United States sanctions against Iran

The Iran and Libya Sanctions Act (ILSA) was signed into law on 5 August 1996 by President Clinton.[9] ISA (the renamed ILSA in 2006) targets both American and non-American businesses that make investments over $20 million in Iran for the development of petroleum resources in Iran. They face having imposed against them two out of seven possible penalties by the United States:[10]

• denial of Export-Import Bank assistance,
• denial of export licenses for exports to the violating company,
• prohibition on loans or credits from United States financial institutions of over $10 million in any 12-month period,
• prohibition on designation as a primary dealer for United States government debt instruments,
• prohibition on serving as an agent of the United States or as a repository for U.S. government funds,
• denial of United States government procurement opportunities (consistent with WTO obligations), and
• a ban on all or some imports of the violating company.

ISA was extended several times under the presidency of George W. Bush,[9] and on December 1, 2016, it was extended under President Barack Obama, before vacating office, for a further ten years.[11]

After the election of Iranian reformist President Mohammad Khatami in 1997, President Clinton eased sanctions on Iran. In 2000 the sanctions for items such as pharmaceuticals, medical equipment, caviar and Persian rugs were reduced.

Iranian financial institutions are barred from directly accessing the U.S. financial system, but they are permitted to do so indirectly through banks in other countries. In September 2006, the United States government imposed sanctions on Bank Saderat Iran, barring it from dealing with U.S. financial institutions, even indirectly. The move was announced by Stuart Levey, the undersecretary for treasury, who accused the major state-owned bank in Iran of transferring funds for certain groups, including Hezbollah. Levey said that since 2001 a Hezbollah-controlled organization had received $50 million directly from Iran through Bank Saderat. He said the United States government will also persuade European banks and financial institutions not to deal with Iran.[18] As of November 2007, the following Iranian banks were prohibited from transferring money to or from United States banks:[19]

• Bank Sepah
• Bank Saderat Iran
• Bank Melli Iran
• Bank Kargoshaee (aka Kargosa’i Bank)
• Arian Bank (aka Aryan Bank)

In other words, these banks were placed on the Office of Foreign Assets Control (OFAC) Specially Designated Nationals List (SDN List). The SDN List is a directory of entities and individuals who have been prohibited from accessing the U.S. financial system. Although difficult there are ways to carry out an OFAC SDN List removal.[20]

As of early 2008, the targeted banks, such as Bank Mellat, had been able to replace banking relationships with a few large sanction-compliant banks with relationships with a larger number of smaller non-compliant banks.[21] In 2008, the United States Department of the Treasury ordered Citigroup Inc. to freeze over $2 billion held for Iran in Citigroup accounts.[22][23]

For individuals and small businesses, these banking restrictions have created a large opportunity for the hawala market, which allows Iranians to transfer money to and from foreign countries using an underground unregulated exchange system.[24] In June 2010, in the case United States v. Banki, the use of the hawala method of currency transfer led to a criminal conviction against a U.S. citizen of Iranian origin. Banki was sentenced to two and a half years in federal prison; however, on the sentencing guidelines, this type of offense could result in imprisonment of up to 20 years.[25]

In 2014, U.S. authorities put a $5 million bounty on Chinese businessman Li Fangwei, whom they alleged to have been instrumental in evading sanctions against Iran's missile programs.[30]

In 2014, French bank BNP Paribas agreed to pay an $8.9 billion fine, the largest ever, for violating United States sanctions. Germany's Commerzbank, France's Credit Agricole and Swiss UBS have also been fined.[31] French President François Hollande said: "When the (European) Commission goes after Google or digital giants which do not pay the taxes they should in Europe, America takes offence. And yet, they quite shamelessly demand 8 billion from BNP or 5 billion from Deutsche Bank."[32]

In 2015, Germany's largest bank Deutsche Bank was fined $258 million for violating U.S. sanctions against Iran, Libya and Syria.[33]

Under the Joint Comprehensive Plan of Action (known commonly as the Iran nuclear deal), signed in July 2015, the United States agreed to cancel most of the U.S. sanctions against Iran, with some safeguard provisions, in return for limitations on Iran's nuclear program.

The Countering America's Adversaries Through Sanctions Act (CAATSA) was enacted in August 2017 and imposed sanctions against Iran, as well as against Russia and North Korea.[44][45] CAATSA requires the President to impose sanctions against: (1) Iran's ballistic missile or weapons of mass destruction programs, (2) the sale or transfer to Iran of military equipment or the provision of related technical or financial assistance, and (3) Iran's Islamic Revolutionary Guard Corps and affiliated foreign persons.[46] The President may also impose sanctions against persons responsible for violations of internationally recognized human rights committed against individuals in Iran,[46] and can waive the imposition or continuation of sanctions.[46][47][48]

In May 2018, the United States President Donald Trump announced an intention to withdraw from the Joint Comprehensive Plan of Action (JCPOA or Iran nuclear deal), and subsequently imposed several new non-nuclear sanctions against Iran,[49] some of which were condemned by Iran as a violation of the deal.

These treasury and other arms of the government, both under Obama and Trump, have basically weakened the JCPOA extensively, which has kept a lot of the sanctions regime intact.[50] In August 2018, the Trump administration reimposed sanctions and warned that anyone doing business with Iran will not be able to do business with the United States.[51][52] However, the United States will be granting waivers to certain countries. For example, Iraq was granted a waiver that would allow the country to continue purchasing gas, energy and food products from Iran on the condition that the purchases were not paid for in United States dollars.[53]

In 2018, the International Court of Justice (ICJ) "ordered" the United States government to revoke the sanctions on the basis of the 1955 United States-Iran "Friendship Treaty", that had been signed with the government that had been overthrown by the 1979 Islamic Revolution.[54] In response, the United States withdrew from two international agreements with Iran.[55]

In October 2018, Reuters reported that JPMorgan Chase bank had "agreed to pay $5.3 million to settle allegations it violated Cuban Assets Control Regulations, Iranian sanctions and Weapons of Mass Destruction sanctions 87 times, the United States Treasury said".[56]

British bank Standard Chartered faced a $1.5 billion fine by the U.S. agencies for violating Iran sanctions.[57]

In November 2018, the United States officially reinstated all sanctions against Iran that had been lifted before the United States withdrew from the JCPOA.[58][59]

In April 2019, the United States threatened to sanction countries continuing to buy oil from Iran after an initial six-month waiver announced in November expired.[60]

In June 2019, Trump imposed sanctions on Iranian Supreme Leader Khamenei, his office and those closely affiliated with his access to key financial resources.[61][62]

On 31 July 2019, the United States placed sanctions on Iran's foreign minister, Mohammad Javad Zarif.[63]

In August 2018, Total S.A. officially withdrew from the Iranian South Pars gas field because of sanctions pressure from the United States,[64] leaving CNPC to take up their 50.1% stake in the natural gas field, of which it had already 30%.[65] It held this 80.1% share until it withdrew its investment in October 2019 due once again to the U.S. sanctions, according to Oil Minister Bijan Zangeneh and the SHANA news agency.[65]

On 19 May 2020, the United States sanctions targeted Shanghai Saint Logistics Limited, a PRC-based company that provides general sales agent services for Mahan Air. The United States claimed that Iran used Mahan Air to carry gold of fuel sales of Venezuela.[66] Also, Iran denied the allegation.[67]

On 8 June 2020, the United States imposed new sanctions of Iran Shipping Lines (IRISL) and its Shanghai-based subsidiary, E-Sail Shipping Company Ltd (E-Sail).[68]

The individuals and companies that had been added to United States sanctions list in 2018:[69]

On 8 May 2019, according to article 36 of the JCPOA agreement, Iran was allowed to reply in case of non-compliance by other signatories. President Rouhani announced that Iran was acting in reply to "the European countries' failure" and held on to stockpiles of excess uranium and heavy water used in nuclear reactors.[70] Rouhani said that Iran gave a 60-day deadline to remaining signatories of the JCPOA to protect it from U.S. sanctions[71] and provide additional economic support.[72] Otherwise, at the end of that deadline, Iran would exceed the limits on its stockpile of enriched uranium.[73] In September 2019, as a third major step to scale down commitments to the 2015 nuclear accord, after another 60-day deadline, Iran nullified all limits on nuclear research and development.[74]

On 25 October 2007, the United States designated the Quds Force, a part of IRGC, a terrorist organization under Executive Order 13224, for providing material support to U.S.-designated terrorist organizations, prohibiting transactions between the group and U.S. citizens, and freezing any assets under United States jurisdiction.[75]

On 18 May 2011, the United States imposed sanctions on Qasem Soleimani, the commander of the Quds Force, along with Syrian president Bashar al-Assad and other senior Syrian officials, due to Soleimani's alleged involvement in providing material support to the Syrian government.[76] He was listed as a known terrorist, which forbade U.S. citizens from doing business with him.[77][78]

On 8 April 2019, the United States imposed economic and travel sanctions on the IRGC and organizations, companies and individuals affiliated with it.[79][80] Hossein Salami was one of the individuals listed.

On 15 April 2019, the United States designated the IRGC as a terrorist organization.[81] The designation is still in force.

On 21 April 2019, a few days before United States sanctions were due to take effect, Iran Supreme Leader Ali Khamenei appointed Hossein Salami as the new commander-in-chief of the Islamic Revolutionary Guard Corps (IRGC).[82][83]

On 7 June 2019, the United States imposed sanctions on some of the petroleum industry in Iran because they were owned by the IRGC.[84]

On 24 June 2019, the US imposed sanctions on eight senior commanders of the navy, aerospace and ground forces components of IRGC.[62]

In May 2020 the United States charged Iranian-Iraqi Amir Dianat and his Iranian business partner with money-laundering on behalf of the Quds Force and with violating sanctions.[85]

The Joe Biden administration levied the sanctions on Iran's Islamic Revolutionary Guard Crops officials on 1 June 2023, who were convicted for plotting assassination abroad, involving against John Bolton and Mike Pompeo. The sanctions targeted Mohammad Reza Ansari, an official with a unit of IRGC-Qods Force “tasked with undertaking covert operations abroad, including planning and conducting intelligence and lethal operations against Iranian dissidents and other non-Iranian nationals in the United States, the Middle East, Europe, and Africa”. The US sanctions will also affect Hossein Hafez Amini, a dual Iranian and Turkish national, for assisting the IRGC-QF’s covert operations.[86]

On 3 September 2019, Trump added the Iran Space Agency, the Iranian Astronautics Research Institute and the Iranian Space Research Center to its sanctions list.[87]

On 20 September 2019, the United States imposed sanctions on the Central Bank of Iran (CBI), the National Development Fund of Iran (NDF) and Etemad Tejarate Pars Co., an Iranian company that was used to transfer money to the Ministry of Defence and Armed Forces Logistics.[88]

In October 2019, the US imposed sanctions on some of the Iranian construction sector which is owned by Iran's Islamic Revolutionary Guard Corps (IRGC), which it regards as a foreign terrorist organization. The US State Department also identified four “strategic materials” being used in connection with military, nuclear, or ballistic missile programs, making trade in them subject to sanctions. However, the department extended nuclear-cooperation waivers on Iran's civil nuclear program, renewing them for 90 days.[89]

On 4 November 2019, the United States imposed new sanctions on the core inner circle of advisers to the Ayatollah Ali Khamenei. The new sanctions included one of his sons, Mojtaba Khamenei, the newly appointed head of Iran's judiciary, Ebrahim Raisi, the supreme leader's chief of staff, Mohammad Mohammadi Golpayegani, and others. The Trump administration also issued $20 million to a reward for information about a former FBI agent who disappeared in Iran 12 years previously.[90]

On 8 October 2020, the United States imposed further sanctions on Iran's financial sector, targeting 18 Iranian banks. The banks targeted are Amin Investment Bank, Bank Keshavarzi Iran, Bank Maskan, Bank Refah Kargaran, Bank-e Shahr, Eghtesad Novin Bank, Gharzolhasaneh Resalat Bank, Hekmat Iranian Bank, Iran Zamin Bank, Karafarin Bank, Khavarmianeh Bank, Mehr Iran Credit Union Bank, Pasargad Bank, Saman Bank, Sarmayeh Bank, Tosee Taavon Bank, Tourism Bank and Islamic Regional Cooperation Bank.[91]

In September 2020, the United States said that it imposed sanctions on Judge Seyyed Mahmoud Sadati, Judge Mohammad Soltani, Branch 1 of the Revolutionary Court of Shiraz, and Adel Abad, Orumiyeh, and Vakilabad Prisons. Elliott Abrams said "the sanctions targeted a judge who sentenced Iranian wrestler Navid Afkari to death," who was convicted of murdering a security guard during the 2018 Iranian protests.[92]

During the 2020 COVID-19 pandemic, health workers and sanctions experts said U.S. sanctions, including financial sanctions and lost oil revenues, were preventing the import of medicine and medical supplies including raw materials and equipment needed to manufacture medicines domestically.[127]

The United States has ostensibly exempted humanitarian items from sanctions, but in practice the prohibition against business with Iranian banks and the reduction in issuance of certain medical export licenses by the United States Treasury Department enforcement agency have caused difficulties in Iran. For example, Iran faces a critical shortage of spare parts that are needed to repair dual-use equipment used to produce medicine. Sanctions have also prevented Iran from procuring active ingredients necessary to manufacture locally produced medicine to treat asthma, cancer, and multiple sclerosis.[128]

In December 2020, according to the central bank chief of Iran, Iran could not pay for a COVID-19 vaccine because of U.S. sanctions against Iranian banks. In March 2020, during the first wave of the pandemic, the United States blocked Iran's request for an emergency $5 billion IMF loan.[129]

After the United States withdrew from the 2015 Iran nuclear deal, many banks and businesses worldwide, including pharmaceutical and medical companies, decided not to conduct any business with Iran due to U.S. sanctions.[130]

As of December 2018, United States sanctions were reportedly affecting hundreds of Iranian university students in the United Kingdom, preventing them from being able to readily pay their tuition fees and forcing them to choose between abandoning their studies or using dangerous means to transfer funds.[131]