In the summer of 2010, the U.S. was not the only country to pass sanctions against Iran. Critically, the UN passed a fourth round of sanctions (UNSCR 1929) against Iran in June 2010, underlining the multilateral nature of action being taken against Iran. The sanctions place additional financial curbs on Iran, expand the arms embargo and target Iran’s national shipping line IRISL and entities controlled by the IRGC.
Later in the summer, the European Union, South Korea, Japan, Canada and Australia followed suit with their own set of more robust, unilateral sanctions. These sanctions primarily target energy-related investments in Iran, further inhibiting the country’s foreign investment-starved oil and gas projects.
UANI has compiled the following index of international sanctions against Iran.
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United Nations
Since 2006, the UN has passed four series of sanctions against the Iranian regime for its illegal nuclear program.
- 9 June 2010: The UN passes its fourth round of sanctions against Iran, including “financial curbs, an expanded arms embargo and warnings to UN member states to be vigilant about a range of Iranian activities.”
- “Iran is prohibited from investing in sensitive nuclear activities abroad, like uranium enrichment and reprocessing activities, where it could acquire nuclear technology and know-how, as well as activities involving ballistic missiles capable of delivering nuclear weapons. The ban also applies to investment in uranium mining.”
- “States are prohibited from selling or in any way transferring to Iran eight broad categories of heavy weapons (battle tanks, armored combat vehicles, large caliber artillery systems, combat aircraft, attack helicopters, warships, missiles or missile systems).”
- “Iran is subject to a new regime for inspection of suspicious cargo to detect and stop Iran's smuggling. States should inspect any vessel on their territory suspected of carrying prohibited cargo.”
- “States must require their nationals to exercise vigilance over IRISL, a known sanctions violator… States are requested to report any information on activities by IRISL and Iran's Air's cargo division to evade sanctions, including by renaming vessels.” States are also required to exercise vigilance when doing business with “any Iranian firm,” including the IRGC.
- “States are called upon to prevent any financial service -- including insurance or reinsurance -- and freeze any asset that could contribute to Iran's proliferation… States are called upon to prohibit on their territories new banking relationships with Iran, including the opening of any new branches of Iranian banks, joint ventures and correspondent banking relationships, if there is a suspected link to proliferation. ”
- “A UN ‘Panel of Experts’ will be established to monitor states' implementation of the sanctions, report on sanctions violations and recommend ways to continually improve enforcement.” [See: UNSCR 1929]
- 3 March 2008: The UN passes its third round of sanctions against Iran to ban the trade of dual use technology. The sanctions authorize inspections of air and sea shipments to Iran that are suspected of containing banned items.
- Additionally, the sanctions require financial monitoring of Bank Melli and Bank Saderat, both of which have suspected ties to Iranian proliferation.
- Finally, the sanctions order countries to “freeze the assets of 12 additional companies and 13 individuals with links to Iran’s nuclear or ballistic missile programmes – and require countries to ‘exercise vigilance’ and report the travel or transit of those Iranians. It imposes a travel ban on five individuals linked to Iran’s nuclear effort.” [See: UNSCR 1803]
- 24 March 2007: The UN Security Council unanimously passes its second round of sanctions against Iran, placing an embargo on Iranian weapons exports to prevent its support of terrorist organizations.
- The resolution also prevents nations and international banks from making new loans to Iran.
- The sanctions primarily target Bank Sepah and the Revolutionary Guard in addition to 15 Iranian citizens and 13 organizations, whose assets were frozen. [See: UNSCR 1747]
- 23 December 2006: After Iran turns down the economic and civilian nuclear technology package offered by the five permanent members of the Security Council and Germany (UNSCR 1696), the UN Security Council unanimously passes its first round of sanctions against the Islamic Republic.
- The resolution bans the supply of nuclear-related technology and materials to Iran; it also freezes the assets of “key” individuals and companies linked to Iran’s nuclear program. [See: UNSCR 1737]
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United States
U.S. sanctions against Iran have been seen in three forms: Congressional sanctions, Executive Orders and Treasury Department actions. Most importantly, Congress passed the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) in the summer of 2010.
- 31 December 2011: The U.S. passes sanctions against the Central Bank of Iran in Section 1245 of the National Defense Authorization Act for fiscal year 2012. Specifically, "the sanctions target foreign financial institutions that conduct petroleum and non-petroleum transactions with Iran's central bank or other blacklisted Iranian financial entities."
- "For non-petroleum transactions, from February 29 [2012] the law requires the president to punish private banks that 'knowingly conducted or facilitated any significant financial transaction with the Central Bank of Iran' or other blacklisted entities."
- "For oil-related transactions, from June 28 [2012] the law allows the president to sanction foreign banks that carry out financial transactions 'for the purchase of petroleum or petroleum products from Iran' provided several conditions are met."
- The law gives the president an explicit exemption under which he can choose not to apply sanctions if he determines that the country with primary jurisdiction over the bank has 'significantly reduced' its volume of crude oil purchases.
- "The law provides broad 'waiver' authority under which the president may waive sanctions for up to 120 days, and every 120 days thereafter, if he determines that it 'is in the national security interest of the United States.' If he does so, he must also submit a report to Congress 'providing a justification for the waiver' and describing any concrete cooperation he has received, or expects to receive, as a result of the waiver."
- 28 September 2010: The U.S. passes Executive Order 13553, “blocking property of certain persons with respect to serious human rights abuses by the government of Iran….” The order targets individuals within the IRGC, intelligence, and police communities. It marked the first time a U.S. President levied sanctions against Iran for human rights abuses.
- 1 July 2010: The US passes the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), its toughest sanctions ever, making it more difficult for Iran to procure “refined petroleum as well as the goods and services to modernize its oil and natural gas sector, the mainstay of its economy.”
- The resolution amends the Iran Sanctions Act of 1996 to direct the President to impose three or more specified ISA sanctions if a person has made an investment of $20 million total or more in Iran’s petroleum industry, or has assisted Iranian oil production.
- It also authorizes state and local governments to adopt and enforce asset-divestment measures.
- It seeks to prevent black-market proliferation networks and US-origin technology from reaching Iranian end users by allowing the President to designate a given country as a “Destination of Diversion Concern.”
- Finally, it requires the Director of National Intelligence to report to the President, Secretaries of Defense, Commerce, State, Treasury, and to Congress to identify countries that permit the diversion through the country of dual-use and banned goods and services to “Iranian end-users or Iranian intermediaries.” [See: H.R. 2194 – Comprehensive Iran Sanctions, Accountability, and Divestment Act]
- 6 November 2008: The U.S. Treasury Department revokes Iran’s “U-turn” license, “further restricting Iran’s access to the U.S. financial system.”
- Prior to this action, “U.S. financial institutions were authorized to process certain funds transfers for the direct or indirect benefit of Iranian banks, other persons in Iran or the Government of Iran, provided such payments were initiated offshore by a non-Iranian, non-U.S. financial institution and only passed through the U.S. financial system en route to another offshore, non-Iranian, non-U.S. financial institution. As a result of today's action, U.S. financial institutions are no longer allowed to process these U-turn transfers.”
- “The Treasury Department previously designated Iranian state-owned banks Melli, Mellat, Sepah, Future Bank and the Export Development Bank of Iran for their roles in Iran's weapons proliferation activities, as well as Bank Saderat for providing support to terrorism. While these banks are already prohibited from taking advantage of the U-turn authorization, today's action ends this exception for all remaining Iranian banks, both state-owned and private, including the Central Bank of Iran.”
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European Union
- 23 January 2012: The EU approves an oil embargo against Iran and freezes the assets of the Central Bank of Iran within the EU.
- "Imports of Iranian crude oil and petroleum products" are banned. "The prohibition concerns import, purchase and transport of such products as well as related finance and insurance. Already concluded contracts can still be executed until 1 July 2012."
- "Imports of petrochemical products from Iran into the EU as well as the export of key equipment and technology for this sector to Iran" are outlawed. "New investment in petrochemical companies in Iran as well as joint ventures with such enterprises are also no more allowed."
- "The assets of the Iranian central bank within the EU" are frozen, "while ensuring that legitimate trade can continue under strict conditions."
- 17 June 2010: The EU passes new sanctions that ban investments, technical assistance and technology transfers to Iran’s oil and gas industry.
- The sanctions prohibit the sale of any equipment or technology that can be used in refining, exploration, and the production of liquefied natural gas.
- All trade supports, including export credit guarantees, are banned; insurance contracts covering a period of two years or longer are prohibited (those under two years are discouraged).
- Transfers of more than €10,000 must be reported to national authorities, and transfers of more than €40,000 must receive prior authorization.
- Banking relationships with Iranian financial entities are prohibited, as are the opening of Iranian banks and/or subsidiaries within the EU.
- Finally, ships in EU ports (and at sea—with the permission of the ship’s “flag state”) suspected of carrying prohibited material will be inspected.
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United Kingdom
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Japan
- 3 September 2010: Japan imposes new sanctions that ban transactions with some Iranian banks and target energy-related investments.
- The sanctions target Bank Mellat, the Islamic Republic of Iran Shipping Lines, and the Revolutionary Guard.
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South Korea
- 8 September 2010: South Korea announces sanctions to:
- “Limit the foreign-exchange transactions of more than 100 people and Iranian entities.”
- “Step up inspections of suspicious cargo to and from Iran; put those blacklisted on a travel ban.”
- “Limit investments in Iran's gas and oil refinery industries.”
- “The sanctions target Bank Mellat, the Revolutionary Guard, and the Islamic Republic of Iran Shipping Lines, among other entities.”
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Canada
- 26 July 2010: Canada passes sanctions against Iran under the Special Economic Measures Act.
- The resolution prohibits: “dealing in the property of designated persons;
- exporting or otherwise providing to Iran arms and related material not already banned, items used in refining oil and gas and items that could contribute to Iran’s proliferation activities;
- providing or acquiring financial services to allow an Iranian financial institution (or a branch, subsidiary or office) to be established in Canada, or vice versa;
- making any new investment in the Iranian oil and gas sector;
- establishing correspondent banking relationships with Iranian financial institutions, or purchasing any debt from the government of Iran;
- and providing a vessel owned or controlled by, or operating on behalf of the Islamic Republic of Iran Shipping Lines (IRISL) with services for the vessel’s operation or maintenance.” [See: Special Economic Measures (Iran) Regulations and Special Economic Measures (Iran) Permit Authorization Order]
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Australia
- 15 June 2010: Australia passes sanctions against Bank Mellat, the Islamic Republic of Iran Shipping Line, and General Rostam Qasemi, the commander of Khatem ol-Anbiya Construction Organisation.
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Israel
- 26 June 2011: Israel announces economic sanctions that:
- Amend the ‘Prohibition on Money Laundering Law’ to enable the expansion of oversight and control on entities trading with Iran.
- Restrict contact between the State and companies that trade with Iran.
- Allow for the confiscation of profits from "enemy trading."
- Declare Iran and "bodies linked to it" as enemy elements.
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