It may sound surprising but Iran has also its own sanctions set-up. Like Russia and China which started to respond to the U.S. (and EU) sanctions with sanctions, Iran created its own sanctions set-up to "punish" those sanctioning Iran and Iranian citizens.
On August 13, 2017 Iran’s legislative branch passed a piece of legislation titled “Law on Countering the Violation of Human Rights and Adventurous and Terrorist Activities of the United States in the Region” (“Act”). (Link to the Act in Persian)
The Act established the legal framework for imposing sanctions against certain targets. It is essentially a list-based/conduct-based sanction program which at this point only targets the United States. Since the passage of the Act there were two rounds of designations. The first designation took place in August of 2019 when Iran’s Ministry of Foreign Affairs (“MOFA”) added Foundation for Defense of Democracies and its director, Mark Dubowitz, to the sanctions list of the Islamic Republic of Iran. (Link) The second round of name addition took place on the last day of the Trump administration. In this latter set of name additions, Iran’s MOFA added 11 high-ranking officials of the Trump’s administration to Iran’s sanctions list. The 11 recently-added individuals are: Donald Trump, Mike Pompeo, Mark Esper, Christopher Miller, Steven Mnuchin, Gina Haspel, Jared Kushner, John Bolton, Brian Hook, Elliott Abrams, and Andrea Gacki. (Link)
Let’s take a closer look at the Act to see how Iran's sanctions work. These sanctions were part of a broader piece of legislation which aimed mainly at addressing the United States "malicious activity" in the Middle East. Similar to the United States, based on Iran's Constitution, once the legislative branch passes a piece of law, then the executive branch (the presidents and his/her cabinet) is obliged to implement the law unless vetoed by the president. The Act was not vetoed by the president and was officially mandated to the Iran’s MOFA on September 25, 2017. The Act requires several steps to be taken by the executive branch. Below, I will first discuss sanctions to be imposed by Iran. I will then discuss some counter-measures aimed at addressing the effects of the United States sanctions.
Sanctions to be imposed by Iran
Section 4 of the Act created 5 grounds for designation of individuals and/or entities. These five grounds relates to the United States’ support for terrorism in the region (Persian Gulf and Western Asia) and they are as follows:
United States’ military and intelligence organizations, their directors, generals, and high-ranking members that played an important role in financing, military support, arms trade, military training and support of the radical terrorist groups in the region like ISIS and Al’Nusra Front;
United States persons who provide support for those stated in paragraph one of this section;
United States persons who plays an important role in organizing, financing, committing act of terrorism against Iran's government and Iranian citizens;
United States persons who, directly or indirectly, provide support to radical terrorist groups. Such supports include financial support, political support and lobbying, propaganda, and supports related to military, intelligence, or arms deals; and,
United States persons who play an important role in supporting the Israel’s government in its acts agains people in the region in particular in Lebanon and Palestine.
Human rights violations-related sanctions
Section 5 of the Act created 3 grounds for designation of individuals and/or entities. These three grounds relates to the systematic human rights violations and they are as follows:
The United States military and intelligence officials involved in violations of human rights of the American citizens and in particular those affected by the travel ban imposed by the United States President, the black citizens of the United States and those killed in Waco siege of 1993;
The United States persons who played an important role in violations of humanitarian law and human rights of people of the region (Persian Gulf and Western Asia) in particular repressive acts of the Israel government and other rouge regimes in the regime; and,
United States citizens who, in breach of international law, committed murder and human rights violations outside of the United States.
Government should create a list of persons and entities falling under above-listed grounds. The list should be updated every six months or alternatively it can be updated as needed.
It is worth mentioning that the final part of section 5 provides a number of carve-outs to the sanctions grounds mainly designed for whistleblowers against the United States.
The sanctions imposed are defined in sections 6, 7, and 8 of the Act and they are as follows:
Section 6: Travel ban for those listed individuals;
Section 7: blocking the assets, subject to Iran’s jurisdiction, of those listed individuals; and,
Section 8: prohibition of any financial transactions with listed individuals within Iran’s financial sector
Counter-measure to address the effect of the United States sanctions
Apart from some vague and broadly worded obligations requiring the executive branch to increase its trade with friendly countries, the Act in section 20 requires the executive branch to provide legal, financial, international and political support to those Iranian persons targeted by the United States sanctions.
Furthermore, in section 21, the Act requires the executive branch to prioritize the foreign companies which does not comply with the United States sanctions when it comes to dealings with a foreign entity.
Finally sections 24 and 25 require the executive branch to implement the law which grant the right to those affected by the United Sanctions to get compensations.
In my opinion, there are several vague points about Iran sanctions at this point (it is indeed a new legal instrument for Iran's government). Whether Iran will clarify and improve its sanctions set-up remains to be seen. Also, whether Iran sanctions could be effective is not clear. Yet, there are parts of the Act which might affect those non-U.S. persons planning to enter the Iranian market in case of relaxation of sanctions.
Iran's sanctions against the United States is part of a recently-emerged trend in which countries sanctioned by the United States (and/or EU) are trying to increase cooperation and to create similar counter measures. Such measures, if nothing else, makes it more difficult to trade internationally.