The United States imposed sanctions on multiple Iranian companies and individuals accused of running an illegal currency-exchange network on May 10, 2018. On May 15, the United States named Valiollah Seif, the governor of the Iranian central bank, along with Ali Tarzali, who works in the central bank’s international division, “specially designated global terrorists.” The Treasury Department accused the men of secretly funneling millions of dollars through an Iraqi bank to help Hezbollah. The sanctions apply to non-Americans and non-U.S. companies, which means that anyone in any country who does business with Seif or Tarzali could be punished, creating a strong disincentive for governments or businesses considering deals involving Iran’s central bank (AP, May 15, 2018). On May 24, 2018, the Treasury Department announced sanctions on nine individuals and firms accused of procuring jet engines and airplane parts for Iranian airlines previously blacklisted for their support of U.S.-designated terror groups (Wall Street Journal, May 24, 2018).
Critics of the Trump Administration insisted Iran could not be pressured by the United States alone and that it was only the multilateral sanctions that brought Iran to the negotiating table. The U.S. prohibitions on doing business with Iran, however, are having a major impact as American companies cancel deals with Iran and European companies do the same despite their governments’ continuing support of the deal. The following is just a sample of the impact of the U.S. policy:
- The top two shipping container carriers, 2M partners MSC and Maersk Line, announced they are reviewing their plans in Iran due to the changing situation (The Maritime Executive, May 14, 2018). French shipping group CMA CGM later announced it was pulling out of Iran (Reuters, July 7, 2018).
- Hyundai and Mazda cancel their contracts with Iranian automaker (BBC Persian, June 11, 2018).
- Airbus reportedly cancelled its deal to provide aircraft to Iran (AFP, June 16, 2018).
- Korean contractor Daelim has cancelled a $2 billion contract to modernize a refinery in the Iranian city of Esfahan (Global Construction Review, June 4, 2018).
- Hyundai Heavy Industries, the world’s largest shipyard was supposed to deliver container ships to an Iranian shipping company starting in April 2018, but has yet to deliver a single vessel (Korea Times, June 13, 2018).
- PSA, owner of the French carmaker Peugeot, said it had begun to suspend its joint ventures in Iran (Financial Times-UK, June 4, 2018).
- South Korea, one of Iran’s main customers in Asia, will not load any Iranian crude and condensate in July, halting all shipments for the first time in six years (Reuters, July 5, 2018).
- British renewable energy investor Quercus said it will halt the construction of a nearly $600 million solar power plant in Iran due to recently imposed U.S. sanctions on Tehran (Reuters, August 14, 2018).
- Deutsche Telekom and Deutsche Bahn, two state-owned German companies, along with car manufacturer Daimler and mechanical engineering company Herrenknecht, announced their withdrawal from Iran because of U.S. sanctions (PressTV, August 16, 2018).
- The Dutch airline KLM said it was cancelling flights to Iran after September 22, 2018. The decision was likely a product of the U.S. sanctions, but also coincided with an unexplained decision to deport two Iranian diplomats (Jerusalem Post, July 8, 2018). Subsequently, British Airways and Air France said they would suspend service to Iran (New York Times, August 23, 2018).
- Volkswagen AG agreed to comply with sanctions on Iran and end almost all of its business in the country. The company was given an exemption to do some business under a humanitarian exception. Other German companies, Adidas AG, and Daimler AG, have also said they will scale back or abandon their activities in Iran (Bloomberg, September 19, 2018).
- Despite Berlin’s pledge to keep the Iranian nuclear deal alive, German banks are so scared of breaching U.S. sanctions they are refusing to process payments from Iran. Only 40 to 50 of Germany’s 900 cooperative banks and scores of Austrian banks are still processing payments linked to Iranian deals (Handelsblatt, October 2, 2018).
- Bank of Kunlun Co, the key Chinese conduit for transactions with Iran, is set to halt handling payments from the Islamic Republic (Reuters, October 23, 2018).
- South Korea’s Hyundai Engineering & Construction scrapped a $521 million deal to build a petrochemical complex in Iran (Reuters, October 29, 2018).
- Germany’s largest telecom company, Deutsche Telekom, reportedly cut off phone and Internet service to Iran’s Bank Melli, which is accused of funneling money to terrorist groups (Jerusalem Post, November 26, 2018).
- Chinese Bank of Kunlun Co. told its clients in April 2019 it was ceasing transfers with Iran. Huawei, the world’s second-largest smartphone maker, laid off most of its Iranian staff and Lenovo, the world’s largest computer manufacturer, “banned its Dubai-based distributors from selling to Iran after a warning from the U.S. Treasury Department” (Wall Street Journal, April 25, 2019).
- On March 25, 2019, France announced that it would halt flights to and from French airports by Iran’s Mahan Air. The move followed Germany’s January ban on flights by the Iranian airline (Washington Institute, April 17, 2019).
It was reported that at least 17 U.S. companies did business with Iran using foreign subsidiaries after the Iran nuclear deal went into effect in January 2016. Most appear to be terminating their activities in Iran to avoid crippling sanctions. For example:
- Boeing cancelled a deal to sell 80 aircraft valued at $16.6 billion to Iran (AFP, June 16, 2018).
- General Electric is planning to end sales of oil and natural-gas equipment to Iran (Wall Street Journal, May 31, 2018).
- Dover, a manufacturing conglomerate, said it would end its business in Iran (Wall Street Journal, June 5, 2018).
In another blow to the Iranian economy, the Treasury Department announced on July 9, 2018, it was sanctioning Mahan Travel and Tourism Sdn Bhd, a Malaysia-based General Sales Agent, for acting for or on behalf of Mahan Air, an Iranian airline previously designated in connection with Iran’s support for international terrorism. Mahan Air was sanctioned in 2011 for “providing financial, material and technological support” to Iran’s Revolutionary Guards IRGC-QF). “Mahan Air is the airline of choice for the Islamic Revolutionary Guard Corps-Qods Force, facilitating its support to terrorism across the Middle East. Mahan’s regular flights to Syria are used to prop up the Assad regime and deliver weapons, foreign fighters, and Iranian operatives who sow violence and unrest across the region,” said Secretary of the Treasury Steven Mnuchin. “The United States government has been very clear about the deadly role played by Mahan Air. Our action against an independent company providing General Sales Agent services to Mahan makes clear to all in the aviation industry that they urgently need to sever all ties and distance themselves immediately from this airline” (U.S. Department of the Treasury, July 9, 2018).
On August 7, “snapback” sanctions came into force targeting Iranian purchases of U.S. dollars, metals trading, coal, industrial software and its auto sector. President Trump tweeted, “Anyone doing business with Iran will NOT be doing business with the United States” (Haaretz, August 7, 2018).
On October 16, 2018, the Treasury Department designated Iran’s Basij Resistance Force – an arm of the Islamic Revolutionary Guard Corps – and 22 companies and financial institutions associated with the group as “specially designated global terrorists.” The designation freezes Basij assets and blocks U.S. citizens from doing business with the Basij and its conglomerate of banks, investment companies and engineering firms, among other interests (Department of the Treasury, October 16, 2018). The same day sanctions also were applied to Bank Mellat, Mehr Eqtesad Bank, the Iran Tractor Manufacturing Company, Esfehan’s Mobarakeh Steel Company, and other companies linked to investment, commodities and engineering (Reuters, October 16, 2018).
In November 2018, Treasury imposed sanctions on nine targets of an international network that allowed Iran, with the help of Russian companies, to provides millions of barrels of oil to the Syrian government. The Assad regime, in turn, facilitates the movement of hundreds of millions of U.S. dollars to the Islamic Revolutionary Guard Corps-Qods Force for transfer to Hamas and Hezbollah. “Today we are acting against a complex scheme Iran and Russia have used to bolster the Assad regime and generate funds for Iranian malign activity,” said Treasury Secretary Steven Mnuchin. “Central Bank of Iran officials continue to exploit the international financial system, and in this case even used a company whose name suggests a trade in humanitarian goods as a tool to facilitate financial transfers supporting this oil scheme” (Department of the Treasury, November 20, 2018).
On January 28, 2019, the Justice Department charged the Chinese telecom firm Huawei, several subsidiaries and its chief financial officer, Meng Wanzhou, with bank fraud by evading economic sanctions on Iran (New York Times, January 28, 2019).
In March 2019, the administration blacklisted 31 Iranian nationals and organizations that allegedly supported or were associated with Iran’s past efforts at building nuclear weapons through its Organization of Defensive Innovation and Research (SPND). The Department of State previously sanctioned SPND on August 29, 2014, for activities that could contributing to the “proliferation of WMD or their means of delivery.” According to Treasury:
Under its “Amad Plan,” Iran procured materials and equipment, and conducted a variety of activities, relevant to the development of a nuclear explosive device. Iran also re-engineered a ballistic missile’s reentry vehicle for probable use as a delivery system for a nuclear weapon. Scientists have engaged in proliferation-sensitive research and experiments on behalf of SPND organizations, which spend millions of dollars each year on a broad spectrum of defense-related projects (Department of the Treasury, March 22, 2019).
“Anyone who continues with SPND risks professional, personal and financial international isolation,” according to a senior administration official. They will have difficulty traveling abroad, attending academic conferences or finding work elsewhere.
The action was taken because of Iran’s efforts to keep the scientists and staff who worked on the nuclear project together to continue research that could be used for a weapon. Another administration official explained, “This was a way to keep the gang together as it were, and to provide a reconstitution capability for that weapons program for the Iranian regime should it choose to use that” (NBC News, March 22, 2019).
In March 2019, the Wall Street Journal reported the U.S. had discovered a “vast network” operating in Turkey and the United Arab Emirates that helped Iran exchange over $1 billion in currency to finance Iranian military operations. The Treasury Department sanctioned more than two dozen currency-exchange houses, trading companies and officials that helped Iran’s military exchange Iranian rials into euros and U.S. dollars. “This vast network is just the latest example of the Iranian regime’s use of deceptive practices to exploit the global financial system and divert resources to sanctioned entities,” said Sigal Mandelker, Treasury’s undersecretary for terrorism and financial intelligence (Wall Street Journal, March 26, 2019).
A few days later, another 25 people and organizations were blacklisted, including banks, financial institutions, and front companies based in the three countries, that were working on behalf of the Islamic Revolutionary Guards Corps (IRGC) and Iran’s defense ministry to raise money for their activities (Reuters, March 27, 2019). The entire IRGC was subsequently designated as a Foreign Terrorist Organization (FTO) subject to economic and travel sanctions. Any group or individual that does business with the IRGC could face criminal prosecution for providing material support to a terrorist organization. Furthermore, anyone ever affiliated with the IRGC can now be excluded from entering the United States.
The Treasury Department previously designated the IRGC as a terrorist group; now, it has been added to the State Department’s own list. The European Union banned economic transactions with the IRGC in 2010, a policy unchanged by the Joint Comprehensive Plan of Action (JCPOA).
The State Department action “recognizes the reality that Iran is not only a State Sponsor of Terrorism, but that the IRGC actively participates in, finances, and promotes terrorism as a tool of statecraft,” Trump said in a statement that described the IRGC as “the Iranian government’s primary means of directing and implementing its global terrorist campaign” (CNN, April 8, 2019).
The United States is also seeking to isolate Iran in other ways and to prevent it from accomplishing its goal of creating a sphere of influence that extends through Iraq, Syria and Lebanon. For example, The State Department has proposed punishing Iraqi militias and politicians who are supported by Iranian officials (New York Times, March 19, 2019).
The Trump administration announced April 22, 2019, it won’t renew waivers due to expire on May 2 that allowed Italy, Greece , Taiwan, South Korea, Japan , China, Turkey and India to buy Iranian oil without facing U.S. sanctions. “This decision is intended to bring Iran’s oil exports to zero, denying the regime its principal source of revenue,” according to a statement issued by the White House. “The U.S., Saudi Arabia and the United Arab Emirates, three of the world’s great energy producers, along with our friends and allies, are committed to ensuring that global oil markets remain adequately supplied,” according to the statement (Bloomberg, April 22, 2019).
By the end of May 2019, it appeared all of the countries that had received waivers were in compliance with the U.S. dictate to cease oil purchases. China, India, Turkey, South Korea and Japan have now ended all direct purchases of Iranian crude. Taiwan, Greece and Italy were unable to use their waivers due to banking and insurance issues (Wall Street Journal, May 27, 2019).
A day after it revoked waivers on Iranian oil exports, the administration renewed five of seven sanctions waivers that allow Russia and European nations to conduct civilian nuclear cooperation with Iran for 90 days, shorter than the 180 days that had been granted in the past. The other two waivers — one that allowed Iran to store excess heavy water produced in the uranium enrichment process in Oman, and one that allowed Iran to swap enriched uranium for raw yellowcake with Russia — were not renewed. The waivers allow work at Iran’s Bushehr nuclear plant, the Fordow enrichment facility, the Arak nuclear complex and the Tehran Research Reactor (Reuters, July 30, 2019).
On October 31, 2019, the administration announced it was extending sanctions waivers that were part of the nuclear agreement enabling foreign companies to work with Iran’s civilian nuclear program without U.S. penalties. The waivers were due to expire when Secretary of State Mike Pompeo extended them for another 90 days.
State Department spokeswoman Morgan Ortagus said the move “will help preserve oversight of Iran’s civil nuclear program, reduce proliferation risks, constrain Iran’s ability to shorten its ‘breakout time’ to a nuclear weapon, and prevent the regime from reconstituting sites for proliferation-sensitive purposes.”
“This is disappointing and another lost opportunity to tear up the catastrophic Obama-Iran nuclear deal once and for all,” Senators Ted Cruz and Lindsey Graham said in a statement. “President Trump should immediately order his administration to stop issuing civil nuclear waivers.” They also said they would propose legislation “to reverse this misguided decision” (CBS News, November 1, 2019).
The JCPOA allowed Iran to maintain centrifuges for research purposes at Fordow; however, following Iran’s announcement – and the IAEA’s confirmation – that it had resumed uranium enrichment at its underground Fordow site, Pompeo announced, “The United States will terminate the sanctions waiver related to the nuclear facility at Fordow effective Dec. 15, 2019.” He said, “The right amount of uranium enrichment for the world’s largest state sponsor of terror is zero. Iran originally constructed Fordow as a fortified underground bunker to conduct secret uranium enrichment work, and there is no legitimate reason for Iran to resume enrichment at this previously clandestine site.” He demanded that “Iran should reverse its activity there immediately” (Rebecca Kheel, “Pompeo: US ending sanctions waiver for site where Iran resumed uranium enrichment,” The Hill, (November 18, 2019).
The State Department announced a further ratcheting up of the pressure on Iran focused on its ongoing uranium enrichment activities. “Starting May 4, 2019, assistance to expand Iran’s Bushehr Nuclear Power Plant beyond the existing reactor unit could be sanctionable. In addition, activities to transfer enriched uranium out of Iran in exchange for natural uranium could be sanctionable,” the Department said. “Iran must stop all proliferation-sensitive activities, including uranium enrichment, and we will not accept actions that support the continuation of such enrichment. We will also no longer permit the storage for Iran of heavy water it has produced in excess of current limits; any such heavy water must no longer be available to Iran in any fashion.”
The State Department also announced, “Iran must declare to the IAEA a full account of the prior military dimensions of its nuclear program, and verifiably abandon such work in perpetuity. Additionally, he reiterates his call that Iran must stop enrichment and never pursue plutonium reprocessing” (State Department Press Statement, May 3, 2019).
President Trump signed an executive order May 8, 2019, blocking the assets of people involved in the iron, steel, aluminum, or copper sector of Iran. It also authorizes sanctions against foreign financial institutions that sell goods and services to Iran to help it produce or export those metals. According to Iranian government trade figures, iron, cast iron and steel were the nation’s fourth biggest non-energy export and copper and copper products were its 10th largest.
“Today’s action … puts other nations on notice that allowing Iranian steel and other metals into your ports will no longer be tolerated,” Trump said.
Patrick Clawson, research director for the Washington Institute for Near East Policy, said the new U.S. sanctions also would hurt Iran’s labor market. “They hit [economic] sectors that employ quite a few people in Iran and [that make] products used in metal industries such as the automobile industry,” Clawson said. “So there are quite a few workers who could lose their jobs as a result of difficulties in these industries” (VOA News, May 9, 2019).
On June 7, 2019, the Treasury Department announced sanctions against Iran’s Persian Gulf Petrochemical Industries Company (PGPIC) and 39 subsidiaries and foreign-sales agents. The PGPIC was targeted because it provides financial support for a company controlled by the Islamic Revolutionary Guards Corps. It is the country’s largest and most profitable petrochemical group and accounts for 40 percent of Iran’s petrochemical-production capacity and 50 percent of its petrochemical exports (Radio Farda, June 7, 2019).
On July 18, 2019, the Treasury Department sanctioned a group of individuals and entities based in Iran, China, and Belgium and have acted as a procurement network for Iran’s Centrifuge Technology Company (TESA), which plays a crucial role in Iran’s uranium enrichment nuclear program through the production of centrifuges used in facilities belonging to the Atomic Energy Organization of Iran (AEOI). Treasury sanctioned TESA on November 21, 2011 (U.S. Department of the Treasury, July 18, 2019).
In late June, after Iran shot down a U.S. drone, the administration announced it would bar Ayatollah Ali Khamenei from access to the international financial system and impose sanctions on eight Iranian military commanders and Iran’s foreign minister Mohammad Javad Zarif (New York Times, June 24, 2019). The move against Zarif freezes any assets he might have in the U.S. and prohibits his travel across U.S. borders. Companies and people who engage with Zarif could be sanctioned as well, which could complicate his travel. Treasury Secretary Steven Mnuchin said, “The United States is sending a clear message to the Iranian regime that its recent behavior is completely unacceptable” and Secretary Pompeo explained that Zarif was sanctioned because he is “a key enabler” of the policies of Ayatollah Ali Khamenei (Wall Street Journal, July 31, 2019).
On August 28, 2019, the Treasury announced sanctions against the “Dehghan Network” of Hamed and Hadi Dehghan, who it said had procured and supplied “military-grade electronic components” to an Iranian engineering company that works with the military and the IRGC. It also was blacklisting the “Shariat Network,” controlled by Seyed Hossein Shariat, for supplying aluminum alloy products to Iranian entities already sanctioned for their missile proliferation and nuclear weapons programs.
“As the Iranian regime attempts to use complex schemes to hide its efforts to bolster its WMD [weapons of mass destruction] program, the U.S. government will continue to thwart them at every turn,” said Sigal Mandelker, Treasury Under Secretary for Terrorism and Financial Intelligence (Times of Israel, August 28, 2019).
In addition to sanctions, the Trump administration is also engaging in an information campaign directed at the Iranian people with the aim of convincing them their leaders are to blame for their economic hardship. Social media and the Voice of America are among the tools being used to spread the message. The U.S. effort has intensified in response to disinformation efforts by the Iranians which has also led Facebook and Twitter to shut down hundreds of fake accounts linked to Iran (Wall Street Journal, July 30, 2019).
The media began to circulate stories about the possibility of U.S.-Iran negotiations and President Trump said he was open to talks. However, Iranian President Hassan Rouhani said, “If the United States wants to negotiate, it must lift the sanctions in their entirety before anything....We can’t talk to a criminal” (PressTV, August 6, 2019).
The United States imposed sanctions on the three Iranian space agencies – the Iran Space Agency, Iran Space Research Center and the Astronautics Research Institute – on September 3, 2019, following Iran’s unsuccessful attempt to test a space launch vehicle on August 29. “These designations should serve as a warning to the international scientific community that collaborating with Iran’s space program could contribute to Tehran’s ability to develop a nuclear weapon delivery system,” Pompeo said (Reuters, September 3, 2019).
Following Iranian attacks on Saudi oil facilities, the administration announced on September 20, 2019, it was imposing sanctions on the Iranian national bank. Treasury Secretary Steven Mnuchin said the new sanctions cut off the last remaining source of funds for Iran (Wall Street Journal, September 20, 2019). In addition to the Central Bank of Iran, the National Development Fund of Iran and the Etemad Tejarate Pars Co. were also sanctioned. NDF was a major source of foreign currency and funding to Iran’s military forces, including the Revolutionary Guard, while Etemad Tejarate Pars concealed financial transfers for military purchases (AP, September 20, 2019).
During the UN General Assembly meeting in September 2019, French President Macron reportedly sought to arrange a meeting or phone call with Trump, which the president was prepared to accept, but Rouhani said he would not engage in any talks unless all sanctions were first lifted. “No responsible government should subsidize Iran’s bloodlust,” Trump said during his speech to the General Assembly. “As long as Iran's menacing behavior continues, sanctions will not be lifted. They will be tightened” (White House, September 24, 2019).
On October 31, 2019, the administration imposed sanctions on the construction sector, which it said is “controlled directly or indirectly by the IRGC. The sanctions target “four strategic materials as being used in connection with Iran’s nuclear, military, or ballistic missile programs” and “will help preserve oversight of Iran’s civil nuclear program, reduce proliferation risks, constrain Iran;s ability to shorten its ‘breakout time’ to a nuclear weapon, and prevent the regime from reconstituting sites for proliferation-sensitive purposes” (AFP, October 31, 2019).
On November 4, 2019, sanctions were imposed against Iran’s Armed Forces General Staff and nine individuals who are appointees of, or have acted for or on behalf of, Ali Khamenei. “This action seeks to block funds from flowing to a shadow network of Ali Khamenei’s military and foreign affairs advisors who have for decades oppressed the Iranian people, exported terrorism, and advanced destabilizing policies around the world,” according to the Treasury Department. Secretary Mnuchin added, “These individuals are linked to a wide range of malign behaviors by the regime, including bombings of the U.S. Marine Barracks in Beirut in 1983 and the Argentine Israelite Mutual Association in 1994, as well as torture, extrajudicial killings, and repression of civilians. This action further constricts the Supreme Leader’s ability to execute his agenda of terror and oppression” (U.S. Department of the Treasury, November 4, 2019).