Unpacking What Remains of Iran Sanctions

On Friday, President Donald Trump waived economic sanctions on Iran, the third time he’s issued a sanctions waiver under a 2015 nuclear deal between Iran and major world powers.

The agreement, known as the Joint Comprehensive Plan of Action, restricted Iran’s controversial nuclear program in exchange for broad relief from international sanctions.

While the United States, the United Nations and the European Union have lifted most nuclear-related sanctions, unilaterally imposed U.S. sanctions going back decades remain in place. These restrictions were levied because of Iran’s human rights violations, support of terrorism, and pursuit of a ballistic missile program.

Sorting out the myriad sanctions requires “a team of lawyers,” said Alex Vatanka of the Middle East Institute in Washington.

“It’s a maze, in many ways,” Vatanka said.

Here is the status of key sanctions on Iran, based largely on a recent Congressional Research Service (CRS) report, as well as those with the Treasury and State departments:

​What sanctions relief Iran has received under the nuclear deal

As part of the deal, the U.S. agreed to waive several key Iran sanctions laws and revoke related presidential executive orders.

The U.S. waived all provisions of the Iran Sanctions Act (ISA), a 1996 law that imposed sanctions on foreign investment in Iran’s energy sector. Among other things, the sweeping legislation mandated penalties on persons and entities that invested more than $20 million in one year in Iran’s energy sector.

The U.S. waived the Iran sanctions provisions of the fiscal year 2012 National Defense Authorization Act (NDAA). Among its other stipulations, the law targeted foreign banks that conducted transactions with Iran’s central bank.

The U.S. waived all provisions of the Iran Threat Reduction and Syria Human Rights Act (ITRSHR) of 2012 except for those that applied to the Islamic Revolutionary Guard Corps (IRGC) and its affiliates. The law had imposed sanctions on companies that provided insurance or reinsurance services for Iran’s national oil company and national tanker company.

The U.S. waived the Iran Freedom and Counter-Proliferation Act (IFCA), a 2012 law that penalized companies that did business with Iran’s energy, shipbuilding and shipping sectors, exported precious metals to Iran, and allowed Iran to deal in U.S. banknotes.

The president revoked a 2012 presidential executive order that slapped sanctions on companies that purchased oil from Iran, conducted transactions with its national oil company or helped Iran buy previous metals and U.S. banknotes.

The president revoked a 2013 executive order that punished companies that do business with Iran’s automotive sector, expanded penalties on sales of precious metals to Iran, and prohibited regional banks that conduct business in the Iranian currency from holding U.S. bank accounts.

Also, the U.S. released Iranian assets frozen because of Iran’s nuclear deal. The CRS report puts the figure around $1.7 billion.

​What sanctions remain in place

The 2015 U.N. Security Council resolution that endorsed the Iran nuclear deal left intact sanctions on Iran’s development of nuclear-capable ballistic missiles as well as Iran’s arms exports and imports.

U.S. and EU sanctions on the Islamic Revolutionary Guard Corps, its affiliates and commanders remain in place.

The Iran-Iraq Arms Non-Proliferation Act of 1992 remain intact. The act imposes penalties on companies that provide Iran with weapons of mass destruction (WMD) technology or advanced conventional weaponry.

Under JCPOA, the U.S. relaxed a ban on imports of Iranian luxury goods, such as carpets and caviar, but most U.S. restrictions on trade with and investment with Iran remain in place, according to the CRS report.

A ban on U.S. financial institutions doing business with Iranian banks remains in place.

The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISDA) of 2010 and a related executive order punishing Iranian human rights violators have survived the nuclear deal.

The legislation allows the Treasury Secretary to imposes travel bans and other sanctions on Iranian individuals and entities accused of human rights violations and other abuses. The Treasury Department announced on Friday that it had designated 14 Iranian individuals and entities under the executive order.

More than $3.7 billion worth of Iranian assets, blocked because of Iran’s human rights record, support for terrorism and missile technology, remain frozen, according to the Congressional Research Service report.

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