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United States Sanctions

The U.S. Department of the Treasury continues to impose targeted financial sanctions on the individuals and organizations involved in Iran’s proliferation-related activities, terrorist activities, and human rights violations. The 1979 hostage crisis prompted the U.S. to impose its first set of sanctions against Iran. Since then, the United States has imposed a series of sanctions against Iran through both executive orders and acts of Congress.

In 2008, Stuart Levey, then-Under Secretary for Terrorism and Financial Intelligence at the U.S. Treasury, testified before Congress that, “U.S. designations in this area gain worldwide recognition, particularly among financial institutions. My colleagues and I have traveled worldwide explaining our actions to, and sharing information with, foreign government officials and private sector representatives to help them understand the nature of the threat. The result is that our actions jeopardize designated proliferators' access to the international financial system and put their commercial partners on notice of the threat they pose. Those who continue to do business with them do so at the risk of tainting their reputations or even being designated themselves.”

Major Designated Entities

Islamic Revolutionary Guard Corps (IRGC)

  • Initially designated by the U.S. Treasury in October 2007, the IRGC (Pasdaran, in Persian) has been “has been outspoken about its willingness to proliferate ballistic missiles capable of carrying WMD.” Treasury has designated the group’s branches, including the IRGC army, navy, basij militiamen and Qods forces; and a number of IRGC subsidiaries and front companies, including its construction and engineering arm, Khatam al-Anbiya. The U.S. government has also designated the IRGC leadership, including commander Mohammed Ali Jafari.

        Please see “The Dangers of Doing Business with Iran’s Revolutionary Guards” by FDD Experts Mark Dubowitz & Emanuele Ottolenghi.

Ministry of Defense Armed Forces Logistics (MODAFL)

  • MODAFL was designated by the U.S. Treasury in October 2007 as a result of its connections to Iran’s nuclear weapons activities.

Islamic Republic of Iran Shipping Lines (IRISL)

  • Iran’s major shipping line, IRISL, was designated by the U.S. Treasury in September 2008 for providing logistical services to MODAFL. Treasury subsequently designated dozens of subsidiaries and front companies, in addition to ships owned by IRISL.The full list of designated vessels can be accessed here.

Iranian Banks

  • In addition to targeting Iranian organizations engaged in developing nuclear weapons and supporting terrorism, the U.S. Treasury has put increasing pressure on the banks that enable these activities. A number of Iranian banks and their subsidiaries worldwide have been designated, including Bank Melli, Bank Mellat, and Mehr Bank.

Existing Sanctions

Executive Order 12170 (November 14, 1979)
Issued on November 14, 1979 by President Carter, Executive Order 12170 froze all Iranian assets held in the US, held by the government of Iran and the Central Bank of Iran.

Executive Order 12205 (April 7, 1980)
Enacted on April 7, 1980, Executive Order 12205 prohibited commercial trade with Iran with the exception of food, medical supplies, and donations of clothing.

Executive Order 12211 (April 17, 1980)

Executive Order 12211, issued on April 17, 1980, prohibited the import of Iranian goods or services into the United States and financial transactions supporting travel to Iran.

Iran-Iraq Arms Non-Proliferation Act of 1992

The Iran-Iraq Arms Non-Proliferation Act provided new restrictions on exports including a ban on foreign military sales and export licenses to military equipment for export to Iran. The legislation also gave the President the power to levy sanctions against any person or country who participates in the transfer of sensitive items to Iran.

Executive Order 12957 (March 17, 1995)

Signed by President Bill Clinton on March 17, 1995, Executive Order 12957 prohibited transactions that aided Iran in the development of its petroleum resources.

Executive Order 12959 (May 6, 1995)

Executive Order 12959, issued on May 6, 1995, prohibited the reexportation of any goods or technology to Iran subject to an export license, as well as any investment in anything owned or controlled by the government of Iran.

Iran and Libya Sanctions Act of 1996

The Iran and Libya Sanctions Act of 1996 (ILSA) became the Iran Sanctions Act in 2006 when Libya was removed from the bill's consideration. The legislation linked Iran's energy sector with its support for terrorism and nuclear weapons development by giving the President the authority to levy sanctions against any person who invests in Iran's petroleum resources.

Executive Order 13059 (August 19, 1997)

President Clinton issued Executive Order 13059 on August 19, 1997 clarified Executive Orders 12957 and 12959. In this order, the President reiterated that virtually all trade and investment with Iran was prohibited.

Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010

Signed into law by President Obama on July 1, 2010, the Comprehensive Iran Sanctions, Accountability and Divestment Act requires the president to impose sanctions on Iran's entire refined petroleum supply chain. The bill prohibits the sale of technology, goods and services to Iran's oil and natural gas industry, prevents the U.S. government from awarding contracts to companies that do business in Iran, and targets energy-related joint ventures, investments, and partnerships involving Iranian entities. The president can waive sanctions under certain conditions.

Executive Order (September 28, 2010)
President Obama signed this Executive Order on September 28, 2010 designating Iranian officials connected to gross human rights abuses in Iran.

Executive Order 13574 (May 23, 2011)

President Obama signed Executive Order 13574 on May 23, 2011 authorizing the implementation of sanctions outlined in the Iran Sanctions Act.

Executive Order 13590 (November 21, 2011)

President Obama signed this Executive Order on November 21, 2011 targeting assistance to Iran's upstream oil and gas activities. The order imposes sanctions on involvement in Iran's petrochemical industry.

FY 2012 National Defense Authorization Act (December 31, 2011)

Signed into law by President Obama on December 31, 2011, the FY 2012 National Defense Authorization Act expanded U.S. sanctions against the Central Bank of Iran.

Executive Order 13599 (February 5, 2012)

President Obama signed this Executive Order in February 2012 to block property of Iranian government and financial institutions in the United States, including the Central Bank of Iran

Executive Order 13606 (April 23, 2012)

President Obama signed this Executive Order on April 23, 2012 imposing sanctions on those who provide technology to help the Syrian and Iranian governments carry out human-rights abuses.

Executive Order 13608 (May 1, 2012)

President Obama signed this Executive Order on May 1, 2012 prohibiting certain transactions with and preventing entry into the United States by foreign sanctions evaders relating to Iran and Syria.

Executive Order 13622 (July 30, 2012)

President Obama signed Executive Order 13622 on July 30, 2012 to give the U.S. government the power to sanction foreign financial institutions that conduct transactions with the National Iranian Oil Company (NIOC) and Naftiran Intertrade Company (NICO).

Iran Threat Reduction & Syria Human Rights Act of 2012

Signed into law by President Obama on August 10, 2012, the Iran Threat Reduction & Syria Human Rights Act of 2012 increases sanctions against Iran. It blacklists virtually all of Iran’s energy, financial, and transportation sectors, and cuts off companies that keep doing business with Iran from access to our markets in the United States. This legislation also imposes sanctions to prevent Iran from repatriating any proceeds from its oil sales, depriving the Iranian regime of 80 percent of its hard currency earnings and half of the funds that support its budget.

Senate Joint Resolution 41 (September 22, 2012)

On September 22, 2012, the U.S. Senate passed a resolution ruling out the policy of containing a nuclear-armed Iran, urging increased diplomatic pressure and economic sanctions on Iran. The measure stipulates that it shall not be “construed as an authorization for the use of force.”

Executive Order 13628 (October 9, 2012)

President Obama signed this Executive Order on October 9, 2012 implementing sanctions from the Iran Threat Reduction and Syria Human Rights Act of 2012 and other sanctions measures.

Executive Order 13645 (June 3, 2013)

On June 3, 2103, President Obama signed Executive Order 13645 increasing financial sanctions against Iran. The law targets the activities of non-U.S. financial institutions and commercial businesses with respect to Iran.

The U.S. Treasury has also targeted Iranian leaders complicit in human rights violations; profiles of Iran’s designated human rights violators can be found here.

A complete list of designations can be found on the U.S. Treasury website.