Iran sanctions program is one of the most comprehensive and complex regimes currently administered by OFAC. The first round of sanctions was imposed in 1979, in the midst of the U.S. embassy hostage crisis, when the then U.S. President issued E.O. 12170 blocking the assets of the Iranian Government. It was followed by E.O. 12205 which introduced a near total prohibition on trade with and investment in Iran. Since then, there has been more than 20 executive orders issued by U.S. presidents. Some of those added more restrictions and some eased the sanctions. Additionally, there are several pieces of legislations with respect to Iran which has increased the complexity of this regime. Some of the notable ones with major impacts are: ​

• Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, Public Law 111-195, As Amended Through Public Law 112-239, Enacted January 2, 2013 

• Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) (Public Law 112-239)

• Iran Sanctions Act of 1996, as Amended, 50 U.S.C. § 1701 note

• Iran Threat Reduction and Syria Human Rights Act of 2012 H.R. 1905 (Public Law 112-158)

• Section 1245 of the National Defense Authorization Act for Fiscal Year 2012, P.L. 112-81, As Amended Through Public Law 115-91, Enacted December 12, 2017

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The current administration has adopted a "maximum pressure" against Iranian government. In line with this policy, on May 8, 2018, President Trump it withdrew "ended U.S. participation" in the JCPoA. By issuing E.O. 13846 on August 6, 2018, the President re-imposed all sanctions lifted or waived in connection with the JCPOA following expiration of two wind down periods. Since then, the United States imposed 3 rounds of additional sanctions (along with other measures like naming IRGC as an FTO, or designation of Iranian Central Bank under Global Terrorism program). The three recently imposed sanctions are: 

• Sanctions with respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran - May 2019

• Sanctions with respect to Supreme Leader of the Islamic Republic of Iran and the Iranian Supreme Leader’s Office - June 2019

• Sanctions with respect to the Construction, Mining, Manufacturing, or Textiles Sectors of Iran - January 2020

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Iran sanctions program is a comprehensive regime. Also it has list-based regimes within it which targets certain conduct of the Iranian government or other actors. Many tags on the SDN list is related to the Iran program: [HRIT-IR]​, [IFCA]​, [IFSR]​, [IRAN]​, [​IRAN-EO13846], ​[IRAN-EO13876], ​[IRAN-EO13871], ​[IRAN-EO13902], [IRAN-HR]​, [IRAN-TRA]​, [IRGC]​. There are more than a thousand of listed entities and individuals around the world listed with one our couple of these tags. 

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Iran program is codified under 4 different parts in the Code of Federal Regulations. Each of these parts prohibits different activity, blocks different targets' assets, or put different restrictions. 

• 31 CFR Part 535 - Iranian Assets Control Regulations

• 31 CFR Part 560 - Iranian Transactions and Sanctions Regulations

• 31 CFR Part 561 - Iranian Financial Sanctions Regulations

• 31 CFR Part 562 - Iranian Human Rights Abuses Sanctions Regulations

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Although there are several different types of sanctions in the Iran program, here is a non-exhaustive list of sanctions measure in place against Iran: 

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• Travel bans 

• Trade sanctions 

  • Comprehensive ban on import and export with limited carve-outs ​

• Financial sanctions 

  • Asset freezing ​

  • Banking restrictions 

  • Investment restrictions 

  • Provision of financial services (this could also fall under the trade sanctions) 

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The notion of sanctioning non-U.S. firms (even in the absence of any U.S. nexus) for conducting certain activities or as it is known today as secondary sanctions, was majorly used in Iran sanctions program program. The Iran Sanctions Act of 1996, defined some trigger events that if would happen, U.S. could impose some sanctions (from a menu of sanctions) against a foreign firm. Since then, the menu from which the U.S. President could choose sanctions from has expanded as well as the number of mandatory sanctions that the President should impose if determines a company is in violation of certain sanctions against Iran. Also, other pieces of legislations and executive orders added new secondary sanctions authority. One can argue that the use of secondary sanctions in Iran program is higher than the other currently administered programs of OFAC.

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Finally, it is important to note that in November of 2011, the U.S. President identified Iran as a “jurisdiction of primary money laundering concern” under Section 311 of the USA Patriot Act. This imposed more restriction on banks on complexity of any transactions related to Iran. Moreover, On October 25, 2019, the Treasury Department’s Financial Crimes Enforcement Network issued a final rule barring the U.S. financial system from any transactions with Iranian banks or foreign banks acting on behalf of Iranian banks. (Note that Iranian banks already could not have direct relation with the U.S. bank per C.F.R. § 560.516). 

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