015, lest it incur a $200 million per month penalty due Iran.

China and Russia

The position of Russia and China, two permanent members of the U.N. Security Council, is that they will impose only those sanctions required by U.N. Security Council resolutions. Russia earns significant revenues from large projects in Iran, such as the Bushehr nuclear reactor, and it also seeks not to provoke Iran into supporting Islamist movements in the Muslim regions of Russia and the Central Asian states. In August 2014, the two countries reportedly agreed to a broad trade and energy deal which might include an exchange of Iranian oil (500,000 barrels per day) for Russian goods. That deal could potentially violate the JPA, if it is implemented as reported, (37) and might serve as leverage for Iran to mitigate the effects of continuing international sanctions. Russia is an oil exporter and a need to preserve oil imports from Iran has not been a factor in its Iran policy calculations. The Iranian oil that Russia might buy under this arrangement would presumably free up additional Russian oil for export.

China has been of concern to U.S. officials because it is Iran's largest oil customer, and therefore its cooperation has been pivotal to U.S. efforts to reduce Iran's revenue from oil sales. U.S.-China negotiations in mid-2012 led to an agreement for China to cut Iranian oil purchases by about 18% from its 2011 average of about 550,000 barrels per day to about 450,000 barrels per day. Under Secretary of State Wendy Sherman and Under Secretary of the Treasury David Cohen testified before the House Foreign Affairs Committee and Senate Foreign Relations Committee on May 15, 2013, that China had cut its buys of oil from Iran by 21% from 2011 to 2012 (to about 435,000 barrels per day). Iran's overall oil exports have fallen slightly further since, as shown in the table. As is the case with other Iranian oil customers, some months might show spikes to higher levels as oil shipments get scheduled. Because China is the largest buyer of Iranian oil, percentage cuts by China have a large impact in reducing Iran's oil sales by volume--explaining State Department's maintenance of China's Section 1245 U.S. sanctions exemption. Several Chinese energy firms invested in Iran's energy sector, but some of these projects have been given to Iranian or other country firms or show little evidence of actual development work.

A February 6, 2013, U.S. sanction requiring that Iran be paid in local currency accounts caused Iran to further increase importation from China. Even before that sanction was imposed, China had begun to settle much of its trade balance with Iran with goods rather than hard currency. Doing so was highly favorable to China financially. Some reports in August 2013 indicated that China might settle some of its Iran oil bill by providing 315 subway cars for the Tehran metro. (38) Press reports indicated that Iran's automotive sector obtains a significant proportion of its parts from China, and two Chinese companies, Geelran and Chery, produce cars in Iran. These exports were reduced substantially during 2013 because of U.S. sanctions, but recovered somewhat after the JPA took effect, which requires easing sanctions on Iran's automotive sector.

Turkey/South Caucasus

The relationship between Turkey and Iran deteriorated after 2011 as both took opposite sides on the Syria civil conflict. However, Turkey remains a significant buyer of Iranian oil; in 2011, it averaged nearly 200,000 bpd. Turkey subsequently reduced those purchases and Turkey received a Section 1245 NDAA sanctions exemption on June 11, 2012, renewed every six months thereafter. Some press reports have accused Turkey's Halkbank of settling much of Turkey's payments to Iran for oil or natural gas with shipments to Iran of gold. U.S. officials testified on May 15, 2013, that Turkey is not paying for its gas imports from Iran with gold, but that the gold going from Turkey to Iran consists mainly of Iranian private citizens' purchases of Turkish gold to hedge against the value of the rial. In line with cuts in Turkey's purchases of Iranian oil, overall bilateral trade fell to $15 billion in 2013 from $22 billion in 2012. On June 9, 2014, Rouhani visited Ankara, accompanied by more than 100 Iranian businessmen, and the two vowed to double bilateral trade to $30 billion by 2015.

Turkey buys natural gas from Iran via a pipeline built in 1997. Turkey is Iran's main gas customer because Iran has not developed a liquefied natural gas (LNG) export capability. During the pipeline's construction, the State Department testified that Turkey would be importing gas originating in Turkmenistan, not Iran, under a swap arrangement, and the State Department did not determine that the project was a violation of ISA. In 2001, direct Iranian gas exports to Turkey through the line began. No ISA sanctions have been imposed, possibly because the State Department views the line as crucial to the energy security of Turkey, which is a key U.S. ally. Prior to the EU decision on October 15, 2012, to bar sales of Iranian gas to Europe, Turkey was also the main conduit for Iranian gas exports to Europe (primarily Bulgaria and Greece). Turkey said in December 2012 that it is constructing a second Iran-Turkey gas pipeline (the work is being performed by Som Petrol). No determination of sanctions violation has been announced. (39)

On January 6, 2014, the Commerce Department issued an emergency order blocking a Turkey-based firm (3K Aviation Consulting and Logistics) from re-exporting two U.S.-made jet engines to Iran. That and other firms reportedly involved in the deal denied that the engines were bound for an Iranian airline (Pouya Airline). (40)

Caucasus: Azerbaijan, Armenia, and Georgia

The Clinton and George W. Bush Administrations used the threat of ISA sanctions to deter oil pipeline routes involving Iran and thereby successfully promoted an alternate route from Azerbaijan (Baku) to Turkey (Ceyhan). The route became operational in 2005. Section 6 of Executive Order 13622 exempts from sanctions under Section 5 of the Order any pipelines that bring gas from Azerbaijan to Europe and Turkey.

In part because Iran and Azerbaijan are often at odds, Iran and Armenia--Azerbaijan's adversary--enjoy extensive economic relations. Armenia is Iran's largest direct gas customer, after Turkey. In May 2009, Iran and Armenia inaugurated a natural gas pipeline between the two, built by Gazprom of Russia. No determination of ISA sanctions has been issued. Armenia has said its banking controls are strong and that Iran is unable to process transactions illicitly through Armenia's banks. (41) However, Azerbaijani officials assert that Iran is using Armenian banks operating in the Armenia-occupied Nagorno-Karabakh territory to circumvent international financial sanctions. These institutions could include Artsakhbank and Ameriabank. (42) In May 2014, Iran and Armenia increased weekly flights between the two from 3 to 50, suggesting that commerce between the two is growing.

Some press reports say that Iran might have used another Caucasian state, Georgia, to circumvent sanctions. IRGC companies reportedly have established 150 front companies in Georgia for the purpose of importing dual-use items, but also to boost Iran's non-oil exports with sales to Georgia of Iranian products such as roofing materials and jams. Iranian firms reportedly are investing in Georgian companies and buying Georgian land. (43) On the other hand, observers assert that since extensive Iran-Georgia economic ties were highly publicized in mid-2013, Georgia has sought and obtained cooperation from its businessmen in reducing transactions with Iran.

Persian Gulf and Iraq (44)

The Persian Gulf countries are oil exporters and close allies of the United States. Those Gulf states with spare oil production capacity, particularly Saudi Arabia, have supplied the global oil market with extra oil to keep prices steady in the face of reduced Iranian oil exports. The Gulf states have generally sought to prevent the re-exportation to Iran of U.S. technology, and have curtailed banking relationships with Iran. On the other hand, in order not to antagonize Iran, the Gulf countries still conduct a wide range of trade with Iran and some Gulf countries allow some sanctioned Iranian banks to operating in their countries. Gulf-based shipping companies such as United Arab Shipping Company have continued to pay port loading fees to such sanctioned IRGC-controlled port operators as Tidewater. (45)

The UAE is particularly closely watched by U.S. officials because of the large presence of Iranian firms there. Several UAE-based firms have been sanctioned for efforts to evade sanctions, as noted in the tables at the end of the report. U.S. officials praised the UAE's March 1, 2012, ban on transactions with Iran by Dubai-based Noor Islamic Bank. Iran reportedly used the bank to process a substantial portion of its oil payments. Some Iranian gas condensate (120,000 barrels per day) reportedly is imported by Emirates National Oil Company (ENOC) and refined into jet fuel, gasoline, and other products.

Iran and Kuwait have held talks on the construction of a 350-mile pipeline that would bring Iranian gas to Kuwait. No construction has been reported. The two have apparently reached agreement on volumes (8.5 million cubic meters of gas would go to Kuwait each day) but not on price. (46) Kuwait's Amir visited Iran in early June 2014.

Iran has sought to use its close relations with Iraq to evade some sanctions. As noted above, the United States sanctioned an Iraqi bank that has cooperated with Iran's efforts, but lifted those sanctions when the bank reduced that business. Iraq presented the United States with a more significant Iran sanctions-related dilemma on July 23, 2013, when it signed an agreement with Iran to buy 850 million cubic feet per day of natural gas through a joint pipeline that reportedly is nearing construction. The pipeline will enter Iraq at Diyala province and feed several power plants. The two countries signed a contract for the pipeline construction in July 2011, and it reportedly is close to completion on both sides of the border; its construction costs are estimated at about $365 million. (47)

The United States has also has pressed Iraq, with limited success, to inspect flights from Iran to Syria to enforce cooperation with U.N. sanctions that ban Iran from exporting arms. The Iraq crisis that began in June 2014 prompted further apparent U.N. sanctions violations by Iran, although Iranian arms supplies to the beleaguered Iraq Security Forces apparently complements U.S. policy. (48)


Some reports say that Iranian currency traders are using Afghanistan to acquire dollars that are plentiful there but in short supply in Iran. Iranian traders--acting on behalf of wealthy Iranians seeking to preserve the value of their savings--are said to be carrying local currency to Afghanistan to buy up some of the dollars available there. There are also allegations that Iran is using an Iran-owned bank in Afghanistan, Arian Bank, to move funds in and out of Afghanistan. The U.S. Treasury Department has warned Afghan traders not to process dollar transactions for Iran. The Special Inspector General for Afghanistan Reconstruction reported in late January 2013 that Afghan security forces might have used some of U.S. aid funds to purchase fuel from Iran. In September 2013, it was reported that Anham FZCO, a U.S. contractor building food storage shelters for U.S. troops in Afghanistan, might have violated U.S. sanctions by transshipping building materials through Iran. (49)

Latin America

Iran, during the term of President Ahmadinejad, looked to several Latin American countries, particularly Venezuela, to try to avoid or reduce the effects of international sanctions. For the most part, however, Iran's trade and other business dealings with Latin America remain modest and likely to reduce the effect of sanctions on Iran only marginally. And, Iran lost a key Latin American ally with the March 2013 death of Venezuelan President Hugo Chavez. As noted elsewhere in this report, several Venezuelan firms have been sanctioned for dealings with Iran.


During the term of Ahmadinejad, Iran sought to cultivate relations with some African countries to try to circumvent sanctions. However, African countries have tended to avoid dealings with Iran in order to avoid pressure from the United States. South Africa has ended its buys of Iranian oil. In June 2012, Kenya contracted to buy about 30 million barrels of Iranian oil, but cancelled the contract the following month after the United States warned that going ahead with the purchase could hurt U.S.-Kenya relations. Tanzania has re-flagged about 6-10 Iranian tankers. Perhaps fearing similar criticism, in September 2012 Sierra Leone removed nine vessels from its shipping register after determining they belonged to IRISL.

World Bank Loans

The July 27, 2010, EU measures narrowed substantially the prior differences between the EU and the United States over international lending to Iran. As noted above, the United States representative to international financial institutions is required to vote against international lending, but that vote, although weighted, is not sufficient to block international lending. No new loans have been approved to Iran since 2005, including several environmental projects under the Bank's "Global Environmental Facility" (GEF). The initiative has slated more than $7.5 million in loans for Iran to dispose of harmful chemicals. (50)

Earlier, in 1993, the United States voted its 16.5% share of the World Bank against loans to Iran of $460 million for electricity, health, and irrigation projects, but the loans were approved. To block that lending, the FY1994-FY1996 foreign aid appropriations (P.L. 103-87, P.L. 103-306, and P.L. 104-107) cut the amount appropriated for the U.S. contribution to the bank by the amount of those loans. The legislation contributed to a temporary halt in new bank lending to Iran. In the 111th Congress, a provision of H.R. 6296--Title VII--cut off U.S. contributions to the World Bank, International Finance Corp., and the Multilateral Investment Guarantee Corp. if the World Bank approves a new Country Assistance Strategy for Iran or makes a loan to Iran.

During 1999-2005, Iran's moderating image had led the World Bank to consider new loans over U.S. opposition. In May 2000, the United States' allies outvoted the United States to approve $232 million in loans for health and sewage projects. During April 2003-May 2005, a total of $725 million in loans were approved for environmental management, housing reform, water and sanitation projects, and land management projects, in addition to $400 million in loans for earthquake relief.

Private-Sector Cooperation and Compliance

The imposition of sanctions on Iran by many governments has caused Iran to be viewed by many worldwide corporations as a "controversial market"--a market that carries political and reputational risks. On the other hand, travelers to Iran say many foreign products, including U.S. products, are readily available in Iran, suggesting that such products are being re-exported to Iran from neighboring countries. Examples of major non-U.S. companies that, prior to the JPA, had discontinued business with Iran include the following:

* ABB of Switzerland said in January 2010 it would cease doing business with Iran. Siemens of Germany followed suit in February 2010. Finemeccanica, a defense and transportation conglomerate of Italy, and Thyssen-Krupp, a German steelmaker, subsequently left the Iran market as well. Indian conglomerate Tata is ending its Iran business.

* Selling cars to Iran has not been sanctionable at any time, Yet, in 2010, the following firms suspended such sales: Germany's Daimler (Mercedes-Benz) and Porsche; Toyota (Japan); Fiat (Italy); and South Korea's Hyundai, and Kia Motors.

* As of 2007, BNP Paribas of France ceased pursuing new business in Iran, according to attorneys for the company.

* The State Department reported on September 30, 2010, that Hong Kong company NYK Line Ltd. had ended shipping business with Iran on any goods. On June 30, 2011, the Danish shipping giant Maersk said that it would no longer operate out of Iran's three largest ports. The firm's decision reportedly was based on the U.S. announcement on June 23, 2011, of sanctions on the operator of those ports, Tidewater Middle East Co., under Executive Order 13382.

* Well before Executive Order 13590 was issued (see above), one large oil services firm, Schlumberger, incorporated in the Netherlands Antilles, said it would wind down its business with Iran. (51)

Foreign Subsidiaries of U.S. Firms That Have Exited the Iran Market

Many foreign subsidiaries of U.S. firms had exited the Iran market voluntarily, before any of their business activities with Iran became sanctionable (for example sales to Iran of equipment that can be used in Iran's oil, gas, and petrochemicals sectors).

* Chemical manufacturer Huntsman announced in January 2010 its subsidiaries would halt sales to Iran.

* On January 11, 2005, Iran said it had contracted with U.S. company Halliburton, and an Iranian company, Oriental Kish, to drill for gas in Phases 9 and 10 of South Pars. Halliburton reportedly provided $30 million to $35 million worth of services per year through Oriental Kish, leaving unclear whether Halliburton would be considered in violation of the U.S. trade and investment ban or the Iran Sanctions Act (ISA), (52) because the deals involved a subsidiary of Halliburton (Cayman Islands-registered Halliburton Products and Service, Ltd., based in Dubai). On April 10, 2007, Halliburton announced that its subsidiaries were no longer operating in Iran, as promised in January 2005.

* General Electric (GE) announced in February 2005 that it would seek no new business in Iran, and it reportedly wound down preexisting contracts by July 2008. GE was selling Iran equipment and services for hydroelectric, oil, and gas services. However, GE subsidiary sales of medical diagnostic products such as MRI machines, sold through Italian, Canadian, and French subsidiaries, are not generally sanctionable and are believed to be continuing.

* On March 1, 2010, Caterpillar Corp. said it had altered its policies to prevent foreign subsidiaries from selling equipment to independent dealers that have been reselling the equipment to Iran. (53) Ingersoll Rand, maker of air compressors and cooling systems, followed suit. (54)

* In April 2010, it was reported that foreign partners of several U.S. or other multinational accounting firms had cut their ties with Iran, including KPMG of the Netherlands, and local affiliates of U.S. firms PricewaterhouseCoopers and Ernst and Young. (55)

* Oilfield services firm Smith International said on March 1, 2010, it would stop sales to Iran by its subsidiaries. Another oil services firm, Flowserve, said its subsidiaries have voluntarily ceased new business with Iran as of 2006. (56) FMC Technologies took similar action in 2009, as did Weatherford (57) in 2008. However, in November 2013, Weatherford was fined by the Treasury Department for violating sanctions against Iran and other countries.

Foreign Firms Reportedly Remaining in the Iran Market

Still, many major firms continue to do business with Iran, including major consumer products companies of Europe and Asia. Some of the foreign firms that trade with Iran, such as Mitsui and Co. of Japan, Alstom of France, and Schneider Electric of France, are discussed in a March 7, 2010, New York Times article on foreign firms that do business with Iran and also receive U.S. contracts or financing. The Times article does not claim that these firms have violated any U.S. sanctions laws. Internet and communications-related foreign firms remaining in or having departed the Iranian market are discussed in the section below on human rights effects of sanctions.

Some foreign firms still active in Iran are subsidiaries of U.S. firms and some of them also received U.S. government contracts, grants, loans, or loan guarantees. They include:

* An Irish subsidiary of the Coca Cola Company, which provides syrup for the U.S.-brand soft drink to an Iranian distributor, Khoshgovar. Local versions of both Coke and of Pepsi (with Iranian-made syrups) are also marketed in Iran by distributors who licensed the recipes for those soft drinks before the Islamic revolution and before the trade ban was imposed on Iran.

* Via a Swiss-based subsidiary, Transammonia Corp. conducts business with Iran to help it export ammonia, a growth export for Iran.

* Kansas-based Koch Industries may have sold equipment to Iran to be used in petrochemical plants (making methanol) and possibly oil refineries, until 2007. Sales of refinery equipment to Iran were later made sanctionable under ISA. (58)

* Some subsidiaries of U.S. energy equipment and energy-related shipping firms were in the Iranian market as late as 2010, including Natco Group, (59) Overseas Shipholding Group, (60) UOP (United Oil Products, a Honeywell subsidiary based in Britain), (61) Itron, (62) Fluor, (63) Parker Drilling, Vantage Energy Services, (64) PMFG, Ceradyne, Colfax, Fuel Systems Solutions, General Maritime Company, Ameron International Corporation, and World Fuel Services Corp. UOP reportedly sold refinery gear to Iran. However, as of mid-2010 almost all energy sector-related sales to Iran are sanctionable and these companies have most likely exited the Iranian market.

Effectiveness of Sanctions on Iran

The following sections examine the effectiveness of sanctions on a variety of criteria and goals. These issues are discussed in depth in CRS Report R43492, Achievements of and Outlook for Sanctions on Iran, by Kenneth Katzman.

Effect on Iran's Nuclear Program Decisions and Capabilities

Many experts interpret Iran's acceptance of the JPA as evidence that sanctions contributed substantially to a shift in Iran's nuclear policies. The agreement came after the June 14, 2013, presidential election in Iran in which Iranians elected the relatively moderate mid-ranking cleric Hassan Rouhani as president; he ran on a platform of achieving an easing of sanctions and ending Iran's international isolation. However, Director of National Intelligence James Clapper testified in his "Worldwide Threat Assessment" presentation to Congress on January 29, 2014, that Iran's ultimate nuclear intentions remain "unclear." A comprehensive solution on Iran's nuclear program has been under negotiation between Iran and the "P5+1" countries (United States, Britain, France, Russia, China, and Germany) since February 2014 but did not reach agreement by the JPA expiration date of July 20, 2014. Based on reported progress in the negotiations, Iran and the P5+1 exercised the provision of the JPA to extend it for up to six months--opting for a four-month extension until November 24, 2014. Negotiations are ongoing.

Effects on Iran's Strategic Programs and Regional Influence

Another issue is whether sanctions have weakened Iran strategically. One aspect of that question is whether sanctions have prevented Iran from acquiring needed technology or skills for its nuclear program or its missile or advanced conventional weapons programs. Some U.S. officials have asserted that sanctions have complicated Iran's efforts to acquire key equipment for its enrichment program, (65) but not to the point where Iran has been unable to develop more advanced centrifuges and expand its uranium enrichment program, as discussed in reports by the International Atomic Energy Agency (IAEA). Director of National Intelligence James Clapper has testified that Iran continues to expand the scale, reach, and sophistication of its ballistic missile arsenal. On March 16, 2014, Principal Deputy Assistant Secretary of State for International Security and Non-Proliferation Vann Van Diepen said Iran was still "very actively" creating front companies and engaging in other activity to conceal procurements, and that Iran's procurement activities had not changed since the JPA was agreed to. (66) See also CRS Report R40094, Iran's Nuclear Program: Tehran's Compliance with International Obligations, by Paul K. Kerr, and CRS Report R42849, Iran's Ballistic Missile and Space Launch Programs, by Steven A. Hildreth.

Sanctions might have eroded those aspects of Iran's conventional military capabilities that are most dependent on foreign supplies, but the effect of sanctions on Iran's overall military capacity is not clear. Resolution 1929 of June 2010 prohibited the sale to Iran of major combat systems, and there have been no reports of sales to Iran of tanks or combat aircraft since then. However, Iran might have acquired some ships and small submarines, (67) and Iran is able to produce some advanced conventional weaponry indigenously, including short range ballistic and cruise missiles.

Sanctions do not appear to have materially reduced Iran's ability to arm militant movements in the Middle East and the Syrian regime. As noted above, Iran reportedly is also exporting military equipment to the embattled government of Iraq in the wake of the Islamic State offensive in June 2014. Iran's arms exports contravene Resolution 1747, which bans Iran's exportation of arms. (68) The State Department report on international terrorism for 2013, released April 30, 2014, said Iran also has exported arms to factions in Yemen and to militant Palestinian Islamist factions, and has sought to supply arms to radical Shiite factions in Bahrain.

General Political Effects

Sanctions might have produced some political change in Iran. The support of Iranians seeking change--and an easing of sanctions--helped power the most moderate candidate in the race, Rouhani, to a first round victory. The Supreme Leader welcomed Rouhani's election and has publicly backed the JPA and subsequent negotiations on a comprehensive solution, while at the same time expressing skepticism about the prospects for an agreement.

No U.S. Administration has stated that sanctions on Iran are intended to bring about the change of Iran's regime. However, some Iran sanctions advocates have stated that outcome should be the goal of the sanctions. The major unrest in Iran in 2009 was, by all accounts, a response to repression and alleged fraud in the June 2009 re-election of Mahmoud Ahmadinejad as president--and not to international sanctions. Since 2012 there have been labor and public unrest over escalating food prices and the dramatic fall of the value of Iran's currency. But the unrest has not been sufficiently large or sustained to threaten the regime.

Human Rights-Related Effects

Some see sanctions as a tool to compel improvement in human rights practices in Iran, but the connection between sanctions and any trends in Iran's human rights practices is unclear. The State Department human rights report for 2013, released February 27, 2014, contains many of the same criticisms of Iran's human rights practices as do the reports for previous years. That and other reports note that President Rouhani has released a few political prisoners and press reports say media freedoms have increased slightly since he took office. However, executions have, by some accounts, become more frequent.

Sanctions have apparently not reduced the regime's ability to monitor and censor use of the Internet, even though some major telecommunications equipment firms have exited the Iran market. Among those exiting are German telecommunications firm Siemens, which announced on January 27, 2010, that it would stop signing new business deals in Iran as of mid-2010. (69) Chinese Internet infrastructure firm Huawei announced in December 2011 that it was withdrawing its sales staff from Iran. A South African firm, MTN Group, owns 49% of a private cellular phone network, Irancell, and was accused by some groups of helping the Iranian government shut down some social network services during the 2009 protests in Iran. (70) On August 8, 2012, MTN announced it would leave Iran. On October 11, 2012, Eutelsat, a significant provider of satellite service to Iran's state broadcasting establishment, ended that relationship following EU sanctioning in March 2012 of the head of the Islamic Republic of Iran Broadcasting (IRIB) Ezzatollah Zarghami. The GAO report of January 7, 2014, did not identify any foreign firms that exported technology to Iran for monitoring, filtering, or disrupting information and communications flow from October 1, 2012, to November 7, 2013. (71)

Some major telecommunications firms have remained in the Iran market, although it is not clear whether their products help either the regime or the opposition. They include Deutsche Telekom, Ericsson, Emirates Telecom, LG Group, NEC Corporation, and Asiasat.

Economic Effects

Sanctions have taken a dramatic toll on Iran's economy, by almost all accounts, and amplified the effect of Iran's own mismanagement, according to experts. Indicators of the economic effect of sanctions are discussed below:

* GDP Decline. Sanctions caused Iran to suffer its first gross domestic product (GDP) contraction in two decades--about 5% contraction in 2013. Under Secretary of the Treasury for Terrorism and Financial Intelligence David Cohen testified before the Senate Foreign Relations Committee on July 29, 2014, that Iran's economy is 25% smaller than it would have been had post-2010 sanctions not been imposed. Many Iranian businesses failed, the number of non-performing loans held by Iranian banks increased to about 15%-30%, (72) and many employees in the private sector have gone unpaid or are subject to long delays in payments.

The unemployment rate is about 20%, although the Iranian government reported that the rate at 13%.

* The sanctions relief of the JPA has stabilized the economy somewhat--Iran's economy is expected to achieve slight growth of about 1%-1.5% for all of 2014, according to the International Monetary Fund. However, the sanctions relief has not been sufficient to produce a strong economic rebound. Treasury Secretary Jack Lew said on June 16, 2014, that "Iran's economy remains in a state of distress that brought the government to the negotiating table in the first place." (73)

* Oil Exports. As noted in Table 2, sanctions drove Iran's oil sales down about 60% from the 2.5 mbd of sales in 2011, reducing Iran's crude oil sales revenue from $100 billion in 2011 to about $35 billion in 2013. The JPA specifies that Iran's oil sales remain constant at about 1 mbd for the six-month duration of the deal. (State Department officials say that 1.1 mbd of exports would be within their interpretation of the JPA limit.) (74) International Energy Agency (IEA) and other data indicate that Iran's exports of crude oil are within that prescribed range. Deputy Assistant Secretary of State Amos Hochstein testified before the House Foreign Affairs Committee on June 11, 2014, that "So far [in JPA implementation], as we look at the [Iranian crude oil export] numbers, we are comfortable [that] at the moment, those numbers ... are kept to that range of 1 million to 1.1 million barrels a day." Iran exports about 100,000 barrels per day of oil to Syria, but receives no revenue from those sales.

* Falling Oil Production. At the time the JPA began implementation, Iran's oil production had fallen to about 2.6-2.8 mbd from the level of nearly 4.0 mbd at the end of 2011. (75) Iran has tried to avoid further production cuts by storing as many as 30 million barrels of unsold crude oil on tankers in the Persian Gulf, and it built additional storage tanks on shore. U.S. officials say that production is holding steady at this lower level and that Iran has largely succeeded in preventing damage to shut or inactive wells.

* Hard Currency Inaccessible. Not only have Iran's oil exports fallen by volume, but Iran has not been paid in hard currency for its oil and is unable to access most of its hard currency held in accounts abroad. Prior to the implementation of the JPA, about $1.5 billion per month was accumulating in foreign accounts, out of about $3.4 billion in the total value of monthly oil sales (76)--in part because Iran cannot always identify a sufficient amount of goods in those countries to import to make use of all the oil money it receives. Iran's hard currency reserves are estimated to be nearly $100 billion, of which as much as $80 billion cannot be repatriated due to compliance by banks with U.S. sanctions. About $20 billion is believed to be accessible--aside from the $700 million per month Iran has received directly since the JPA became effective.

* Currency Decline. Sanctions caused the value of the rial on unofficial markets to decline from about 13,000 to the dollar in September 2011 to about 40,000 as of October 2012. The unofficial rate was about 37,000 to the dollar in May 2013, but optimism over Rouhani's presidency and the JPA caused the rial to appreciate to about 29,000 to the dollar as of the start of 2014 and to remain roughly at that level.

* Inflation. The drop in value of the currency caused inflation to accelerate during 2011-2013. The Iranian Central Bank acknowledged an inflation rate of 45% in July 2013, but many economists asserted that the actual inflation rate was 50% and 70%. The sanctions relief of the JPA has helped reduce that to about 35%, and is projected to fall further to about 25% by March 2015, according to some economists. (77) Some assert that inflation was fed by the policies of Ahmadinejad, particularly the substitution of subsidies with cash payments, rather than the effect of sanctions.

* Industrial Production. Iran's economy is widely assessed as industrializing, but the manufacturing sector remains dependent on imported parts. The currency decline and financial sanctions have made it difficult for that sector to operate. Many Iranian manufacturers are unable to obtain credit and must pre-pay, often through time-consuming and circuitous mechanisms, to obtain parts from abroad. This difficulty is particularly acute in the automotive sector; Iran's production of automobiles fell by about 40% from 2011 to 2013. The JPA has benefited the auto sector because of the sanctions easing on that sector, but press reports say that manufacturing overall has rebounded only modestly since the JPA implementation began.

Sources of Economic Strength and Coping Strategies

Prior to the JPA, Iran had mixed success mitigating the economic effect of sanctions. It has undertaken some measures to mitigate the effects of sanctions. And, some economists assess that Iran has key inherent economic strengths, including an educated workforce--including the highest percentage of engineering graduates in the world--that is familiar with the use of the Internet and other modern technologies.

Non-Oil Exports. Iran's primary strategy has been to substitute for crude oil sales by increasing sales of non-oil products. Some of the non-oil exports that have grown include minerals, cement, urea fertilizer, and other agricultural and basic industrial goods. The main customers for Iran's non-oil exports reportedly are countries in the immediate neighborhood, including Iraq, Afghanistan, and Armenia.

Oil Products/Condensate Sales. Iran has sought to increase sales of oil products such as petrochemicals and condensates. Petrochemical sales are allowed, with no restrictions on volumes, under the JPA, and the JPA's cap on Iranian oil exports apparently does not apply to condensate sales. Condensates are petroleum by-products that can be used to make such fuels as aviation fuel or plastics. Iran exports the equivalent of about 300,000 barrels per day of crude oil in condensates. (78) The main buyers are the same as Iran's main oil customers. Still, these exports have not come close to compensating for the loss of crude oil revenues.

Reallocation of Investment Funds and Import Substitution. Iranian manufacturers have increased production of some goods that Iranians are buying as they cut back on purchases of imported goods. This trend is considered positive by Iranian economists that have long maintained that Iran should expand its own manufacturing capability and reduce dependence on oil revenues and imported goods. In addition, some private funds are going into the Tehran stock exchange and hard assets, such as property. However, many of these trends generally benefit the urban elite.

Subsidy Reductions. In 2007, Ahmadinejad's government instituted a program to wean the population off of generous subsidies by compensating families with cash payments of about $40 per month. Gasoline prices began to run on a tiered system that brought them closer to regional prices--and far above the subsidized price of 40 cents per gallon. However, as sanctions began to crimp government revenues, in late 2012 Ahmadinejad postponed "phase two" of the subsidy phase-out effort. In April 2014, Rouhani instituted phase two by raising gasoline prices further and limiting the cash payments to only those families who could claim financial hardship.

Import Restrictions. To conserve hard currency, Iran has reduced the supply of hard currency to importers of luxury goods, such as cars or cellphones (the last two of the government's 10 categories of imports, ranked by importance)--conserving its supply for the purchase of essential imports. Iranian importers of essential goods were able to obtain dollars at the official "reference" rate of 12,260 to the dollar, although the regime reportedly raised that rate to about 28,000 to the dollar in late June 2013--closer to the free market rate.

Effect on Energy Sector Long-Term Development

Sanctions have been intended, in part, to reduce Iran's oil and gas production capacity over the longer term. The sanctions took advantage of the fact that Iran's oil fields are aging and in need of outside technology and investment to maintain, let alone boost, production. U.S. officials estimated in 2011 that Iran had lost $60 billion in investment in the sector as numerous major firms have announced pullouts from some of their Iran projects, declined to make further investments, or resold their investments to other companies. Iran says it needs $130-$145 billion in new investment by 2020 to keep oil production capacity from falling. (79) Of that amount, continued development of the large South Pars gas field alone requires $100 billion. (80)

Even though some international firms remain invested in Iran's energy sector, observers at key energy fields in Iran say there is little evidence of foreign company development activity sighted at Iran's various oil and gas development sites, as discussed in Table 5. The declining foreign activity appears to be a product of international firms' decisions not to risk triggering U.S. sanctions. Some of the ongoing investments have avoided sanctions either through Administration waivers or invocation of the "special rule" (see above). Other ongoing foreign investment projects have not been determined as ISA violations and may be under State Department investigation.

Some foreign investors have left the Iran market entirely, and their work has been picked up by domestic companies, particularly those controlled or linked to the Revolutionary Guard (IRGC). Foreign firms are reluctant to partner with IRGC firms as international sanctions have increasingly targeted the IRGC. The energy companies still active in Iran, particularly the Iranian firms, are reportedly not as technically capable as the international firms that have withdrawn.

No easing of sanctions on investing in Iran's energy sector is permitted in the JPA, but there are numerous reports of international firms' talking with Iranian energy officials to plan for the possibility that this sanction will be lifted as part of a comprehensive nuclear deal. Iran is reportedly working actively to lure foreign investors back into the sector, including by hiring back many of the former officials that successfully negotiated such past investments.

Others maintain that Iran's gas sector can compensate for declining oil exports, although Iran has used its gas development primarily to reinject into its oil fields rather than to export. Iran exports about 3.6 trillion cubic feet of gas, primarily to Turkey and Armenia. On the other hand, sanctions have rendered Iran unable to develop a liquefied natural gas (LNG) export business. EU sanctions have also derailed several gas ventures, including BP-NIOC joint venture in the Rhum gas field, 200 miles off the Scotland coast, and inclusion of Iran in planned gas pipeline projects to Europe.

Effect on Gasoline Availability and Importation

In March 2010, well before the enactment of CISADA, several suppliers announced that they had stopped or would stop selling gasoline to Iran. (81) Others have ceased since the enactment of CISADA. Some observers say that gasoline deliveries to Iran fell from about 120,000 barrels per day before CISADA to about 30,000 barrels per day immediately thereafter, although importation later increased to about 50,000 barrels per day. The GAO report of January 7, 2014, identified no foreign firms selling Iran gasoline between October 1, 2012, and November 7, 2013, suggesting that a phaseout of gasoline subsidies has reduced demand for gasoline and that Iran has increased domestic production.

Humanitarian Effects/Air Safety

Humanitarian-related effects of sanctions have been noted in several sectors, and some of the sanctions easing in the interim nuclear deal are intended to mitigate these effects. Press reports have mounted since mid-2012 that sanctions are hurting the population's ability to obtain Western-made medicines, such as expensive chemo-therapy medicines, and other critical goods. Some of the scarcity is caused by banks' refusal to finance such sales, even though doing so is technically allowed under all applicable sanctions. Some observers say the Iranian government is exaggerating reports of medicine shortages to generate opposition to the sanctions. Other accounts say that Iranians, particularly those with connections to the government, are taking advantage of medicine shortages by cornering the market for importing key medicines.

Some human rights and other groups have suggested potential solutions. The JPA provides for the international community to provide enhanced financial channels for Iran to import medicines, although the exact mechanism for such facilitation remains unclear. It was reported in late July 2014 that the U.S. Administration had reached out to European medical firms and asked them to expedite sales of medical goods to Iran. The Administration reportedly cleared banks in Switzerland and Japan to process financing for the shipments. (86)

In the aviation sector, some Iranian pilots have complained publicly and stridently that U.S. sanctions are causing Iran's passenger airline fleet to deteriorate to the point of jeopardizing safety. Since the U.S. trade ban was imposed in 1995, 1,700 passengers and crew of Iranian aircraft have been killed in air accidents, although it is not clear how many of the crashes, if any, were due to difficultly in acquiring U.S. spare parts. (87) The JPA provides for new sales of civilian aircraft parts to address this issue and Boeing and GE have applied for and obtained licenses to make some spare part sales to Iranian airlines.

Other reports say that pollution in Tehran and other big cities has worsened because Iran is making gasoline itself with methods that cause more impurities than imported gasoline. As noted above, Iran's efforts to deal with environment hazards and problems might be hindered by denial of World Bank lending for that purpose.

Post-JPA Sanctions Debate

U.S. officials have said that the JPA requires "limited, temporary, targeted, and reversible" easing of international sanctions. And, despite such developments as the visits to Iran of business delegations, U.S. officials say there has not been any significant decline in international compliance with the sanctions regime since JPA implementation began in January 2014.

The JPA (including its extension to November 24, 2014) provides for the following sanctions easing. (88) The relief was estimated to provide Iran with about $7 billion in total sanctions relief for the six-month JPA period (January 20-July 20, 2014), and then another approximately $4.3 billion for the four-month extension until November 24, 2014. Under the JPA:

* Iran's oil exports are to remain at the level of about 1 million barrels per day. This implies that Iran's current oil customers will not reduce their oil purchases from Iran "significantly" during the interim period--such reduction is a requirement to avoid sanctions on the banks of those countries under Section 1245 of P.L. 112-81. To avoid penalizing these oil buyers, the Administration has exercised waiver authority under Section 1245(d)(1) of the National Defense Authorization Act for FY2012 (P.L. 112-81) and Section 1244c(1) of the Iran Freedom and Counter-Proliferation Act of 2012 ("IFCA," Title XII, subtitle D, of the FY2013 National Defense Authorization Act, P.L. 112-239); the Administration has said it will not impose sanctions on foreign banks under Executive Orders 13622, 13645, and 13382 and related regulations. Waivers of Section 302(a) of the Iran Threat Reduction and Syria Human Rights Act of 2012 (P.L. 112-158) and of Section 5(A)(7) of the Iran Sanctions Act (P.L. 104-172, as amended) have been issued to permit transactions with Iran's national oil company (NIOC). The European Union has based its own regulations to allow shipping insurers to provide insurance for ships carrying oil from Iran. (89) It should be noted that the waivers and sanctions suspensions under the JPA do not permit U.S. companies trading in such goods with Iran, but rather suspend U.S. sanctions on foreign companies that trade in such goods with Iran.

* Iran was able to repatriate about $4.2 billion in oil sales proceeds during the first six-month JPA period, and will repatriate $2.8 billion for the four-month extension period. Iran is also able to use an additional $400 million of oil earnings to make tuition payments for Iranian students abroad (and another $300 million for the four-month extension period). Under the agreed JPA implementation plan, Iran accesses the hard currency in installments of $500 million or $450 million. The schedule was initially programmed to ensure that Iran completes at least the early stages of implementation, including diluting its 20% enriched uranium, before too much of the funds are released. The waiver authority under Section 1245(d)(1), discussed above, enables Iran to receive the oil proceeds installments directly.

* The JPA permits Iran to resume sales of petrochemicals and trading in gold and other precious metals, and to resume transactions with foreign firms involved in Iran's automotive manufacturing sector. The Administration estimates the value of the revenue Iran will accrue from these changes during the six months of the interim arrangement at about $2 billion, and for the four-month extension to produce an additional $1.3 billion in revenue. To enable these transactions, the Administration suspended application of Executive Orders 13622 and 13645, several provisions of U.S. trade regulations with Iran, and several sections of IFCA.

* The parties to the JPA pledged to facilitate humanitarian transactions that are already allowed by U.S. and partner country laws, such as sales of medicine to Iran, but which many banks refuse to finance. The United States also committed to license safety-related repairs and inspections inside Iran for certain Iranian airlines. Such licensing is specifically permitted under U.S. trade regulations written pursuant to Executive Order 12959 (May 6, 1995) and Executive Order 13059 (August 19, 1997) that impose a ban on U.S. trade with and investment in Iran. However, several Iranian airlines, including Iran Air, have been designated for sanctions under Executive Order 13382, which blocks U.S.-based property of entities designated as "proliferation supporters." To implement this commitment, the Administration issued a new "Statement of Licensing Policy" to enable U.S. aircraft manufacturers to sell the appropriate equipment to Iranian airlines and, as noted above, Boeing and GE have applied for such licenses. The Administration has suspended application of Executive Order 13382 and certain provisions of U.S. trade regulations with Iran to allow the supply of equipment to Iran Air. Steps to facilitate humanitarian shipments to Iran are discussed above.

* The P5+1 and Iran agreed to set up a Joint Commission whose tasks will include evaluating P5+1 compliance with its commitments for sanctions relief. The commission is empowered to consider Iranian complaints about foreign firms that Tehran believes have been sanctioned inappropriately for commercial interactions with Iran.

* The JPA requires that the P5+1 "not impose new nuclear-related sanctions," if Iran abides by its commitments under this deal, to the extent permissible within their political systems. (90)

Permanent Sanctions Easing?

A comprehensive nuclear deal between Iran and the P5+1 would include a broad easing of international sanctions against Iran. The JPA indicates that "nuclear-related" sanctions would be eased in a comprehensive deal, but in practice many sanctions are related to Iran's nuclear program even if they are not proliferation-related sanctions specifically. As of October 2014, Iran reportedly is demanding that a comprehensive agreement ease those sanctions imposed in recent years (since 2011) for the specific purpose of compelling Iran to agree to reduce the scope of its nuclear program. Those sanctions include those that limit its oil and oil products exports, its use of the international financial system, and its receipt and repatriation of hard currency. Iran appears to have acquiesced that a nuclear deal will not immediately result in the easing of sanctions addressing purely human rights and Iranian foreign policy issues, or longer-term investment in Iran's energy sector.

The Administration has said that, at least initially to implement a nuclear deal, it would use the waiver and other authority to suspend application of sanctions on Iran that has been discussed in this report. (91) Iran reportedly will be satisfied, at least over the near term, with suspension of sanctions rather than outright lifting. U.S. officials assert that, after Iran's compliance is tested over a period of time (about one year, according to some observers), the Administration would ask Congress to repeal or terminate those sanctions that cannot be lifted through Administration action alone. (92) The requirements for lifting sanctions are discussed in this report, in CRS Report R43311, Iran: U.S. Economic Sanctions and the Authority to Lift Restrictions, by Dianne E. Rennack, and in a reported Treasury Department report that has not been released. (93) In a background briefing on the eve of March 17, 2014, talks with Iran on a comprehensive deal, a senior Administration official said
   we are doing a considerable amount of work, including consultations
   with the Congress, in that regard. We need to understand in great
   detail how to unwind sanctions and what--under what authorities and
   what can be done by the Executive Branch, what can be done by
   waivers, what will need congressional action.... any sanctions
   relief, should we get to a comprehensive agreement, will be phased
   in and will be in response to actions that Iran takes. (94)

Some in Congress have sought to provide for a congressional vote on any comprehensive agreement reached--a proposal the Administration has opposed. The Administration also has opposed attempts by some in Congress to link release of the $2.8 billion in hard currency during the JPA extension period to certification that Iran is not using those funds to support Hamas, Hezbollah, the regime of Asad of Syria, and other groups. Such linkage is proposed in S. 2667.

Possible Additional Sanctions

Should no comprehensive nuclear deal be reached and Iran resume pre-JPA nuclear activities such as producing 20% enriched uranium, the Administration and many in Congress have indicated they seek to impose additional sanctions on Iran. Additional sanctions legislation already pending in the 113th Congress are discussed below.

H.R. 850 and S. 1881

Two pending bills could affect the course of nuclear negotiations with Iran and could advance if negotiations on a comprehensive settlement break down. S. 1881, the "Nuclear Weapon Free Iran Act of 2013," was introduced on December 19, 2013. The operative provisions are similar to those of H.R. 850, a House bill that was passed 400-20 in July 2013, before the interim nuclear agreement.

* Both bills contain virtually identical provisions to require those countries that have exemptions allowing them to pay Iran's Central Bank for oil to accelerate their Iran oil import reductions to an aggregate cut of an additional 1 million barrels per day within one year of enactment. Countries that do not "dramatically reduce" their Iran oil buys would lose their exemptions.

* Both bills expand the proportion of the Iranian economy for which transactions are sanctionable (under IFCA; P.L. 112-239). H.R. 850 references the automotive and mining sectors; S. 1881 references the shipbuilding, construction, engineering, and mining sectors--defining them, along with the energy and shipping sectors, as "strategic sectors."

* H.R. 850 authorizes, but does not mandate, sanctions for conducting financial transaction with Iran's Central Bank or other sanctioned Iranian banks for trade with Iran in any goods.

* Both bills would sanction foreign banks that help Iran exchange its foreign currency abroad--a provision identical to S. 892 (introduced on May 8, 2013).

* H.R. 850 would require the Administration to determine whether the Revolutionary Guard should be named a Foreign Terrorist Organization.

* S. 1881 contains provisions to delay the effective date of the sanctions beyond the duration of the interim nuclear deal (which expires July 19, 2014, based on implementation start on January 20). The sanctions contained in S. 1881 can be delayed for 180 days, provided the President certifies Iran is implementing the interim nuclear agreement, is negotiating in good faith on a final deal, has not (directly or through proxies) supported an act of terrorism against the United States, and has not conducted any tests of ballistic missiles of over 500 kilometer range. The suspension can be continued for an additional 60 days (two 30-day extensions) if the President certifies that a comprehensive deal that would "terminate" Iran's "illicit" nuclear program is imminent. The sanctions suspension would end if the President cannot submit a certification that Iran is fully implementing the interim nuclear deal. A waiver provision enables the President to forestall reinstatement of the act's sanctions.

* S. 1881 also provides for sanctions to be suspended if there is a final comprehensive nuclear agreement. The sanctions in the bill can be suspended for one year, with additional one-year periods, if the President certifies there is a final deal under which Iran agrees to dismantle its "illicit" nuclear infrastructure, is brought into compliance with U.N. Security Council resolutions, resolves all issues of possible military dimensions of its nuclear program, and permits constant monitoring of all "suspect" facilities in Iran. Under S. 1881, this sanctions suspension could be terminated if Congress enacts a joint resolution of disapproval. None of these delay provisions are contained in H.R. 850, which was passed by the House before the interim nuclear deal was reached.

Supporters of these bills have expressed mistrust of Iranian intentions, perhaps partly based on past nuclear discussions with Iran. Some Members say they doubt that the negotiating process will produce a result that ensures that Iran's nuclear program can only be used for peaceful purposes.

The Administration argues that imposing new sanctions while the JPA is still in effect--no matter the effective date of the provisions--could split the international coalition that negotiated it. The Administration argues that some countries could end their cooperation with international sanctions if they perceive that the United States is not upholding the JPA pledge not to increase nuclear sanctions. (95) After the JPA was agreed, Iran's Foreign Minister Mohammad Javad Zarif said in an NBC interview that any U.S. imposition of new sanctions during the JPA period would void the deal. That Iranian position has been reiterated since the introduction of S. 1881. Other critics say that S. 1881 adds requirements to avoid new sanctions that are not in the interim deal--particularly that Iran not test new longer-range missiles. Others say S. 1881 imposes unattainable conditions on a final nuclear deal--that Iran's nuclear infrastructure be eliminated. Supporters of the bill say that the term "illicit" allows flexibility to allow Iran to continue some enrichment as part of a final deal. The President has said he will veto S. 1881 if it is passed by both chambers.

Other Possible U.S. and International Sanctions

There are a number of other possible sanctions that might receive consideration--either in a global or multilateral framework--presumably if the interim nuclear deal is not translated into a permanent deal and Iran continues to develop its nuclear program.

* Sanctioning All Trade with Iran. Some organizations, such as United Against Nuclear Iran, advocate sanctions against virtually all trade with Iran, with exceptions for food and medical products. The concept of a global trade ban on Iran has virtually no support in the United Nations Security Council, and U.S. allies strongly oppose U.S. measures that would compel allied firms to end commerce with Iran in purely civilian, non-strategic goods.

* Comprehensive Ban on Energy Transactions with Iran. Many experts believe that a U.N.-mandated, worldwide embargo on the purchase of any Iranian crude oil would put significant pressure on Iran. Even before the interim nuclear deal, the concept lacked sufficient support in the U.N. Security Council. Some advocate a U.N. Security Council ban on all investment in and equipment sales to Iran's energy sector. During the 1990s, U.N. sanctions against Libya for the Pan Am 103 bombing banned the sale of energy equipment to Libya.

* Iran Oil Free Zone. Prior to the EU oil embargo on Iran, there was discussion of forcing a similar result by closing the loophole in the U.S. trade ban under which Iranian crude oil, when mixed with other countries' oils at foreign refineries in Europe and elsewhere, can be imported as refined product. Some argue this concept has been mooted by the EU oil embargo, while others say the step still has value in making sure the EU oil embargo on Iran is not lifted or modified.

* Mandating Reductions in Diplomatic Exchanges with Iran or Prohibiting Travel by Iranian Officials. Some have suggested that the United States organize a worldwide ban on travel by senior Iranian civilian officials, a pullout of all diplomatic missions in Tehran, and expulsion of Iranian diplomats worldwide.

The EU came close to adopting this option after the November 29, 2011, attack on the British Embassy in Tehran.

* Barring Iran from International Sporting Events. An option is to limit sports or cultural exchanges with Iran, such as Iran's participation in the World Cup soccer tournament. However, many experts oppose using sporting events to accomplish political goals.

* Sanctioning Iranian Profiteers and Other Abusers. Some experts believe that, despite the provision of P.L. 112-239 discussed earlier, the United States and international community should more aggressively target for sanctions Iranians who are exploiting special rights, monopolies, or political contacts for economic gain at the expense of average Iranians. Others believe that human rights sanctions should be extended to Iranian officials who are responsible for depriving Iranian women and other groups of internationally accepted rights.

* Banning Passenger Flights to and from Iran. Bans on flights to and from Libya were imposed on that country in response to the finding that its agents were responsible for the December 21, 1988, bombing of Pan Am 103 (now lifted). A variation of this idea could be the imposition of sanctions against airlines that are in joint ventures or codeshare arrangements with Iranian airlines.

* Limiting Lending to Iran by International Financial Institutions. Resolution 1747 calls for restraint on but does not outright ban international lending to Iran. An option is to make a ban on such lending mandatory. Some U.S. groups have called for the International Monetary Fund (IMF) to withdraw all its holdings in Iran's Central Bank and suspend Iran's membership in the body.

* Banning Trade Financing or Official Insurance for Trade Financing. Another option is to mandate a worldwide ban on official trade credit guarantees. This was not mandated by Resolution 1929, but several countries imposed this sanction subsequently. A ban on investment in Iranian bonds reportedly was considered but deleted to attract China and Russia's support.

* Restricting Operations of and Insurance for Iranian Shipping. One option, reportedly long under consideration, has been a worldwide ban on provision of insurance or reinsurance for any shipping to or from Iran. A call for restraint is in Resolution 1929, but is not mandatory. As of July 1, 2012, the EU has banned such insurance, and many of the world's major insurers are in Europe.

Author Contact Information

Kenneth Katzman

Specialist in Middle Eastern Affairs, 7-7612




(4) The executive order was issued not only under the authority of IEEPA but also: the National Emergencies Act (50 U.S.C. 1601 et seq.; [section]505 of the International Security and Development Cooperation Act of 1985 (22 U.S.C. 2349aa9) and [section]301 of Title 3, United States Code.

(5) Reuters, February 21, 2014; Exclusive: Boeing Says Gets U.S. License to Sell Spare Parts to Iran. Reuters, April 4, 2014.


(7) The information in this bullet is taken from: Jo Becker, "With U.S. Leave, Companies Skirt Iran Sanctions," New York Times, December 24, 2010.

(8) The title is called the "Trade Sanctions Reform and Export Enhancement Act of 2000."

(9) As amended by CISADA (P.L. 111-195), these definitions include pipelines to or through Iran, as well as contracts to lead the construction, upgrading, or expansions of energy projects. CISADA also changes the definition of investment to eliminate the exemption from sanctions for sales of energy-related equipment to Iran, if such sales are structured as investments or ongoing profit-earning ventures.

(10) Under [section]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. However, P.L. 111-195 explicitly sets the threshold investment level at $20 million. For Libya, the threshold was $40 million, and sanctionable activity included export to Libya of technology banned by Pan Am 103-related Security Council Resolutions 748 (March 31, 1992) and 883 (November 11, 1993).

(11) The original ISA definition of energy sector included oil and natural gas, and CISADA added to that definition: liquefied natural gas (LNG), oil or LNG tankers, and products to make or transport pipelines that transport oil or LNG.

(12) A definition of chemicals and products considered "petrochemical products" is found in a Policy Guidance statement. See, Federal Register, November 13, 2012,!documentDetail;D=DOS_FRDOC_0001-2175.

(13) 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,!documentDetail;D=DOS FRDOC 0001-2175.

(14) Other ISA amendments under that law included recommending against U.S. nuclear agreements with countries that supply nuclear technology to Iran and expanding provisions of the USA Patriot Act (P.L. 107-56) to curb money-laundering for use to further WMD programs.

(15) This termination requirement added by P.L. 109-293, which 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.


(17) Dollar figures for investments in Iran represent public estimates of the amounts investing firms are expected to spend over the life of a project, which might in some cases be several decades.

(18) Text of announcement of waiver decision by then-Secretary of State Madeleine Albright, containing expectation of similar waivers in the future, at

(19) Text of letter from Senators Mark Kirk and Robert Menendez to Secretary Geithner, January 19, 2012.

(20) Announcements by the Department of State, March 20, 2012, June 11, 2012, and June 28, 2012.

(21) The provision contains certain exceptions to ensure the safety of astronauts, but it nonetheless threatened to limit U.S. access to the international space station after April 2006, when Russia started charging the United States for transportation on its Soyuz spacecraft. Legislation in the 109th Congress (S. 1713, P.L. 109-112) amended the provision in order to facilitate continued U.S. access and extended INA sanctions provisions to Syria.

(22) Glenn Kessler, "U.S. Moves to Isolate Iranian Banks," Washington Post, September 9, 2006.

(23) Jessica Silver-Greenberg, "Regulator Says Bank Helped Iran Hide Deals," New York Times, August 7, 2012.

(24) Rick Gladstone. "U.S. Announces Actions to Enforce Iran Sanctions." New York Times, April 29, 2014.


(26) For information on the steps taken by individual states, see National Conference of State Legislatures, "State Divestment Legislation."

(27) U.S. Department of the Treasury, Office of Public Affairs, Treasury Sanctions Iranian Security Forces for Human Rights Abuses, June 9, 2011.

(28) Christopher Rhoads, "Iran's Web Spying Aided by Western Technology," Wall Street Journal, June 22, 2009.

(29) Fact Sheet: Treasury Issues Interpretive Guidance and Statement of Licensing Policy on Internet Freedom in Iran, March 20, 2012.


(31) Note: CRS has no mandate or capability to "judge" compliance of any country with U.S., multilateral, or international sanctions against Iran. This section is intended to analyze some major trends in third country cooperation with U.S. policy toward Iran. These assessments bear in mind that there are many other issues and considerations in U.S. relations with the countries discussed here.

(32) Avi Jorish, "Despite Sanctions, Iran's Money Flow Continues," Wall Street Journal, June 25, 2013.

(33) During the active period of talks, which began in December 2002, there were working groups focused not only on the TCA terms and proliferation issues but also on Iran's human rights record, Iran's efforts to derail the Middle East peace process, Iranian-sponsored terrorism, counter-narcotics, refugees, migration issues, and the Iranian opposition PMOI.

(34) Iran Aims to Return to Shipping Market. Wall Street Journal, September 17, 2014.

(35) Prasanta Sahu and Biman Mukherji, "New Delhi Looks to Buy More Iran Oil, Risks U.S. Ire," Wall Street Journal, August 13, 2013. p. 8.

(36) Asia Times, March 21,2014.

(37) "Iran, Russia Negotiating Big Oil-for-Goods Deal." Reuters, January 10, 2014.

(38) Author conversation with journalists based in China, September 1, 2013.

(39) Information provided to the author by the New York State government, July 2012.

(40) "US Acts to Block Turkish Firm from Sending GE Engines to Iran." Reuters, January 6, 2014.

(41) Louis Charbonneau, "Iran Looks to Armenia to Skirt Banking Sanctions," Reuters, August 21, 2012.

(42) Information provided to the author by regional observers. October 2013.

(43) "As Sanctions Bite, Iran Invests Big in Georgia," Wall Street Journal, June 20, 2013.

(44) The CRS Report RL32048, Iran: U.S. Concerns and Policy Responses, by Kenneth Katzman, discusses the relations between Iran and other Middle Eastern states.

(45) Mark Wallace, "Closing U.S. Ports to Iran-Tainted Shipping. Op-ed," Wall Street Journal, March 15, 2013.

(46); nn=8901181055.

(47) Ben Lando, "Iraq Inks Gas Supply Deal with Iran," Iraq Oil Report, July 23, 2013.

(48) Michael Gordon and Eric Schmitt. "Iran Secretly Sending Drones and Supplies to Iraq, U.S. Officials Say." New York Times, June 25, 2014.

(49) "Pentagon Contractor Used Iran for Project," Wall Street Journal, September 26, 2013.

(50) Barbara Slavin. "Obama Administration Holds Up Environmental Grants to Iran." Al Monitor, June 23, 2014.

(51) Farah Stockman, "Oil Firm Says It Will Withdraw From Iran," Boston Globe, November 12, 2010.

(52) "Iran Says Halliburton Won Drilling Contract," Washington Times, January 11, 2005.

(53) "Caterpillar Says Tightens 'No-Iran' Business Policy," Reuters, March 1,2010.

(54) Ron Nixon, "2 Corporations Say Business With Tehran Will Be Curbed," New York Times, March 11, 2010.

(55) Peter Baker, "U.S. and Foreign Companies Feeling Pressure to Sever Ties With Iran," New York Times, April 24, 2010.

(56) In September 2011, the Commerce Department fined Flowserve $2.5 million to settle 288 charges of unlicensed exports and reexports of oil industry equipment to Iran, Syria, and other countries.

(57) Form 10-K for Fiscal year ended December 31, 2008, claims firm directed its subsidiaries to cease new business in Iran and Cuba, Syria, and Sudan as of September 2007.

(58) Asjylyn Loder and David Evans, "Koch Brothers Flout Law Getting Richer With Iran Sales," Bloomberg News, October 3, 2011.

(59) Form 10-K Filed for fiscal year ended December 31, 2008.

(60) Paulo Prada and Betsy McKay, "Trading Outcry Intensifies," Wall Street Journal, March 27, 2007; Michael Brush, "Are You Investing in Terrorism?," MSN Money, July 9, 2007.

(61) New York Times, March 7, 2010, cited previously.

(62) "Subsidiaries of the Registrant at December 31, 2009,"

(63) "Exhibit to 10-K Filed February 25, 2009." Officials of Fluor claim that their only dealings with Iran involve property in Iran owned by a Fluor subsidiary, which the subsidiary has been unable to dispose of. CRS conversation with Fluor, December 2009.

(64) Form 10-K for Fiscal year ended December 31, 2007.

(65) Speech by National Security Adviser Tom Donilon at the Brookings Institution, November 22, 2011.

(66) William Maclean. "Iran Pursuing Banned Items for Nuclear, Missile Wor: U.S. Official." Reuters, March 16, 2014.

(67) Department of Defense, Annual Report ofMilitary Power of Iran, April 2012.

(68) Louis Charbonneau, "U.N. Monitors See Arms Reaching Somalia From Yemen, Iran," Reuters, February 10, 2013.

(69) Aurelia End, "Siemens Quits Iran Amid Mounting Diplomatic Tensions," Agence France Press, January 27, 2010.


(71) GAO-14-218R Iran, January 7, 2014.

(72) "Iran's Pivotal Moment.", 2014.

(73) "Iran Economy Remains in Distress Amid Sanctions--U.S.'s Lew." Reuters, June 18, 2014.

(74) "Why Higher Iran Oil Exports Are Not Roiling Nuclear Deal." Reuters, June 13, 2014.

(75) Rick Gladstone, "Data on Iran Dims Outlook for Economy," New York Times, October 13, 2012.

(76) Marjorie Olster, "Report: U.S. Sanctions Make Half Iran's Oil Income Out of its Reach," Associated Press, August 30, 2013.

(77), op.cit.

(78) Clifford Krauss. "With Gas Byproduct, Iran Sidesteps Sanctions." New York Times, August 13, 2014.

(79) Khajehpour presentation at CSIS. Op. cit.

(80) Iran Faces Steep Climb to Join Gas Superpowers by 2017. International Oil Daily, April 29, 2014.

(81) Information in this section derived from Javier Bias, "Traders Cut Iran Petrol Line," Financial Times, March 8, 2010.


(83) 11788115&Itemid= 105.

(84) 11788115&Itemid= 105.

(85) 11788115&Itemid= 105.

(86) U.S. Pushes to Expedite Some Humanitarian Shipments to Iran., July 28, 2014.

(87) Thomas Erdbink, "Iran's Aging Airliner Fleet Seen As Faltering Under U.S. Sanctions," July 14, 2012.

(88) The Administration sanctions suspensions and waivers are detailed at:

(89) Daniel Fineren. "Iran Nuclear Deal Shipping Insurance Element May Help Oil Sales." Reuters, November 24, 2013.

(90) White House Office of the Press Secretary. "Fact Sheet: First Step Understandings Regarding the Islamic Republic of Iran's Nuclear Program." November 23, 2013.


(92) David Sanger. "Obama Sees an Iran Deal Skirting Congress, for Now." New York Times, October 20, 2014.

(93) David Sanger. "Obama Sees an Iran Deal Skirting Congress, for Now." New York Times, October 20, 2014.

(94) Dept. of State. "Background Briefing on Next Week's EU-Coordinated P5+1 Talks With Iran." March 14, 2014.

(95) Ibid.
Table 2. Top Energy Buyers From Iran and Reductions
(amounts in barrels per day, bpd)

                                         Average (at time of JPA
Country/Bloc              2011 Average    implementation start)

European Union              600,000             Negligible
  (particularly Italy,
  Spain, and Greece)
China                       550,000                410,000
Japan                       325,000                190,000
India                       320,000                190,000
South Korea                 230,000                130,000
Turkey                      200,000                120,000
South Africa                 80,000             Negligible
Malaysia                     55,000             Negligible
Sri Lanka                    35,000             Negligible
Taiwan                       35,000                 10,000
Singapore                    20,000             Negligible
Other                        55,000             Negligible
Total                       2.5 mbd              1.057 mbd

Source: International Energy Agency and rough estimates based
on CRS conversations with foreign diplomats and press reports.

Note: Actual volumes might differ, and import volumes may
fluctuate dramatically over short periods of time as
actual tanker deliveries occur.

Table 3. Summary of Provisions of U.N. Resolutions on Iran Nuclear
Program (1737, 1747, 1803, and 1929)

Requires 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)

Freezes the assets of Iranian persons and entities named in annexes
to the resolutions, and requires that countries ban the travel of
named Iranians. (1737, 1747, 1803, and 1929)

Prohibits transfer to Iran of nuclear, missile, and dual use items
to Iran, except for use in light-water reactors. (1737, and 1747)

Prohibits Iran from exporting arms or WMD-useful technology (1747)

Prohibits Iran from investing abroad in uranium mining, related
nuclear technologies or nuclear capable ballistic missile
technology, and prohibits Iran from launching ballistic missiles
(including on its territory). (1929)

Requires Iran to refrain from any development of ballistic missiles
that are nuclear capable. (1929)

Mandates that countries not export major combat systems to Iran,
but does not bar sales of missiles that are not on the U.N.
Registry of Conventional Arms. (1929)

Calls for voluntary restraint on transactions with Iranian banks,
particularly Bank Melli and Bank Saderat. (1929)

Calls for vigilance on international lending to Iran and providing
trade credits and other financing. (1929)

Calls 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. (1929)

A Sanctions Committee, composed of the 15 members of the Security
Council, monitors implementation of all Iran sanctions and collects
and disseminates information on Iranian violations and other
entities involved in banned activities. A "panel of experts" is
empowered by 1929 to assist the U.N. sanctions committee in
implementing the resolution and previous Iran resolutions, and to
suggest ways of more effective implementation.

Source: Text of U.N. Security Council resolutions 1737, 1747, 1803,
and 1929. More information on specific
provisions of each of these resolutions and the nuclear
negotiations with Iran is in CRS Report RL32048, Iran: U.S.
Concerns and Policy Responses, by Kenneth Katzman.

Table 4. Comparison Between U.S., U.N., and EU and Allied
Country Sanctions

U.S. Sanctions                       U.N. Sanctions

General Observation:                 Increasingly sweeping, but still
                                     intended to primarily target
Most sweeping sanctions on           Iran's nuclear and other WMD
Iran of virtually any country        programs. No mandatory sanctions
in the world                         on Iran's energy sector.

Ban on U.S. Trade with and           U.N. sanctions do not ban
Investment in Iran:                  civilian trade with Iran or
                                     general civilian sector
Executive Order 12959 bans (with     investment in Iran. Nor do U.N.
limited exceptions) U.S. firms       sanctions mandate restrictions
from exporting to Iran, importing    on provision of trade financing
from Iran, or investing in Iran.     or financing guarantees by
There is an exemption for sales      national export credit guarantee
to Iran of food and medical          agencies.

Sanctions on Foreign Firms that      No U.N. equivalent exists.
Do Business with Iran's Energy       However, preambular language in
Sector:                              Resolution 1929 "not[es] the
                                     potential connection between
The Iran Sanctions Act, P.L.         Iran's revenues derived from its
104-172, and subsequent laws         energy sector and the funding of
and executive orders, discussed      Iran's proliferation-sensitive
throughout the report, mandate       nuclear activities." This wording
sanctions on virtually any type      is interpreted by most observers
of transaction with/in Iran's        as providing U.N. support for
energy sector. Some exemptions       countries who want to ban their
are permitted for firms of           companies from investing in
countries that have "significantly   Iran's energy sector.
reduced" purchases of Iranian
oil each 180 days.

Ban on Foreign Assistance:           No U.N. equivalent

U.S. foreign assistance to Iran--
other than purely humanitarian
aid--is banned under
[section]620A of the Foreign
Assistance Act, which bans U.S.
assistance to countries on the
U.S. list of "state sponsors of
terrorism." Iran is also
routinely denied direct U.S.
foreign aid under the annual
foreign operations appropriations
acts (most recently in
[section]7007 of division H
of P.L. 111-8).

Ban on Arms Exports to Iran:         Resolution 1929 (operative
                                     paragraph 8) bans all U.N. member
Iran is ineligible for U.S.          states from selling or supplying
arms exports under several laws,     to Iran major weapons systems,
as discussed in the report.          including tanks, armored
                                     vehicles, combat aircraft,
                                     warships, and most missile
                                     systems, or related spare parts
                                     or advisory services for such
                                     weapons systems.

Restriction on Exports to Iran       The U.N. resolutions on Iran,
of "Dual Use Items":                 cumulatively, ban the export of
                                     almost all dual-use items to Iran.
Primarily under [section]6(j) of
the Export Administration Act
(P.L. 96-72) and [section]38 of
the Arms Export Control Act,
there is a denial of license
applications to sell Iran goods
that could have military

Sanctions Against International      Resolution 1747 (oper. paragraph
Lending to Iran:                     7) requests, but does not
                                     mandate, that countries and
Under [section]1621 of the           international financial
International Financial              institutions refrain from making
Institutions Act (P.L. 95118),       grants or loans to Iran, except
U.S. representatives to              for development and humanitarian
international financial              purposes.
institutions, such as the World
Bank, are required to vote
against loans to Iran by those

Sanctions Against Foreign Firms      Resolution 1737 (oper. paragraph
that Sell Weapons of Mass            12) imposes a worldwide freeze
Destruction-Related Technology       on the assets and property of
to Iran:                             Iranian entities named in an
                                     Annex to the Resolution. Each
As discussed in this report,         subsequent resolution has
several laws and regulations         expanded the list of Iranian
provide for sanctions against        entities subject to these
entities, Iranian or otherwise,      sanctions.
that are determined to be
involved in or supplying Iran's
WMD programs (asset freezing, ban
on transaction with the entity).

Ban on Transactions with             No direct equivalent, but
Terrorism Supporting Entities:       Resolution 1747 (oper. Paragraph
                                     5) bans Iran from exporting any
Executive Order 13224 bans           arms--a provision widely
transactions with entities           interpreted as trying to reduce
determined by the Administration     Iran's material support to groups
to be supporting international       such as Lebanese Hezbollah,
terrorism. Numerous entities,        Hamas, Shiite militias in Iraq,
including some of Iranian origin,    and insurgents in Afghanistan.
have been so designated.

Travel Ban on Named Iranians:        Resolution 1803 imposed a binding
                                     ban on international travel by
CISADA and H.R. 1905 provide for     several Iranians named in an
a prohibition on travel to the       Annex to the Resolution.
U.S., blocking of U.S.-based         Resolution 1929 extended that ban
property, and ban on transactions    to additional Iranians, and forty
with Iranians determined to be       Iranians are now subject to the
involved in serious human rights     ban. However, the Iranians
abuses against Iranians since the    subject to the travel ban are so
June 12, 2009, presidential          subjected because of their
election there, or with persons      involvement in Iran's WMD
selling Iran equipment to commit     programs, not because of
such abuses.                         involvement in human rights


Restrictions on Iranian Shipping:    Resolution 1803 and 1929
                                     authorize countries to inspect
Under Executive Order 13382, the     cargoes carried by Iran Air and
U.S. Treasury Department has         Islamic Republic of Iran Shipping
named Islamic Republic of Iran       Lines (IRISL)--or any ships in
Shipping Lines and several           national or international
affiliated entities as entities      waters--if there is an indication
whose U.S.-based property is to      that the shipments include goods
be frozen.                           whose export to Iran is banned.

Banking Sanctions:                   No direct equivalent

During 2006-2011, several Iranian    However, two Iranian banks are
banks have been named as             named as sanctioned entities
proliferation or terrorism           under the U.N. Security Council
supporting entities under            resolutions.
Executive Orders 13382 and 13224,
respectively (see Table 5 at end
of report).

CISADA prohibits banking
relationships with U.S. banks for
any foreign bank that conducts
transactions with Iran's
Revolutionary Guard or with
Iranian entities sanctioned under
the various U.N. resolutions.

FY2012 Defense Authorization
(P.L. 112-81) prevents U.S.
accounts with foreign banks that
process transactions with Iran's
Central Bank (with specified

No direct equivalent, although,      Resolution 1929 (oper. paragraph
as discussed above, U.S.             7) prohibits Iran from acquiring
proliferations laws provide for      an interest in any country
sanctions against foreign            involving uranium mining,
entities that help Iran with its     production, or use of nuclear
nuclear and ballistic missile        materials, or technology related
programs.                            to nuclear-capable ballistic
                                     missiles. Paragraph 9 prohibits
                                     Iran from undertaking "any
                                     activity" related to ballistic
                                     missiles capable of delivering a
                                     nuclear weapon.

                                     Implementation by EU and Some
U.S. Sanctions                       Allied Countries

General Observation:                 EU closely aligns its sanctions
                                     tightening--as well as sanctions
Most sweeping sanctions on           relief in the context of the
Iran of virtually any country        nuclear deal--with those of the
in the world                         U.S.

                                     Japan and South Korean sanctions
                                     also increasingly extensive.

Ban on U.S. Trade with and           No general EU ban on trade in
Investment in Iran:                  civilian goods with Iran, but
                                     bans on certain types of trade
Executive Order 12959 bans (with     as discussed.
limited exceptions) U.S. firms
from exporting to Iran, importing    Japan and South Korea have
from Iran, or investing in Iran.     banned medium- and long-term
There is an exemption for sales      trade financing and financing
to Iran of food and medical          guarantees. Short-term credit
products.                            still allowed.

Sanctions on Foreign Firms that      With certain exceptions likely
Do Business with Iran's Energy       to fulfill the nuclear deal, the
Sector:                              EU bans almost all dealings with
                                     Iran's energy sector.
The Iran Sanctions Act, P.L.
104-172, and subsequent laws         Japanese and South Korean
and executive orders, discussed      measures ban new energy projects
throughout the report, mandate       in Iran and call for restraint
sanctions on virtually any type      on ongoing projects. South Korea
of transaction with/in Iran's        in December 2011 cautioned its
energy sector. Some exemptions       firms not to sell energy or
are permitted for firms of           petrochemical equipment to Iran.
countries that have "significantly   Both have cut oil purchases from
reduced" purchases of Iranian        Iran sharply.
oil each 180 days.

Ban on Foreign Assistance:           EU measures of July 27, 2010,
                                     ban grants, aid, and concessional
U.S. foreign assistance to Iran--    loans to Iran. Also prohibit
other than purely humanitarian       financing of enterprises involved
aid--is banned under                 in Iran's energy sector.
[section]620A of the Foreign
Assistance Act, which bans U.S.      Japan and South Korea measures
assistance to countries on the       do not specifically ban aid or
U.S. list of "state sponsors of      lending to Iran, but no such
terrorism." Iran is also             lending by these countries is
routinely denied direct U.S.         under way.
foreign aid under the annual
foreign operations appropriations
acts (most recently in
[section]7007 of division H
of P.L. 111-8).

Ban on Arms Exports to Iran:         EU sanctions include a
                                     comprehensive ban on sale to
Iran is ineligible for U.S.          Iran of all types of military
arms exports under several laws,     equipment, not just major combat
as discussed in the report.          systems. No similar Japan and
                                     South Korean measures announced,
                                     but neither has exported arms
                                     to Iran.

Restriction on Exports to Iran       EU bans the sales of dual use
of "Dual Use Items":                 items to Iran, in line with
                                     U.N. resolutions.
Primarily under [section]6(j) of
the Export Administration Act        Japan and S. Korea have announced
(P.L. 96-72) and [section]38 of      full adherence to strict export
the Arms Export Control Act,         control regimes when evaluating
there is a denial of license         sales to Iran.
applications to sell Iran goods
that could have military

Sanctions Against International      The July 27, 2010, measures
Lending to Iran:                     prohibit EU members from
                                     providing grants, aid, and
Under [section]1621 of the           concessional loans to Iran,
International Financial              including through international
Institutions Act (P.L. 95118),       financial institutions.
U.S. representatives to
international financial              No specific similar Japan or
institutions, such as the World      South Korea measures announced.
Bank, are required to vote
against loans to Iran by those

Sanctions Against Foreign Firms      The EU measures imposed July
that Sell Weapons of Mass            27, 2010, commit the EU to
Destruction-Related Technology       freezing the assets of entities
to Iran:                             named in the U.N. resolutions,
                                     as well as numerous other named
As discussed in this report,         Iranian entities. Japan and South
several laws and regulations         Korea froze assets of
provide for sanctions against        U.N.-sanctioned entities.
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).

Ban on Transactions with             No direct equivalent, but many
Terrorism Supporting Entities:       of the Iranian entities named as
                                     blocked by the EU, Japan, and
Executive Order 13224 bans           South Korea overlap or complement
transactions with entities           Iranian entities named as
determined by the Administration     terrorism supporting by the
to be supporting international       United States.
terrorism. Numerous entities,
including some of Iranian origin,
have been so designated.

Travel Ban on Named Iranians:        The EU sanctions announced July
                                     27, 2010, contains an Annex of
CISADA and H.R. 1905 provide for     named Iranians subject to a ban
a prohibition on travel to the       on travel to the EU countries.
U.S., blocking of U.S.-based         An additional 60+ Iranians
property, and ban on transactions    involved in human rights abuses
with Iranians determined to be       were subjected to EU sanctions
involved in serious human rights     since. Japan and South Korea have
abuses against Iranians since the    announced bans on named Iranians.
June 12, 2009, presidential
election there, or with persons
selling Iran equipment to commit
such abuses.

Restrictions on Iranian Shipping:    The EU measures announced July
                                     27, 2010, bans Iran Air Cargo
Under Executive Order 13382, the     from access to EU airports. The
U.S. Treasury Department has         measures also freeze the EU-based
named Islamic Republic of Iran       assets of IRISL and its
Shipping Lines and several           affiliates. Insurance and
affiliated entities as entities      re-insurance for Iranian firms
whose U.S.-based property is to      is banned. Japan and South Korean
be frozen.                           measures took similar actions
                                     against IRISL and Iran Air.

Banking Sanctions:                   The EU froze Iran Central Bank
                                     assets January 23, 2012, and
During 2006-2011, several Iranian    banned all transactions with
banks have been named as             Iranian banks unless authorized
proliferation or terrorism           on October 15, 2012.
supporting entities under
Executive Orders 13382 and 13224,    Brussels-based SWIFT expelled
respectively (see Table 5 at end     sanctioned Iranian banks from
of report).                          the electronic payment
                                     transfer system.
CISADA prohibits banking
relationships with U.S. banks for    Japan and South Korea measures
any foreign bank that conducts       similar to the 2010 EU sanctions,
transactions with Iran's             with South Korea adhering to the
Revolutionary Guard or with          same 40,000 Euro authorization
Iranian entities sanctioned under    requirement. Japan and S. Korea
the various U.N. resolutions.        froze the assets of 15 Iranian
                                     banks; South Korea targeted Bank
FY2012 Defense Authorization         Mellat for freeze.
(P.L. 112-81) prevents U.S.
accounts with foreign banks that     Some measures by these allies
process transactions with Iran's     likely to be eased to implement
Central Bank (with specified         nuclear deal.

No direct equivalent, although,      EU measures on July 27, 2010,
as discussed above, U.S.             require adherence to this
proliferations laws provide for      provision of Resolution 1929.
sanctions against foreign
entities that help Iran with its
nuclear and ballistic missile

Table 5. Post-1999 Major Investments/Major Development Projects
in Iran's Energy Sector

Date            Field/Project

Feb. 1999       Doroud (oil)

                (Energy Information Agency, Department of Energy,
                August 2006.) Total and ENI exempted from sanctions
                on September 30 because of pledge to exit Iran market

April 1999      Balal (oil)

                ("Balal Field Development in Iran Completed," World
                Market Research Centre, May 17, 2004.)

Nov. 1999       Soroush and Nowruz (oil)

                ("News in Brief: Iran." Middle East Economic Digest,
                (MEED) January 24, 2003.)
                Royal Dutch exempted from sanctions on 9/30 because
                of pledge to exit Iran market

April 2000      Anaran bloc (oil)

                (MEED Special Report, December 16, 2005, pp. 48-50.)

July 2000       Phase 4 and 5, South Pars (gas)

                (Petroleum Economist, December 1, 2004.) ENI
                exempted 9/30 based on pledge to exit Iran market

March 2001      Caspian Sea oil exploration-construction of
                submersible drilling rig for Iranian partner

                (IPR Strategic Business Information Database,
                March 11,2001.)

June 2001       Darkhovin (oil)

                ("Darkhovin Production Doubles." Gulf Daily News,
                May 1,2008.) ENI told CRS in April 2010 it would
                close out all Iran operations by 2013. ENI exempted
                from sanctions on 9/30, as discussed above

May 2002        Masjid-e-Soleyman (oil)

                ("CNPC Gains Upstream Foothold." MEED,
                September 3, 2004.)

Sept. 2002      Phase 9 + 10, South Pars (gas)

                ("OIEC Surpasses South Korean Company in South
                Pars." IPR Strategic Business Information Database,
                November 15, 2004.)

October         Phase 6, 7, 8, South Pars (gas)
                (Source: Statoil, May 2011)

                Field began producing late 2008; operational control
                handed to NIOC in 2009. Statoil exempted from
                sanctions on 9/30/2010 after pledge to exit
                Iran market.

January 2004    Azadegan (oil)-South and North

                October 15, 2010: Inpex announced it would exit the
                Azadegan project entirely by selling its 10%
                stake; "special rule" exempting it from ISA
                investigation invoked November 17, 2010.

                China National Petroleum Corp. took a majority stake
                in South and North Azadegan fields in January 2009.
                However, on April 29, 2014, Iran cancelled the South
                Azadegan contract citing CNPC for performing "no
                effective work" since taking the stake in 2009.
                Industry sources say CNPC likely to also lose North
                Azadegan project also. (Iran-CNPC Breakup: Tehran Eyes
                the West, Christian Science Monitor, May 5, 2014.

August          Tusan Block
                Oil found in block in Feb. 2009, but not in commercial
                quantity, according to the firm. ("Iran-Petrobras
                Operations." APS Review Gas Market Trends,
                April 6, 2009; "Brazil's Petrobras Sees Few Prospects
                for Iran Oil," (

October 2004    Yadavaran (oil)

                Christian Science Monitor reports May 5, 2014,
                (op.cit.) that Iran says Sinopec has "experienced
                problems with regards to progress" on the field,
                which also extends into Iraq. But International Oil
                Daily quotes company on May 7, 2014, as saying
                project is on course to produce an initial 85,000
                bpd by the end of 2014.

2005            Saveh bloc (oil)

                GAO report, cited below

June            Garmsar bloc (oil)
                Deal finalized in June 2009

                ("China's Sinopec signs a deal to develop oil block
                in Iran-report," Forbes, 20 June 2009,

July 2006       Arak Refinery expansion

                (GAO reports; Fimco FZE Machinery website;

Sept. 2006      Khorramabad block (oil)

                Seismic data gathered, but no production is planned.
                (Statoil factsheet, May 2011)

Dec. 2006       North Pars Gas Field (offshore gas). Includes gas

                Work crews reportedly pulled
                from the project in early-mid 2011. ("China Curbs
                Iran Energy Work" Reuters, September 2, 2011)

Feb. 2007       LNG Tanks at Tombak Port

                Contract to build three LNG tanks at Tombak, 30 miles
                north of Assaluyeh Port.

                (May not constitute "investment" as defined in
                pre-2010 version of ISA, because that definition did
                not specify LNG as "petroleum resource" of Iran.)

                "Central Bank Approves $900 Million for Iran LNG
                Project." Tehran Times, June 13, 2009.

Feb. 2007       Phase 13, 14-South Pars (gas)

                Deadline to finalize as May 20, 2009, apparently not
                met; firms submitted revised proposals to Iran in
                June 2009. (

                State Department said on September 30, 2010, that
                Royal Dutch Shell and Repsol will not pursue this
                project any further

March 2007      Esfahan refinery upgrade

                ("Daelim, Others to Upgrade Iran's Esfahan Refinery."
                Chemical News and Intelligence, March 19, 2007.)

July 2007       Phase 22, 23, 24-South Pars (gas)

                Pipeline to transport Iranian gas to Turkey, and on
                to Europe and building three power plants in Iran.
                Contract not finalized to date.

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.)

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,
                for this and other activities.

2008            Dayyer Bloc (Persian Gulf, offshore, oil)

                GAO report cited below

Feb. 2008       Lavan field (offshore natural gas)

                GAO report cited below invested. PGNiG invested, but
                delays caused Iran to void PGNiG contract in
                December 2011. Project to be implemented by Iranian
                firms. (Fars News, December 20, 2011)

March 2008      Danan Field (on-shore oil)

                "PVEP Wins Bid to Develop Danan Field." Iran Press
                TV, March 11, 2008

April 2008      Iran's Kish gas field

                Includes pipeline from Iran to Oman

April 2008      Moghan 2 (onshore oil and gas, Ardebil province)

                Jan. 7, 2014, GAO report says INA has withdrawn
                from Iran.

-               Kermanshah petrochemical plant (new construction)

                GAO report cited below

June 2008       Resalat Oilfield

                (Fars News Agency, June 16, 2008) Status
                of work unclear

January 2009    Bushehr Polymer Plants

                Production of polyethelene at two polymer plants
                in Bushehr Province.

                GAO Jan. 7, 2014, report says Sasol has withdrawn
                from Iran.

March 2009      Phase 12 South Pars (gas)-Incl. LNG terminal
                construction and Farsi Block gas field/Farzad-B bloc.

                Jan.7, 2014, GAO reports says ONGC Videsh has
                withdrawn from Iran, but project continued by NIOC
                subsidiary Petropars. Field began producing
                in March 2014.

August 2009     Abadan refinery

                Upgrade and expansion; building a new refinery at
                Hormuz on the Persian Gulf coast

Oct. 2009       South Pars Gas Field-Phases 6-8, Gas Sweetening Plant

                CRS conversation with Embassy of S. Korea in
                Washington, D.C, July 2010

                Contract signed but then abrogated by S. Korean firm

Nov. 2009       South Pars: Phase 12-Part 2 and Part 3

                ("Italy, South Korea To Develop South Pars Phase
                12." Press TV (Iran), November 3, 2009,

Feb. 2010       South Pars: Phase 11

                Drilling was to begin in March 2010, but CNPC pulled
                out in October 2012. (Economist Intelligence Unit "Oil
                Sanctions on Iran: Cracking Under Pressure." 2012)

2011            Azar Gas Field

                Gazprom contract voided in late 2011 by Iran due
                to Gazprom's unspecified failure to fulfill its

Dec. 2011       Zagheh Oil Field

                Preliminary deal signed December 18, 2011
                (Associated Press, December 18, 2011)

Date            Company(ies)/Status (If Known)

Feb. 1999       Total (France)/ENI (Italy)

April 1999      Total/ Bow Valley (Canada)/ENI

Nov. 1999       Royal Dutch Shell (Netherlands)/Japex (Japan)

April 2000      Norsk Hydro and Statoil (Norway) and Gazprom and
                Lukoil (Russia) No production to date; Statoil
                and Norsk have left project.

July 2000       ENI Gas onstream as of Dec. 2004

March 2001      GVA Consultants (Sweden)

June 2001       ENI Field in production

May 2002        Sheer Energy (Canada)/China National Petroleum
                Company (CNPC). Local partner is Naftgaran Engineering

Sept. 2002      LG Engineering and Construction Corp. (now known
                as GS Engineering and Construction Corp., South Korea)

                On stream as of early 2009
October         Statoil (Norway)

January 2004    Inpex (Japan) and CNPC (China)

August          Petrobras (Brazil)

October 2004    Sinopec (China), deal finalized Dec. 9, 2007

2005            PTT (Thailand)

June            Sinopec (China)

July 2006       Sinopec (China); JGC (Japan). Work may have
                been taken over or continued by Hyundai Heavy
                Industries (S. Korea)

Sept. 2006      Norsk Hydro and Statoil (Norway).

Dec. 2006       China National Offshore Oil Co.

Feb. 2007       Daelim (S. Korea)

Feb. 2007       Royal Dutch Shell, Repsol (Spain)

March 2007      Daelim (S. Korea)

July 2007       Turkish Petroleum Company (TPAO)

Dec. 2007       Petrofield Subsidiary of SKS Ventures (Malaysia)

2007            Belarusneft (Belarus) under contract to Naftiran.
(unspec.)       No production to date

2008            Edison (Italy)

Feb. 2008       PGNiG (Polish Oil and Gas Company, Poland)

March 2008      Petro Vietnam Exploration and Production Co. (Vietnam)

April 2008      Oman (co-financing of project)

April 2008      INA (Croatia)

-               Uhde (Germany)

June 2008       Amona (Malaysia). Joined in June 2009 by CNOOC and
                another China firm, COSL.

January 2009    Sasol (South Africa)

March 2009      Taken over by Indian firms (ONGC Videsh, Oil India
                Ltd., India Oil Corp. Ltd. in 2007); may also
                include minor stakes by Sonanagol (Angola) and
                PDVSA (Venezuela)..

August 2009     Sinopec

Oct. 2009       G and S Engineering and Construction (South Korea)

Nov. 2009       Daelim (S. Korea)-Part 2; Tecnimont (Italy)-Part 3

Feb. 2010       CNPC (China)

2011            Gazprom (Russia)

Dec. 2011       Tatneft (Russia)

Date            Value                     Output/Goal

Feb. 1999       $1 billion                205,000 bpd

April 1999      $300 million              40,000 bpd

Nov. 1999       $800 million              190,000 bpd

April 2000      $ 105 million             65,000

July 2000       $ 1.9 billion             2 billion cu.
                                          ft./day (cfd)

March 2001      $225 million              NA

June 2001       $1 billion                100,000 bpd

May 2002        $80 million               25,000 bpd

Sept. 2002      $ 1.6 billion             2 billion cfd

October         $750 million              3 billion cfd

January 2004    $200 million (Inpex       260,000 bpd
                stake); China
                $2.5 billion

August          $ 178 million             No production

October 2004    $2 billion                300,000 bpd

2005            ?                         ?

June            $20 million               ?

July 2006       $959 million (major       Expansion to produce
                initial expansion;        250,000 bpd
                extent of Hyundai
                work unknown)

Sept. 2006      $49 million               ?

Dec. 2006       $ 16 billion              3.6 billion cfd

Feb. 2007       $320 million              200,000 ton capacity

Feb. 2007       $4.3 billion              ?

March 2007                                NA

July 2007       $ 12. billion             2 billion cfd

Dec. 2007       $ 15 billion              3.4 billion cfd of
                                          gas/250,000 bpd of oil

2007            $500 million              40,000 bpd

2008            $44 million               ?

Feb. 2008       $2 billion

March 2008      ?                         ?

April 2008      $7 billion                1 billion cfd

April 2008      $40-$140 million          ?
                (dispute over size)

-                                         300,000 metric tons/yr

June 2008       $ 1.5 billion             47,000 bpd

January 2009    ?                         Capacity is 1 million
                                          tons per year.
                                          Products are exported
                                          from Iran.

March 2009      $8 billion from Indian    20 million tonnes of
                firms/$1.5 billion        LNG annually by 2012
                million PDVSA

August 2009     up to $6 billion if
                new refinery is built

Oct. 2009       $ 1.4 billion

Nov. 2009       $4 billion
                ($2 bn each part)

Feb. 2010       $4.7 billion


Dec. 2011       $l billion                55,000 barrels per day
                                          within five years

Sources: As noted in table, as well as CRS conversations with
officials of the State Department Bureau of Economics, and
officials of embassies of the parent government of some of the
listed companies (2005-2009). Some information comes from various
GAO reports, the latest of which was updated on December 7, 2012,
in GAO-13-173R. "Iran Energy Sector"

Note: CRS has neither the mandate, the authority, nor the means to
determine which of these projects, if any, might constitute a
violation of the Iran Sanctions Act. CRS has no way to confirm the
precise status of any of the announced investments; some
investments may have been resold to other firms or terms altered
since agreement. In virtually all cases, such investments and
contracts represent private agreements between Iran and its
instruments and the investing firms, and firms are not necessarily
required to confirm or publicly release the terms of their
arrangements with Iran. Reported $20 million+ investments in oil
and gas fields, refinery upgrades, and major project leadership are
included in this table. Responsibility for a project to develop
Iran's energy sector is part of ISA investment definition.

Table 6. Firms That Sold Gasoline to Iran

Vitol of Switzerland (notified GAO it stopped selling to Iran in
early 2010)

Trafigura of Switzerland (notified GAO it stopped selling to Iran
in November 2009)

Glencore of Switzerland (notified GAO it stopped selling in
September 2009)

Total of France (notified GAO it stopped sales to Iran in May 2010)

Reliance Industries of India (notified GAO it stopped sales to Iran
in May 2009)

Petronas of Malaysia (said on April 15, 2010, it had stopped sales
to Iran) (82)

Lukoil of Russia was reported to have ended sales to Iran in April
2010, (83) although some reports continue that Lukoil affiliates
are supplying Iran.

Royal Dutch Shell of the Netherlands (notified GAO it stopped sales
in October 2009)

Kuwait's Independent Petroleum Group (told U.S. officials it
stopped selling gasoline to Iran as of September 2010) (84)

Tupras of Turkey (stopped selling to Iran as of May 2011, according
to the State Department)

British Petroleum of United Kingdom, Shell, Q8, Total, and OMV are
no longer selling aviation fuel to Iran Air, according to U.S.
State Department officials on May 24, 2011

A UAE firm, Golden Crown Petroleum FZE, told the author in April
201 1 that, as of June 29, 2010, it no longer leases vessels for
the purpose of shipping petroleum products from or through Iran

Munich Re, Allianz, Hannover Re (Germany) were providing insurance
and re-insurance for gasoline shipments to Iran. However, they
reportedly have exited the market for insuring gasoline shipments
for Iran (85)

Lloyd's (Britain). The major insurer had been the main company
insuring Iranian gas (and other) shipping, but reportedly ended
that business in July 2010.

According to the State Department on May 24, 2011, Linde of Germany
said it had stopped supplying gas liquefaction technology to Iran,
contributing to Iran's decision to suspend its LNG program.

Some of the firms sanctioned by the Administration on May 24, 2011,
(discussed above), may still be providing service to Iran,
including PCCI (Jersey/Iran); Associated Shipbroking (Monaco); and
Petroleos de Venezuela (Venezuela). Tanker Pacific representatives
told the author in January 2013 that the firm had stopped dealing
with Iran in April 2010 but may have been deceived by IRISL into a
transaction with Iran after that time.

Zhuhai Zhenrong, Unipec, ZhenHua Oil, and China Oil of China.
Zhuhai Zhenrong is no longer selling Iran gasoline, according to
the January 7, 2014, GAO report (GAO--I4-28IR). ZhenHua, a
subsidiary of arms manufacturer Norinco, supplied one third of
Iran's gasoline in March 2010, but there is little information on
supplies since.

Emirates National Oil Company of UAE has been reported by GAO to
still be selling to Iran. Three other UAE energy traders, FAL,
Royal Oyster Group, and Speedy Ship (UAE/Iran) may still be selling
even though they were sanctioned as discussed above.

Hin Leong Trading of Singapore may still be selling gasoline to
Iran, as might Kuo Oil of Singapore.

Some refiners in Bahrain reportedly may still be selling gasoline
to Iran.

Source: CRS conversations with various firms, GAO reports, various
press reports.

Table 7. Entities Sanctioned Under U.N. Resolutions and U.S. Laws
and Executive Orders

(Persons listed are identified by the positions they held when
designated; some have since changed. Sanctions imposed, revoked, or
exempted under the Iran Sanctions Act, CISADA, and IFCA are
discussed above and not included in this table)

Entities Sanctioned Under Resolution 1737

Atomic Energy Organization of Iran (AEIO) Mesbah Energy Company
(Arak supplier); Kalaye Electric (Natanz supplier); Pars Trash
Company (centrifuge program); Farayand Technique (centrifuge
program); Defense Industries Organization (DIO); 7th of Tir (DIO
subordinate); Shahid Hemmat Industrial Group (SHIG)--missile
program; Shahid Bagheri Industrial Group (SBIG)--missile program;
Fajr Industrial Group (missile program); Mohammad Qanadi, AEIO Vice
President; Behman Asgarpour (Arak manager); Ehsan Monajemi (Natanz
construction manager); Jafar Mohammadi (Adviser to AEIO); Gen.
Hosein Salimi (Commander, IRGC Air Force); Dawood Agha Jani (Natanz
official); Ali Hajinia Leilabadi (director of Mesbah Energy); Lt.
Gen. Mohammad Mehdi Nejad Nouri (Malak Ashtar University of Defence
Technology rector); Bahmanyar Morteza Bahmanyar (AIO official);
Reza Gholi Esmaeli (AIO official); Ahmad Vahid Dastjerdi (head of
Aerospace Industries Org., AIO); Maj. Gen. Yahya Rahim Safavi
(Commander in Chief, IRGC)

Entities/Persons Added by Resolution 1747

Ammunition and Metallurgy Industries Group (controls 7th of Tir);
Parchin Chemical Industries (branch of DIO); Karaj Nuclear Research
Center; Novin Energy Company; Cruise Missile Industry Group; Sanam
Industrial Group (subordinate to AIO); Ya Mahdi Industries Group;
Kavoshyar Company (subsidiary of AEIO); Sho'a Aviation (produces
IRGC light aircraft for asymmetric warfare); Bank Sepah (funds AIO
and subordinate entities); Esfahan Nuclear Fuel Research and
Production Center and Esfahan Nuclear Technology Center; 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
serving as deputy Interior Minister; Brig. Gen. Qasem Soleimani
(Qods Force commander); Fereidoun Abbasi-Davani (senior defense
scientist); Mohasen Fakrizadeh-Mahabai (defense scientist); Seyed
Jaber Safdari (Natanz manager); Mohsen Hojati (head of Fajr
Industrial Group); Ahmad Derakshandeh (head of Bank Sepah); Brig.
Gen. Mohammad Reza Zahedi (IRGC ground forces commander); Amir
Rahimi (head of Esfahan nuclear facilities); Mehrdada Akhlaghi
Ketabachi (head of SBIG); 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); Brig. Gen. Mohammad
Hejazi (Basij commander)

Entities Added by Resolution 1803

Thirteen Iranians named in Annex 1 to Resolution 1803; all
reputedly involved in various aspects of nuclear program. Bans
travel for five named Iranians.

Electro Sanam Co.; Abzar Boresh Kaveh Co. (centrifuge production);
Barzaganin Tejaral Tavanmad Saccal; Jabber Ibn Hayan; 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.; Pshgam (Pioneer) Energy Industries; Tamas Co.
(involved in uranium enrichment); Safety Equipment Procurement (AIO
front, involved in missiles)

Entities Added by Resolution 1929

Over 40 entities added; makes mandatory a previously nonbinding
travel ban on most named Iranians of previous resolutions. Adds one
individual banned for travel--AEIO head Javad Rahiqi

Amin Industrial Complex; Armament 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 (only bank added by
Resolution 1929); Kaveh Cutting Tools Company; M. Babaie
Industries; Malek Ashtar University (subordinate of Defense T
echnology and Science Research Center, above); Ministry of Defense
Logistics Export (sells Iranian made arms to customers worldwide);
Mizan Machinery Manufacturing; Modern Industries Technique Company;
Nuclear Research Center for Agriculture and Medicine (research
component of the AEIO); Pejman Industrial Services Corp.; Sabalan
Company; Sahand Aluminum Parts Industrial Company; Shahid Karrazi
Industries; Shahid Sattari Industries; Shahid Sayyade Shirazi
Industries (acts on behalf of the DIO); Special Industries Group
(another subordinate of DIO); Tiz Pars (cover name for SHIG); Yazd
Metallurgy Industries

The following Revolutionary Guard 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; Imensazan Consultant Engineers Institute;
Khatam ol-Anbiya; Makin; Omran Sahel; Oriental Oil Kish; Rah Sahel;

Engineering Institute; Sahel Consultant Engineers; Sepanir; Sepasad
Engineering Company

The following entities owned or controlled by Islamic Republic of
Iran Shipping Lines (IRISL): Irano Hind Shipping Company; IRISL
Benelux; and South Shipping Line Iran

Entities Designated Under U.S. Executive Order 13382
(many designations coincident with designations under U.N. resolutions)

Entity                                   Date Named

Shahid Hemmat Industrial Group (Iran)    June 2005, September 2007

Shahid Bakeri Industrial Group (Iran)    June 2005, February 2009

Atomic Energy Organization of Iran       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

Defense Industries Organization (Iran)   March 2007

June 2007

Pars Trash (Iran, nuclear program); Farayand Technique (Iran,
nuclear program); Fajr Industries Group (Iran, missile program);
Mizan Machine Manufacturing Group (Iran, missile prog.)

Aerospace Industries Organization
(AIO) (Iran)                             September 2007

Korea Mining and Development
Corp. (N. Korea)                         September 2007

October 21, 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 banking
services to Iran's nuclear sector); Mellat Bank SB CJSC (Armenia).
Reportedly has $1.4 billion in assets in UAE; Persia International
Bank PLC (U.K.); Khatam ol Anbiya Gharargah Sazendegi Nooh (main
IRGC construction and contracting arm, with $7 billion in oil, gas
deals); Oriental Oil Kish (Iranian oil exploration firm); Ghorb
Karbala; Ghorb Nooh (synonymous with Khatam ol Anbiya); Sepasad
Engineering Company (Guard construction affiliate); Omran Sahel
(Guard construction affiliate); Sahel Consultant Engineering (Guard
construction affiliate); Hara Company; Gharargahe Sazandegi Ghaem

Individuals: Bahmanyar Morteza Bahmanyar (AIO, Iran missile
official, see above under Resolution 1737); Ahmad Vahid Dastjerdi
(AIO head, Iran missile program); Reza Gholi Esmaeli (AIO, see
under Resolution 1737); Morteza Reza'i (deputy commander, IRGC) See
also Resolution 1747; Mohammad Hejazi (Basij commander). Also,
Resolution 1747; Ali Akbar Ahmadian (Chief of IRGC Joint Staff).
Resolution 1747; Hosein Salimi (IRGC Air Force commander).
Resolution 1737; Qasem Soleimani (Qods Force commander). Resolution

March 12, 2008

Future Bank (Bahrain-based but allegedly controlled by Bank Melli)

July 8, 2008

Yahya Rahim Safavi (former IRGC Commander in Chief); Mohsen
Fakrizadeh-Mahabadi (senior Defense Ministry scientist); Dawood
Agha-Jani (head of Natanz enrichment site); Mohsen Hojati (head of
Fajr Industries, involved in missile program); Mehrdada Akhlaghi
Ketabachi (heads Shahid Bakeri Industrial Group); Naser Maliki
(heads Shahid Hemmat Industrial Group); Tamas Company (involved in
uranium enrichment); Shahid Sattari Industries (makes equipment for
Shahid Bakeri); 7th of Tir (involved in developing centrifuge
technology); Ammunition and Metallurgy Industries Group (partner of
7th of Tir); Parchin Chemical Industries (deals in chemicals used
in ballistic missile programs)

August 12, 2008

Karaj Nuclear Research Center; Esfahan Nuclear Fuel Research and
Production Center (NFRPC); Jabber Ibn Hayyan (reports to Atomic
Energy Org. of Iran, AEIO); Safety Equipment Procurement Company;
Joza Industrial Company (front company for Shahid Hemmat Industrial
Group, SHIG)

September 10, 2008

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 17, 2008

Firms affiliated to the Ministry of Defense, including Armament
Industries Group; Farasakht Industries; Iran Aircraft Manufacturing
Industrial Co.; Iran Communications Industries; Iran Electronics
Industries; and Shiraz Electronics Industries

October 22, 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

Assa Corporation (alleged front for Bank Melli involved in managing
property in December 17, 2008 New York City on behalf of Iran)

March 3, 2009

11 Entities Tied to Bank Melli: 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

February 10, 2010

IRGC General Rostam Qasemi, head of Khatem ol-Anbiya Construction
Headquarters (main IRGC corporate arm) and several entities linked
to Khatem ol-Anbiya, including: Fater Engineering Institute,
Imensazen Consultant Engineers Institute, Makin Institute, and
Rahab Institute

June 16, 2010

--Post Bank of Iran

--IRGC Air Force

--IRGC Missile Command

--Rah Sahel and Sepanir Oil and Gas Engineering (for ties to Khatem
ol-Anibya IRGC construction affiliate)

--Mohammad Ali Jafari--IRGC Commander-in-Chief since September 2007

--Mohammad Reza Naqdi--Head of the IRGC's Basij militia force that
suppresses dissent (since October 2009)

--Ahmad Vahedi--Defense Minister

--Javedan Mehr Toos, Javad Karimi Sabet (procurement brokers or
atomic energy managers)

--Naval Defense Missile Industry Group (controlled by the Aircraft
Industries Org that manages Iran's missile programs)

--Five front companies for IRISL: Hafiz Darya Shipping Co.; Soroush
Sarzamin Asatir Ship Management Co.; Safiran Payam Darya; and Hong
Kong-based Seibow Limited and Seibow Logistics.

Also identified on June 16 were 27 vessels linked to IRISKL and 71
new names of already designated IRISL ships.

Several Iranian entities were also designated as owned or
controlled by Iran for purposes of the ban on U.S. trade with Iran.

November 30, 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

December 21, 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)

May 17, 2011

Bank of Industry and Mine (BIM)

June 23, 2011

--Tidewater Middle East Company; Iran Air; Mehr-e Eqtesad Iranian
Investment Co.

March 28, 2012

Iran Maritime Industrial Company SADRA (owned by IRGC engineering
firm Khatem-ol-Anbiya, has offices in Venezuela); Deep Offshore
Technology PJS (subsidiary of the above); Malship Shipping Agency
and Modality Ltd (both Malta-based affiliates of IRISL); Seyed
Alaeddin Sadat Rasool (IRISL legal adviser); Ali Ezati (IRISL
strategic planning and public affairs manager)

July 12, 2012

--Electronic Components Industries Co. (ECI) and Information
Systems Iran (ISIRAN); Advanced Information and Communication
Technology Center (AICTC) and Hamid Reza Rabiee (software engineer
for AICTC); Digital Medial Lab (DML) and Value Laboratory (owned or
controlled by Rabiee or AICTC); Ministry of Defense Logistics
Export (MODLEX); Daniel Frosh (Austria) and International General
Resourcing FZE)--person and his UAE-based firm allegedly supply
Iran's missile industry.

November 8, 2012

--National Iranian Oil Company; Tehran Gostaresh, company owned by
Bonyad Taavon Sepah; Imam Hossein University, owned by IRGC;
Baghyatollah Medical Sciences University, owned by IRGC or
providing services to it.

December 13, 2012

Atomic Energy Organization of Iran (AEOI) chief Fereidoun Abbasi
Davain; Seyed Jaber Safdari of Novin Energy, a designated affiliate
of AEOI; Morteza Ahmadi Behazad, provider of services to AEOI
(centrifuges); Pouya Control--provides goods and services for
uranium enrichment; Iran Pooya--provides materials for manufacture
of IR-1 and IR2 centrifuges; Aria Nikan Marine Industry--source of
goods for Iranian nuclear program; Amir Hossein Rahimyar--procurer
for Iran nuclear program; Mohammad Reza Rezvanianzadeh--involved in
various aspects of nuclear program; Faratech--involved in Iran
heavy water reactor project; Neda Industrial Group--manufacturer of
equipment for Natanz enrichment facility; Tarh O Palayesh--designer
of elements of heavy water research reactor; Towlid Abzar Boreshi
Iran--manufacturer for entities affiliated with the nuclear

December 21, 2012

SAD Import Export Company (also designated by U.N. Sanctions
Committee a few days earlier for violating Resolution 1747 ban on
Iran arms exports, along with Yas Air) for shipping arms and other
goods to Syria's armed forces; Marine Industries
Organization--designated for affiliation with Iran Ministry of
Defense and Armed Forces Logistics; Mustafa Esbati, for acting on
behalf of Marine Industries; Chemical Industries and Development of
Materials Group--designated as affiliate of Defense Industries
Org.; Doostan International Company--designated for providing
services to Iran Aerospace Industries Org, which oversees Iran
missile industries.

April 11, 2013

Babak Morteza Zanjani--chairmen of Sorinet Group that Iran uses to
finance 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

May 9, 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.

May 31, 2013

Bukovnya AE (Ukraine) for leasing aircraft to Iran Air.

December 12, 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

February 6, 2014

Ali Canko (Turkey) and Tiva Sanat Group, for procuring IRGC-Navy
fast boats; Advance Electrical and Industrial Technologies (Spain),
for procurement for Neka Novin; Ulrich Wipperman and Deutsche
Forfait (Germany), and Deutsche Forfait Americas (U.S.) for
facilitating oil deals for NIOC.

April 29, 2014

Karl Lee (aka Li Fangwei) and 8 China-based front companies:
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.

August 29, 2014 (by both State and Treasury)

By State: Organization of Defensie Innovation and Research (nuclear
weapons research); Nuclear Science and Technology Research
Institute (implements nuclear projects including heavy water
reactor at Arak); Jahan Tech Rooyan Pars: and Mandegar Baspar
Kimiya Company (latter two are involved in procuring carbon fiber
for proscribed aspects of Iran's nuclear program).

By Treasury: Mohammad Javad and Arman Imanirad (for acting on
behalf of Aluminat, which procures aluminum products for Iran's
nuclear program); Nefertiti Shipping (IRISL's agent in Egypt);
Sazeh Morakab (provides services to Shahid Hemat Industrial Group,
SHIG, and Iran's Aircraft Manufacturing Industrial Co., HESA); Ali
Gholami and Marzieh Bozorg (officials of Sazeh Morakab). SHIG
aliases identified: Sahand Aluminum Parts Co and Ardalan
Machineries Co.

Iran-Related Entities Sanctioned Under Executive Order 13224
(Terrorism Entities)

July 25, 2007

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, a previously designated Lebanese construction
company run by Hezbollah; Ahmad al-Shami--financial liaison between
Hezbollah in Lebanon and Martyfs Foundation chapter in Michigan

October 21, 2007

Qods Force and Bank Saderat (allegedly used to funnel Iranian money
to Hezbollah, Hamas, PIJ, and other Iranian supported terrorist

January 16, 2009

Al Qaeda Operatives in Iran: Saad bin Laden; Mustafa Hamid;
Muhammad Rab'a al-Bahtiyti; Alis Saleh Husain

August 3, 2010

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, for providing support
to Hezbollah; Razi Musavi, a Syrian based Iranian official
allegedly providing support to Hezbollah

December 21, 2010

Liner Transport Kish (for providing shipping services to transport
weapons to Lebanese Hezbollah)

October 11, 2011 (For alleged plot against Saudi Ambassador to the

Qasem Soleimani (Qods Force commander); Hamid Abdollahi (Qods
force); Abdul Reza Shahlai (Qods Force); Ali Gholam Shakuri (Qods
Force); Manssor Arbabsiar (alleged plotter)

October 12, 2011

Mahan Air (for transportation services to Qods Force)

February 16, 2012

Ministry of Intelligence and Security of Iran (MOIS)

March 27, 2012

Yas Air (successor to Pars Air); Behineh Air (Iranian trading
company); Ali Abbas Usman Jega (Nigerian shipping agent); Qods
Force officers: Esmail Ghani, Sayyid Ali Tabatabaei, and Hosein

These entities and persons were sanctioned for weapons shipments to
Syria and an October 2011 shipment bound for Gambia, intercepted in

May 31, 2013

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)
for serving as a front for Mahan Air acquisition of aircraft; Hamid
Arabnejad, managing director of Mahan Air.

February 6, 2014

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 or facilitators involved in Iran's
efforts in Afghanistan: Sayyed Kamal Musavi; Alireza Hemmati; Akbar
Seyed Alhosseini; and Mahmud Afkhami Rashidi.

One Iran-based Al Qaeda facilitator (supporting movement of Al
Qaeda affiliated fightes to Syria): Olimzhon Adkhamovich Sadikov
(aka Jafar al-Uzbeki or Jafar Muidinov).

August 29, 2014

Meraj Air (for delivering weapons to Syria from Iran); Caspian Air
(supports IRGC by transporting personnel and weapons to Syria);
Sayyed Jabar Hosseini (manager of Liner Transport Kish which IRGC
uses to support terrorist activities outside Iran); Pioneer
Logistics (Turkey, helps Mahan Air evade sanctions); Asian Aviation
Logistics (Thailand, helps Mahan Air evade sanctions). Pouya Air
designated as alias of Yas Air.

Entities Sanctioned Under the Iran North Korea Syria
Non-Proliferation Act or Executive Order 12938

The designations are under the Iran, North Korea, Syria
Non-Proliferation Act (INKSNA) unless specified. These designations
expire after two years, unless re-designated

Baltic State Technical University and
Glavkosmos, both of Russia                       July 30, 1998

(Both removed --Baltic on January 29, 2010,
and Glavkosmos on March 4, 2010)

D. Mendeleyev University of Chemical
Technology of Russia and Moscow Aviation         January 8, 1999
Institute (Both removed on May 21, 2010)

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      September 17, 2003,
shells to Iran. (Also designated under           removed
Executive Order 12938)                           May 21, 2010

13 entities sanctioned including companies
from Russia, China, Belarus, Macedonia,          April 7, 2004
North Korea, UAE, and Taiwan.

14 entities from China, North Korea,
Belarus, India (two nuclear scientists, Dr.      September 29, 2004
Surendar and Dr. Y.S.R. Prasad), Russia,
Spain, and Ukraine.

14 entities, mostly from China, for alleged
supplying of Iran's missile program.             December 2004 and
Many, such as North Korea's Changgwang Sinyong   January
and China's Norinco and Great                    2005
Wall Industry Corp, have been sanctioned
several times previously. Newly
sanctioned entities included North Korea's
Paeksan Associated Corporation, and
Taiwan's Ecoma Enterprise Co.

9 entities, including those from China
(Norinco yet again), India (two chemical         December 26, 2005
companies), and Austria. Sanctions
against Dr. Surendar of India (see September
29, 2004) were ended, presumably
because of information exonerating him.

7 entities. Two Indian chemical companies
(Balaji Amines and Prachi Poly                   August 4, 2006
Products); two Russian firms (Rosobornexport     (see below for
and aircraft manufacturer Sukhoi);               Rosobornexport
two North Korean entities (Korean                removal)
Mining and Industrial Development, and Korea
Pugang Trading); and one Cuban entity
(Center for Genetic Engineering and

9 entities. Rosobornexport, Tula Design, and
Komna Design Office of Machine                   January 2007 (see
Building, and Alexei Safonov (Russia);           below for
Zibo Chemical, China National                    Tula and Rosoboro-
Aerotechnology, and China National               nexport
Electrical (China). Korean Mining and removal)
Industrial Development (North Korea) for WMD
or advanced weapons sales to
Iran (and Syria).

14 entities, including Lebanese Hezbollah.
Some were penalized for transactions             April 23, 2007
with Syria. Among the new entities sanctioned
for assisting Iran were Shanghai
Non-Ferrous Metals Pudong Development Trade
Company (China); Iran's Defense
Industries Organization; Sokkia Company
(Singapore); Challenger Corporation
(Malaysia); Target Airfreight (Malaysia);
Aerospace Logistics Services (Mexico); and
Arif Durrani (Pakistani national).

13 entities: China Xinshidai Co.; China
Shipbuilding and Offshore International          October 23, 2008.
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.)

16 entities: Belarus: Belarusian Optical
Mechanical Association; Beltech Export;          May 23, 2011
China: Karl Lee; Dalian Sunny Industries;
Dalian Zhongbang Chemical Industries
Co.; Xian Junyun Electronic; Iran:
Milad Jafari; DIO; IRISL; Qods Force; SAD
Import-Export; SBIG; North Korea:
Tangun Trading; Syria: Industrial
Establishment of Defense; Scientific
Studies and Research Center; Venezuela: CAVIM.

Mohammad Minai, senior Qods Force member
involved in Iraq; Karim Muhsin al-               November 8, 2012
Ghanimi, leader of Kata'ib Hezbollah
(KH) militia in Iraq; Sayiid Salah
Hantush alMaksusi, senior KH member; and
Riyad Jasim al-Hamidawi, Iran based KH member

Entities Designated as Threats to Iraqi Stability under
Executive Order 13438

January 8, 2008

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,
alleged to have committed mass kidnapings and planned assassination
attempts against Iraqi Sunni politicians; Mishan al-Jabburi.
Financier of Sunni insurgents, owner of pro-insurgent Al-Zawra
television, now banned; Al Zawra T elevision Station

July 2, 2009

Khata'ib Hezbollah (pro-Iranian Mahdi splinter group); Abu Mahdi

Iranians Sanctioned Under September 29, 2010, Executive Order 13553
on Human Rights Abusers

1. IRGC Commander Mohammad Ali Jafari            September 29, 2010

2. Minister of Interior at time of June 2009 elections Sadeq

3. Minister of Intelligence at time of elections Qolam Hossein

4. Tehran Prosecutor General at time of elections Saeed Mortazavi

5. Minister of Intelligence Heydar Moslehi

6. Former Defense Minister Mostafa Mohammad Najjar

7. Deputy National Police Chief Ahmad Reza Radan

8. Basij (security militia) Commander at time of elections Hossein

9. Tehran Prosecutor General Abbas Dowlatabadi   February 23, 2011
(appointed August 2009). Has indicted large
numbers of Green
movement protesters.

10. Basij forces commander (since October 2009) Mohammad Reza Naqdi
(was head of Basij intelligence during post 2009 election

11. Islamic Revolutionary Guard Corps (IRGC)     June 9, 201 1.

12. Basij Resistance Force

13. Law Enforcement Forces (LEF)

14. LEF Commander Ismail Ahmad Moghadam

15. Ministry of Intelligence and Security of
Iran (MOIS)                                      February 16, 2012

16. Ashgar Mir-Hejazi for human rights abuses
on/after June 12, 2009, and for                  May 30, 2013

providing material support to the IRGC and MOIS.

Iranians Sanctioned Under Executive Order 13572 (April 29, 2011)
for Repression of the Syrian People

Revolutionary Guard--Qods Force                  April 29, 2011

Qasem Soleimani (Qods Force Commander)           May 18, 2011

Mohsen Chizari (Commander of Qods Force
operations and training)                         Same as above

Iranian Entities Sanctioned Under Executive Order 13606 (GHRAVITY)

--Ministry of Intelligence and Security (MOIS); IRGC (Guard Cyber
Defense Command); Law Enforcement Forces; Datak Telecom

Entities Sanctioned Under Executive Order 13608 Targeting Sanctions

--Ferland Company Ltd. for helping NITC deceptively sell Iranian
crude oil

Designations on February 6, 2014 (persons or firms that facilitated
deceptive transactions for or on behalf of persons subject to U.S.
sanctions on Iran)

Three persons based in the Republic of Georgia: Pourya Nayebi,
Houshang Hosseinpour, and Houshang Farsoudeh; and 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

Entities Names as Iranian Government Entities Under Executive Order
13599 Designations made July 12, 2012:

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
NIOV, Naftiran Intertrade Company, Ltd (NICO), or NICO Sarl)

20 Iranian financial institutions (names not released but available
from Treasury Dept.)

58 vessels of National Iranian Tanker Company (NITC)

March 14, 2013:

Dimitris Cambis and several affiliated firms named in Treasury
Dept. press release.

May 9, 2013:

Sambouk Shipping FZC, which is tied to Dr. Dimitris Cambis and his
network of front companies.

May 31, 2013:

Eight petrochemicals companies were designated as Iranian
government entities, including Bandar Imam; Bou Ali Sina; Mobin;
Nouri; Pars; Shahid Tondgooyan; Shazand; and Tabriz.

September 6, 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. Three are based in UAE: AA Energy FZCO; Petro Royal FZE;
and KASB International LLC. The other firm is Swiss Management
Services Sari.

August 29, 2014

Five Iranian banks: Khavarmianeh Bank, Ghavamin Bank,
Gharzolhasaneh Bank, Kish International Bank, and Kafolatbank

Entities Sanctioned Under Executive Order 13622 (For Oil and
Petrochemical Purchases from Iran and Precious Metal Transactions
with Iran)

May 31, 2013:

Jam Petrochemical Company (for purchasing petrochemical products
from Iran); Niksima Food and Beverage JLT (for receiving payments
on behalf of Jam Petrochemical)

August 29, 2014:

Asia Bank (for delivering from Moscow to Tehran of $13 million in
U.S. bank notes paid to representatives of the Iranian government).

Entities Designated as Human Rights Abusers or Limiting Free
Expression Under Executive Order 13628 (Exec. order pursuant to
Iran Threat Reduction and Syria Human Rights Act)

Designations made on November 8, 2012:

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 cyber
attacks; Press Supervisory Board, established in 1986 to issue
licenses to publications and oversee news agencies; Ministry of
Culture and Islamic Guidance; Rasool Jalili, active in assisting
the government's Internet censorship activities; Anm Afzar
Goster-e-Sharif, company owned by Jalili, above, to provide web
monitoring and censorship gear; PekyAsa, another company owned by
Jalili, to develop telecom software.

February 6, 2013:

--Islamic Republic of Iran Broadcasting (IRIB) and Ezzatollah
Zarghami (director and head of IRIB); Iranian Cyber Police (filters
websites and hacks email accounts of political activists);
Communications Regulatory Authority (filters Internet content);
Iran Electronics Industries (producer of electronic systems and
products including those for jamming, eavesdropping

May 30, 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

May 23, 2014:

Morteza Tamaddon for cutting mobile phone communications and
harassing opposition leaders Mir Hosein Musavi and Mehdi Karrubi
when Tamaddon was governor-general of Tehran Province in 2009.

Entities Designated Pursuant to Executive Order I3645

December 12, 2012 (all for providing material support to 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

April 29, 2014, (for connections to deceptive oil dealings for

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)

August 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 comp;anies on behalf of NICO);
Mussafer Polat (for obscuring origin of Iran's gas condensate
sales); Seyedeh Hanje Seyed Nasser Seyyedi (managing director of
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Title Annotation:p. 37-78
Author:Katzman, Kenneth
Publication:Congressional Research Service (CRS) Reports and Issue Briefs
Article Type:Report
Geographic Code:7IRAN
Date:Oct 1, 2014
Previous Article:Iran sanctions.
Next Article:Proposed train and equip authorities for Syria: in brief.

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