U.S. Imposes New Sanctions on Iran

Companies Respond to Sanctions
Targeting Iran Airline
SPND
Blacklisting IRGC
Waivers
More Sanctions Added
Targeting the Regime
Following Attacks and JCPOA Violations
Supporting Iranian Democracy
Further Tightening the Screws
Snapback Sanctions
Election Interference
Biden and Sanctions

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).

Companies Respond to Sanctions

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).
In February 2020, Russian Railways withdrew from a $ 1.3 billion project for electrification of a railway line in Iran (Radio Farda, February 26, 2020).

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).

Targeting Iran’s Airline

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).

SPND

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).

Blacklisting IRGC

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).

Waivers

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).

On May 27, 2020, Secretary Pompeo “terminated the nuclear waiver for three remaining Iran nuclear-related projects. This includes the Arak reactor conversion, the provision of enriched uranium for the Tehran research reactor, and the export of Iran-spent and scrap research reactor fuel. The decision will take effect after a 60-day wind-down.” A waiver for the Bushehr Nuclear Power Plant was extended for 90 days because international assistance for Bushehr predates the Iran nuclear deal.

Assistant Secretary Christopher Ashley Ford explained there were “quite a larger number of projects that had begun under the JCPOA for which U.S. waivers were in place, and those waivers have gradually been taken down one by one with this as the latest step in that progression.” He said, the U.S. is willing to “allow safety and other operations work in connection with the first unit at the Bushehr nuclear reactor, as well as fuel supply and fuel take-back for that reactor,” but that waiver “does not extend to work on any additional units that might be constructed at Bushehr.” He added the U.S. does not believe Iran should be allowed any additional reactors.

The State Department also sanctioned two Iranians involved in “supporting Iran’s proliferation of weapons of mass destruction” (State Department, May 27, 2020).

More Sanctions Added

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 10^th 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).

Targeting the Regime

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).

In December 2019, sanctions were imposed on the Islamic Republic of Iran Shipping Lines and one of its subsidiaries, E-Sail Shipping, based in Shanghai (New York Times, December 11, 2019).

Following Attacks and JCPOA Violations

The United States said it was blacklisting Revolutionary Guards Brigadier General Hassan Shahvarpour for crushing protests and overseeing “the massacre of 148 helpless Iranians in the Mahshahr region in November 2019. The sanctions mean Shahvarpour is banned from entering the United States (Times of Israel, January 19, 2020).

On January 10, 2020, the administration imposed new sanctions “against any individual owning, operating, trading with, or assisting sectors of the Iranian economy including construction, manufacturing, textiles, and mining.” In addition, 17 Iranian metal producers and mining companies were sanctioned in response to Iran’s attack on U.S. troops in Iraq on January 7, 2019. Eight senior Iranian officials who were involved in that attack were also sanctioned” (CNN, January 10, 2020).

On January 23, 2020, sanctioned a network of companies helping Iran circumvent Washington’s sanctions selling products by the National Iranian Oil Company (NIOC). One of the targets is Triliance Petrochemical Co. Ltd., a Hong Kong-based broker with branches in Iran, United Arab Emirates, China and Germany. The others effected are Sage Energy, Peakview, and Beneathco DMCC. The action also applies to some company officials. “All property and interests in property of these persons designated today subject to U.S. jurisdiction are blocked, and U.S persons are generally prohibited from engaging in transactions with them,” the Treasury statement said (Department of the Treasury, January 23, 2020).

The Trump administration said on January 30, 2020, it was renewing for 60 days waivers to sanctions that bar non-U.S. firms from dealing with Iran’s Atomic Energy Organization (AEOI), allowing Russian, Chinese and European companies to continue their work at the Arak heavy-water research reactor, the Bushehr nuclear power plant and the Tehran Research Reactor. The decision was made over the objections of some Republican senators who wanted to end the waivers, but the administration argue the presence or those companies impeded Tehran’s ability to develop nuclear weapons.

The United States also imposed sanctions on the AEOI and its director Ali Akbar Salehi. The Jerusalem Post said “the decision to sanction Salehi and the AEOI would have an impact on Iran's civilian nuclear program because it has operational control over the program, including purchasing parts for nuclear facilities” (Jerusalem Post, January 31, 2020). At the same time, the administration agreed to allow medicine for cancer and organ transplant patients to be supplied through Switzerland. U.S. Special Representative for Iran Brian Hook blamed the Iranian government for any shortages of medicine, accusing it of diverting funds to buy other items or selling medicines on the black market to fund its allies (New York Times, January 30, 2020).

Iranian national Ali Sadr Hashemi Nejad was convicted on March 16, 2020, of a scheme to evade sanctions by funneling a portion of a nearly half-billion-dollar Venezuelan construction contract through the U.S. banking system, using entities in Switzerland, Turkey and the British Virgin Islands to mask Iran’s identity (Courthouse News Service, March 16, 2020).

The State Department announced on March 17, 2020, it is blacklisting nine entities based in South Africa, Hong Kong and China, as well as three Iranian individuals, for engaging in “significant transactions” to trade in Iranian petrochemicals. The Commerce Department also added six people – including five Iranian nuclear scientists – and 18 corporations to the U.S. “Entity List” for aiding Iran's nuclear program, Pakistan’s unsafeguarded nuclear and missile programs, and Russian military modernization efforts. The list bars them from obtaining items subject to U.S. export regulations unless the exporter secures a license (Haaretz, March 17, 2020).

The United States announced on March 26, 2020, the designations of 20 individuals and entities that exploit a sanctions waiver that allows Iraq to import electricity from Iran so they can funnel money to the Islamic Revolutionary Guard Corps-Qods Force. “Today’s designations underscore that the United States will not tolerate profiteering by malign Iranian actors from transactions that take place under the sanctions waiver, and we will remain focused on sanctioning those who do so for The benefit of the IRGC-QF or other designated terrorist groups,” according to a statement by the State Department.” At the same time, the waiver was renewed “to meet the immediate energy needs of the Iraqi people” while also promising to work with the Iraqi government to “reduce Iraq’s energy dependence on Iran” (State Department, March 26, 2020).

Four days later the administration renewed waivers allowing Russian, Chinese and European companies to continue nonproliferation work at the Arak heavy-water research reactor, the Bushehr nuclear power plant, the Tehran Research Reactor and other nuclear programs. The rationale is that these projects will make it more difficult for Iran to produce weapons. The waivers are renewed for 60 days, according to a State Department statement on March 30, 2020 (Reuters, March 30, 2020).

Supporting Iranian Democracy

The administration sanctioned five members of Iran’s Guardian Council and its Elections Supervision Committee for their role in disqualifying Iranians from competing in elections. “The Supreme Leader uses his appointees to deprive the Iranian people of free and fair elections by blocking candidates that do not mirror his radical views,” according to a Treasury Department statement. “The Trump Administration will not tolerate the manipulation of elections to favor the regime’s malign agenda, and this action exposes those senior regime officials responsible for preventing the Iranian people from freely choosing their leaders,” said Secretary Mnuchin. “The United States will continue to support the democratic aspirations of Iranians” (Department of the Treasury, February 20, 2020).

On February 25, 2020, the United States announced it was imposing sanctions on 13 foreign entities and individuals in China, Iraq, Russia, and Turkey for supporting Iran’s missile program. Luo Dingwen and Baoding Shimaotong Enterprises Services Co. Ltd., Gaobeidian Kaituo Precise Instrument Co. Ltd., and Wuhan Sanjiang Import and Export Co. Ltd. were sanctioned along with the Turkish firm as Eren Carbon Graphite Industrial Trading Co. Ltd. (Reuters, February 26, 2020).

Meanwhile, the Paris-based Financial Action Task Force (FATF) placed Iran on its blacklist after the country failed to comply with international anti-terrorism financing norms, which will make it more difficult for foreign companies to invest in the country. Iran had been repeatedly warned it needed to comply with the FATF, but officials feared doing so would interfere with its support for Hezbollah (Haaretz, February 21, 2020).

In response to the COVID-19 crisis, the administration announced on February 27, 2020, that it would allow transactions with Iran’s sanctioned central bank for the distributin of food, medicine and other supplies to help Iran during the pandemic. Humanitarian supplies were already exempt; however, this decision was aimed at facilitating their distribution through Switzerland (Reuters, February 27, 2020).

Further Tightening the Screws

In May 2020, the Treasury Department sanctioned Shanghai Saint Logistics Limited, a Chinese company it says acts as an agent for Mahan Air. It’s the seventh company Treasury has sanctioned as an agent of Mahan Air (Bloomberg, May 19, 2020).

On May 20, 2020, the U.S. imposed sanctions on Iran’s Interior Minister, Abdolreza Rahmani Fazli, for his role in human rights abuses against Iranians, as well as seven senior officials of Iran’s Law Enforcement Forces and a provincial commander of Iran’s Islamic Revolutionary Guard Corps. Sanctions were also applied to the LEF Cooperative Foundation, along with its director and members of the board of trustees. The Foundation “is an economic collaborative controlled by the LEF and is active in Iran’s energy, construction, services, technology, and banking industries.” In addition, “The LEF has played a key role in government crackdowns on protesters, and operates detention centers associated with physical and psychological abuses” (U.S. Treasury Department, May 29, 2020).

The same day, the State Department permanently barred Ali Fallahian and his immediate family from entering the United States.” Fallahian was the head of Iran’s intelligence service from 1989 to 1997. “During that time, he was involved in multiple assassinations and attacks across the globe, including the 1995 killing of Alisa Flatow, a 20-year old U.S. exchange student who was killed in a suicide bombing in the Gaza Strip,” according to Secretary of State Pompeo. “He also bears responsibility for the 1994 bombing of a Jewish community center in Buenos Aires that killed 85 individuals” (U.S. State Department, May 20, 2020).

In a May 27, 2020, briefing, U.S. Special Representative for Iran Brian Hook referenced a poster from Iran’s supreme leader invoking the “final solution,” which, Hook said, “is to endorse the Nazi policy of genocide against the Jews.” He added, “No country that threatens to annihilate Israel or any nation should be allowed the means to do so. The United States stands with Israel and many other partners around the world in ensuring Iran never develops a nuclear weapon” (State Department, May 27, 2020).

On June 8, 2020, the State Department announced sanctions against the Islamic Republic of Iran Shipping Lines (IRISL) and its Shanghai-based subsidiary, E-Sail Shipping Company Ltd (E-Sail). “IRISL has repeatedly transported items related to Iran’s ballistic missile and military programs and is also a longstanding carrier of other proliferation-sensitive items, including Nuclear Suppliers-Group controlled items,” Secretary Pompeo said. The move had been delayed to allow exporters of humanitarian goods to Iran sufficient time to find alternate shipping methods. Now other carriers or shipping methods must be used to avoid exposure to U.S. WMD sanctions (State Department, June 8, 2020).

Iran has been evading sanctions on its oil exports by selling to Venezuela. On June 24, 2020, sanctions were imposed on the five Iranian ship captains who delivered that oil since April. “As a result of today’s sanctions, these captains’ assets will be blocked. Their careers and prospects will suffer from this designation,” Pompeo said (Reuters, June 25, 2020).

On June 25, 2020, sanctions were imposed on four steel, aluminum, and iron companies operating within Iran’s metals sector, including one subsidiary of Mobarakeh Steel Company — Iran’s largest steel manufacturer. One Germany-based and three United Arab Emirates (UAE)-based sales agents were also targeted. “The Iranian regime continues to use profits from metals manufacturers and foreign sales agents to fund destabilizing behavior around the world,” said Secretary Mnuchin. “The United States remains committed to isolating key sectors of the Iranian economy until the revenues from such sectors are refocused toward the welfare of the Iranian people” (Treasury Department, June 25, 2020).

On August 21, 2020, the State Department announced visa restrictions on “14 Iranian individuals for their involvement in gross violations of human rights on behalf of the Iranian regime.” Of the 14, 13 were “involved in a brutal and intricately planned assassination carried out in Switzerland in 1990” and the 14th was sanctioned for his responsibility as director of Evin Prison, “an institution synonymous with torture and other cruel, inhuman, or degrading treatment or punishment.” The prison, the statement said, “has been used to oppress peaceful Iranian protestors and journalists, as well as foreigners who are swept up and imprisoned to be held hostage to squeeze concessions out of their home governments” (State Department, August 21, 2020).

Snapback Sanctions

On September 19, 2020, Pompeo announced sanctions were being re-imposed on Iran pursuant to the snapback process under UN Security Council Resolution 2231 due to Iran’s “significant non-performance of its JCPOA commitments.” This means all provisions of Security Council Resolutions 1696, 1737, 1747, 1803, 1835, and 1929 that were terminated by UNSCR 2231 are back in effect. “Iran,” he said, “is now obligated to suspend enrichment, reprocessing, and heavy-water-related activities.”

“The United States took this decisive action,” Pompeo explained, “because, in addition to Iran’s failure to perform its JCPOA commitments, the Security Council failed to extend the UN arms embargo on Iran, which had been in place for 13 years. The Security Council’s inaction would have paved the way for Iran to buy all manner of conventional weapons on October 18.”

Pompeo added, “the United States expects all UN Member States to fully comply with their obligations to implement these measures. In addition to the arms embargo, this includes restrictions such as the ban on Iran engaging in enrichment and reprocessing-related activities, the prohibition on ballistic missile testing and development by Iran, and sanctions on the transfer of nuclear- and missile-related technologies to Iran, among others. If UN Member States fail to fulfill their obligations to implement these sanctions, the United States is prepared to use our domestic authorities to impose consequences for those failures and ensure that Iran does not reap the benefits of UN-prohibited activity” (State Department, September 19, 2020).

Thirteen of the 15 U.N. Security Council members rejected the U.S. position. The foreign ministers of France, Britain and Germany, issued a joint statement asserting that the United States could not reimpose sanctions because it withdrew from the agreement. “We have worked tirelessly to preserve the nuclear agreement and remain committed to do so,” representatives of the three countries wrote in a letter to the Council (Reuters, September 19, 2020).

A Western diplomat told the Washington Post, “The U.S. can take unilateral sanctions and say they’re part of snapback. But there’s not much more they can do. The [Security] council itself will actively ignore it. And hope elections go a certain way.” Josep Borrell, the E.U.’s foreign policy chief, said before the U.S. decision, “I will continue to do everything possible to ensure the preservation and full implementation of the JCPOA by all. The JCPOA remains a key pillar of the global nonproliferation architecture, contributing to regional security” (Washington Post, September 17, 20, 2020).

On September 21, 2020, the president issued an Executive Order that blocks the property, and interests in property, in the United States of those who contribute to the supply, sale, or transfer of conventional arms to or from Iran, as well as those who provide technical training, financial support and services, and other assistance related to these arms. The President also announced that the administration was imposing new sanctions and export control measures on 27 entities and individuals connected to Iran’s proliferation networks. These actions target the Atomic Energy Organization of Iran for its role in Iran’s nuclear escalation, the Iranian missile organization Shahid Hemmat Industrial Group for facilitating ballistic missile development, and two Iranian entities for their involvement in the transfer and acquisition of conventional arms.

Three days later, the State Department sanctioned several officials and entities for “gross violations of human rights.” Judge Seyyed Mahmoud Sadati was put on the list for his role in the trial and execution of Iranian wrestler Navid Akfari. Judge Mohammad Soltani of Iran’s Revolutionary Court was sanctioned “for sentencing Baha’is in Iran on dubious charges related to their exercise of freedom of expression or belief.” Two prisons – Vakilabad and Orumiyeh – were also on the list for their mistreatment of prisoners (State Department, September 24, 2020).

On October 8, 2020, the Trump administration imposed sanctions against 18 Iranian banks. According to the New York Times, “The action could effectively lock Iran out of the global financial system, further cratering its already collapsing economy” (New York Times, October 8, 2020).

Election Interference

On October 22, 2020, the Treasury Department announced sanctions against the Islamic Revolutionary Guard Corps, the IRGC-Qods Force, and Bayan Rasaneh Gostar Institute, in addition to the Iranian Islamic Radio and Television Union and International Union of Virtual Media, which are owned or controlled by the IRGC-QF. The five entities were targeted for attempting “to sow discord among the voting populace by spreading disinformation online and executing malign influence operations aimed at misleading U.S. voters” (U.S. Treasury, October 22, 2020).

A few days later the Treasury Departmentsanctioned the Iranian Ministry of Petroleum, the National Iranian Oil Company, and the National Iranian Tanker Company for their financial support to Iran’s Islamic Revolutionary Guard Corps-Qods Force IRGC-QF in addition to four people involved in the sale of Iranian gasoline to Venezuela. The department accused the IRGC-QF network of transporting oil to Syria to perpetuate the civil war and to generate revenue for Iran (U.S. Treasury, October 26, 2020).

The Justice Department announced on October 29, 2020, the filing of a complaint to seek the forfeiture of two shipments of Iranian missiles the U.S. Navy seized in transit from Iran’s Islamic Revolutionary Guard Corps to militant groups in Yemen, as well as the sale of approximately 1.1 million barrels of Iranian petroleum the U.S. previously took custody of from four foreign-flagged oil tankers bound for Venezuela.

The State Department imposed sanctions on Arya Sasol Polymer Company, Binrin Limited, Bakhtar Commercial Company, Kavian Petrochemical Company, and Strait Shipbrokers PTE due to transactions for the purchase, acquisition, sale, transport, or marketing of petroleum products from Iran. Individuals involved in the companies – Amir Hossein Bahreini, Lin Na Wei, Murtuza Mustafamunir Basrai, Hosein Firouzi Arani, and Ramezan Oladi – were also sanctioned. The same day the Treasury Department targeted eight entities involved in the sale and purchase of Iranian petrochemical products brokered by Triliance Petrochemical Co. Ltd (State Department, Treasury Department, October 29, 2020).

On November 18, 2020, the Treasury Department announced sanctions on the Islamic Revolution Mostazafan Foundation (Bonyad Mostazafan, or the Foundation), which it described as “an immense conglomerate of some 160 holdings in key sectors of Iran’s economy, including finance, energy, construction, and mining.” The “holdings are expropriated from the Iranian people,” Treasury added, “and are used by the Supreme Leader Ali Khamenei to enrich his office, reward his political allies, and persecute the regime’s enemies.” Iran’s Minister of Intelligence and Security, Mahmoud Alavi, was also targeted for his role in the Iranian regime’s human rights abuses against Iranian citizens (Treasury Department, November 18, 2020).

The Treasury Department imposed sanctions on Shahid Meisami Group and its director, Mehran Babri, accusing the entity of being involved in Iran‘s chemical weapons research and linked to the Iranian Organization of Defensive Innovation and Research, which is blacklisted by Washington. In his previous position, Babri worked for Iran’s Defense Chemical Research Lab (Treasury Department, December 3, 2020).

In December 2020, the Treasury Department took aim at Iran’s involvement in the civil war in Yemen. Hasan Irlu, an official in Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), and the Iranian regime’s envoy to the Houthi rebels in Yemen, was added to the sanctions list. “The appointment of an IRGC-QF official as an envoy to the Houthi rebels in Yemen demonstrates the Iranian regime’s indifference to resolving the conflict, which has led to the widespread suffering of millions of Yemenis,” said Secretary Steven T. Mnuchin. “Additionally, the IRGC-QF’s recruitment of foreign students for intelligence operations illustrates the degree to which the group has infiltrated Iranian society in order to achieve its destructive goals. These efforts, and the pervasive role the IRGC-QF plays in Iranian foreign policy, contribute to the erosion of trust in Iran’s public and private institutions.”

At the same time, Al-Mustafa International University was also added to the sanctions list. The university is used to recruit students to fight on behalf of IRGC-QF-led militias. It also develops student exchanges with foreign universities to indoctrinate students, and entices tourists from western countries to visit Iran to facilitate the collection of intelligence by the IRGC-QF (Treasury Department, December 8, 2020). The following week, two officials associated with the Iranian Ministry of Intelligence were added to the Specially Designated Nationals list because of their direct involvement in the “abduction, detention and probable death” of Robert Levinson, a former Federal Bureau of Investigation agent who went missing in Iran in 2007 (Treasury Department, Wall Street Journal, December 14, 2020).

On January 5, 2021, the U.S. announced new sanctions on 17 companies and one individual in connection with Iran’s metals industry. The Treasury Department said the Iranian regime uses revenue from its metals sector to fund the regime’s destabilising activities around the world (Treasury Department, January 5, 2021). On the 13th, the Treasury Department announced sanctions against three individuals and 16 entities (Treasury Department, January 13, 2021).

On January 15, the State Department announced sanctions on anyone who transfers any of 15 materials used for Iran’s nuclear, military or ballistic missiles program. Companies in Iran, China and the United Arab Emirates were sanctioned for working with the Islamic Republic of Iran Shipping Lines, as well some of their executives. Iran’s Marine Industries Organization, Aerospace Industries Organization and Iran Aviation Industries Organization were also targeted for engaging in activities related to conventional arms proliferation (Jerusalem Post, January 17, 2021).