During his campaign, Joe Biden said his administration would impose “targeted sanctions against Iranian support for terrorism and Iran’s ballistic missile program” and promised “ironclad support for Israel.” He also said the U.S. could snap back sanctions if necessary.
On March 9, 2021, Secretary of State Tony Blinken announced sanctions on Islamic Revolutionary Guard Corps (IRGC) interrogators Ali Hemmatian and Masoud Safdari “for their involvement in gross violations of human rights, namely the torture and/or cruel, inhuman, or degrading treatment or punishment (CIDTP) of political prisoners and persons detained during protests in 2019 and 2020 in Iran.” The two men and their families are now barred from entry into the United States.
In April 2021, negotiations on returning to the nuclear deal (JCPOA) with Iran began in Vienna. During those talks, the United States and Iran agreed through intermediaries to establish a working group to discuss the lifting of sanctions imposed by President Trump. At the outset, the State Department said the administration was prepared to lift all the sanctions reimposed and new ones enacted by President Trump. Iran, meanwhile, insisted that all sanctions U.S. and international sanctions be lifted before it would return to compliance with the nuclear deal.
In what was viewed as an effort to encourage Iranian cooperation in the negotiations, the Treasury Department repealed sanctions on former senior National Iranian Oil Co. officials and several companies involved in shipping and trading petrochemical products on June 10, 2021. The administration denied there was any connection to the negotiations. “These actions demonstrate our commitment to lifting sanctions in the event of a change in status or behavior by sanctioned persons,” Secretary of State Blinken said in a statement accompanying the notice of the action.
Nevertheless, opponents of the nuclear deal were critical. “Lifting sanctions during negotiations shows weakness to Iran and tells Tehran to continue its nefarious activities, including nuclear extortion and sending conventional arms to U.S. adversaries,” said Anthony Ruggiero, a former top national security adviser to President Trump. Likewise, Senator Ted Cruz criticized the move to dismantle sanctions “before even the pretense of a deal.”
Iranian sources claimed in late June that Biden negotiators had agreed to lift all sanctions imposed by President Trump, including those related to insurance, oil, and shipping. Officials in the administration did not directly deny the claim; instead, they only said negotiations were continuing. U.S. National Security Adviser Jake Sullivan said there was still “a fair distance to travel” in the talks, including the lifting of sanctions.
Meanwhile, on June 22, 2021, the Justice Department seized 33 of Iran’s state-linked news website domains, which it said were “disguised as news organizations or media outlets, targeted the United States with disinformation campaigns and malign influence operations.”
In June 2021, Iran elected Ebrahim Raisi president. The United States imposed sanctions on Raisi in 2019 over his human rights record, which included “administrative oversight over the executions of individuals who were juveniles at the time of their crime and the torture and other cruel, inhuman or degrading treatment or punishment of prisoners in Iran, including amputations.”
The sanctions could complicate U.S. relations with Iran as they prohibit dealings with him.
In September 2021, in response to a plot to kidnap a U.S.-based journalist and human rights activist, sanctions were imposed on
senior Iran-based intelligence official Alireza Shahvaroghi Farahani, who led a network of affiliates, including Mahmoud Khazein, Kiya Sadeghi, and Omid Noori, tasked with planning this kidnapping on U.S. soil as well as targeting Iranian dissidents in the United Kingdom, Canada, and the United Arab Emirates.
In October 2021, the Treasury Department announced sanctions against Iranian companies and their executives linked to the development of armed drones for attacks on U.S. forces and allies used by terror groups supported by Iran, including Hezbollah in Lebanon, Hamas in the Gaza Strip, and the Houthis in Yemen. According to Haaretz, Israel passed intelligence on the Iranian drone program to the United States, including those sanctioned.
Three individuals linked to the Islamic Revolutionary Guard Corps – Yousef Aboutalebi, Saeed Aghajani (Air Force), and Abdollah Mehrabi (Aerospace Force Self Sufficiency Jihad Organization). Mohammad Ebrahim Zargar Tehrani was subject to secondary sanctions for his involvement in the Kimia Part Sivan Company. That company was also sanctioned for its links to the Islamic Revolutionary Guard Corps (Irgc)-Qods Force. Another company, Oje Parvaz Mado Nafar Company, was sanctioned for its connection to the Islamic Revolutionary Guard Corps.
In December 2021, the Biden administration targeted government officials and organizations involved in repressing protesters, political activists, and prisons where activists have been held in brutal conditions. The following entities were added to the U.S. sanctions list: Iran’s Counter-Terror Special Forces, The Isfahan Central Prison (CAATSA-Iran), The Zahedan Prison (CAATSA-Iran), and Special Units Of Iran’s Law Enforcement Forces were added to the list of sanctioned Iranian organizations. At the same time, several individuals associated with these organizations were also sanctioned: Seyed Reza Mousavi Azami (Special Units Of Iran’s Law Enforcement Forces), Mohsen Ebrahimi (Iran’s Counter-Terror Special Forces), Ali Hemmatian (IRGC), Hassan Karami (Special Units Of Iran’s Law Enforcement Forces), Mohammad Karami (CAATSA – IRAN), Soghra Khodadadi (CAATSA – IRAN), Masoud Safdari (IRGC), and Leila Vaseghi (IRAN-HR).
The administration also began taking measures to tighten existing sanctions. A delegation was sent to the UAE, Iran’s second-largest trade partner and a conduit for Iran’s trade and financial transactions with other countries, with the message that petrochemical companies and banks circumventing sanctions will “face extreme risk if this continues.”
The failure of sanctions, however, was exemplified by the fact that Iran’s oil revenue increased by 40% to about $25 billion in 2021. Iran’s oil minister expected the country’s production would reach the level it had before the U.S. withdrew from the nuclear deal in May 2018 and the imposition of unilateral sanctions.
According to the Wall Street Journal, “Iran established a clandestine banking and finance system to handle tens of billions of dollars in annual trade banned under U.S.-led sanctions, enabling Tehran to endure the economic siege and giving it leverage in multilateral nuclear talks.... [and] buying it time to advance its nuclear program even while negotiations were under way.”
On March 30, 2022, the Treasury Department sanctioned an Iran-based procurement agent and his network of companies that procured ballistic missile propellant-related materials for the Islamic Revolutionary Guard Corps Research and Self Sufficiency Jihad Organization (IRGC RSSJO), the IRGC unit responsible for the research and development of ballistic missiles, as well as Iran’s Parchin Chemical Industries (PCI), an element of Iran’s Defense Industries Organization (DIO). A critical Iranian intermediary involved in procuring parts used to develop a missile propellant on behalf of PCI was also sanctioned.
The action followed Iran’s missile attack on Erbil, Iraq, on March 13, the Iranian-enabled Houthi missile attack against a Saudi Aramco facility on March 25, and other missile attacks by Iranian proxies against Saudi Arabia and the United Arab Emirates. “This action reinforces the United States’ commitment to preventing the Iranian regime’s development and use of advanced ballistic missiles,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “While the United States continues to seek Iran’s return to full compliance with the Joint Comprehensive Plan of Action, we will not hesitate to target those who support Iran’s ballistic missile program. We will also work with other partners in the region to hold Iran accountable for its actions, including gross violations of the sovereignty of its neighbors.”
Amid negotiations to return to the JCPOA, Russia said that Western sanctions imposed on it over its invasion of Ukraine had become an obstacle to completing the deal. Moscow insists that the U.S. and Europe carve out an exception from Ukraine-related sanctions so Russia can trade with Iran. In an apparent effort to ensure Russia supports renewing the nuclear agreement, the Biden administration agreed to exempt Russia’s $10 billion nuclear infrastructure deal with Iran.
Despite fears by critics of the JCPOA that Biden would ease other sanctions, he did not, and they continue to have a devastating impact on the Iranian economy along with internal problems. By the end of February 2023, the Iranian rial dropped to its lowest-ever value, 600,000 rials to the U.S. dollar, down from 360,000 three months earlier. When the JCPOA was signed, the rate was 32,000 rials to the dollar.
Also, in June, Iran signed a 20-year cooperation agreement with Venezuela, which is also under U.S. sanctions. According to Reuters,
The plan includes cooperation in the fields of oil, petrochemicals, defense, agriculture, tourism, and culture. It also includes the repair of Venezuelan refineries and the export of technical and engineering services.
Venezuela has shown exemplary resistance against sanctions and threats from enemies and Imperialists, Iranian President Ebrahim Raisi said.
The 20-year cooperation document is testimony to the will of the two countries to develop ties.
As prospects for a new deal with Iran dimmed, the Biden administration imposed sanctions on a network of Iranian petrochemical producers. “Absent a deal, we will continue to use our sanctions authorities to limit exports of petroleum, petroleum products, and petrochemical products from Iran,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to expose the networks Iran uses to conceal sanctions evasion activities.”
These sanctions build upon past designations of the Triliance Petrochemical Co. for facilitating the sale of Iranian petrochemical and petroleum products worth hundreds of millions of dollars from the National Iranian Oil Company to foreign customers, including China. Another set of sanctions imposed in July targeted “an international network of individuals and entities that has used a web of Gulf-based front companies to facilitate the delivery and sale of hundreds of millions of dollars worth of Iranian petroleum and petrochemical products from Iranian companies to East Asia.”
On August 1, 2022, the administration “took action against companies used by Iran’s Persian Gulf Petrochemical Industry Commercial Co. (PGPICC), one of the nation’s largest petrochemical brokers, to facilitate the sale of tens of millions of dollars worth of Iranian petroleum and petrochemical products from Iran to East Asia...The Department of State also designated two entities that have engaged in the purchase, acquisition, sale, transport, or marketing of Iranian petroleum and petroleum products, including providing logistical support to the Iranian petroleum trade.”
Even as negotiations for rejoining the nuclear deal continued, with reports on the sides being close to an agreement, the Biden administration continued to impose new sanctions. In September, the Ministry of Intelligence and its leader were sanctioned along with several Iranian companies in response to a cyberattack on government institutions in Albania. A few days later, 10 individuals and two entities affiliated with the IRGC were put on the sanctions list for ransomware activity. The State Department also posted a reward of up to $10 million for information identifying three individuals suspected of cyberactivities against U.S. critical infrastructure.
“Ransomware incidents have disrupted critical services and businesses globally. Ransomware actors and other cybercriminals target businesses and critical infrastructure and threaten the physical security and economy of the United States and other nations. The United States is taking actions today to combat and deter ransomware threats,” Blinken said.
Additional sanctions were imposed at the end of September on companies involved in Iran’s petrochemical and petroleum trade. Five are based in China. One operates a commercial crude oil storage facility for Iranian petroleum, and another is a ship manager for a vessel that has transported Iranian petroleum products.
In response to the unrest in Iran following the death of a woman (Mahsa “Zhina” Amini) arrested for allegedly wearing a hijab improperly, the administration sanctioned seven senior leaders of Iran’s security organizations: the Morality Police, the Ministry of Intelligence and Security (MOIS), the Army’s Ground Forces, Basij Resistance Forces, and Law Enforcement Forces. The Treasury Department said:
These officials oversee organizations that routinely employ violence to suppress peaceful protesters and members of Iranian civil society, political dissidents, women’s rights activists, and members of the Iranian Baha’i community. Additional sanctions were imposed on seven senior leaders within Iran’s government and security apparatus for the shutdown of Iran’s Internet access and the continued violence against peaceful protesters. The group includes Interior Minister Ahmad Vahidi, who is also the subject of a “red notice” — an international arrest warrant — from Interpol for his alleged role in the 1994 bombing of the AMIA Jewish center in Argentina.
In another round of sanctions unrelated to Iran’s nuclear violations, the administration sanctioned Iranian officials for the crackdown on protestors and placing restrictions on access to the internet. The targets included IRGC and prison officials. Six senior employees of the Islamic Republic of Iran Broadcasting (IRIB) were also sanctioned. “The Iranian government’s systemic reliance on forced confessions illustrates the government’s refusal to speak truth to its citizens and the international community,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson.
In September 2023, another 29 individuals and entities were sanctioned in connection with the violent suppression of nationwide protests over Amin’s death.
The administration responded to Iran’s transfer of drones to help Russia in its war against Ukraine by sanctioning firms involved in the production or ongoing transfer of unmanned aerial vehicles. Today’s action exposes and holds accountable companies and individuals that have enabled Russia’s use of Iranian-built UAVs to brutalize Ukrainian civilians,” said Secretary of the Treasury Janet L. Yellen.
Apparently, in coordination with the United States, the EU announced a series of sanctions on November 14 – 32 human rights-based designations and four related to the Ukraine war. This was the third round of sanctions imposed in 2022 by the EU.
On November 17, 2022, Treasury announced it “sanctioned 13 companies in multiple jurisdictions facilitating the sale of hundreds of millions of dollars worth of Iranian petrochemicals and petroleum products to buyers in East Asia on behalf of sanctioned Iranian petrochemical brokers Persian Gulf Petrochemical Industry Commercial Co. (PGPICC) and Triliance Petrochemical Co. Ltd. (Triliance), as well as the National Iranian Oil Company (NIOC) and its marketing arm, Naftiran Intertrade Company Ltd. (NICO). Today’s action, the fifth round of designations targeting Iran’s illicit petroleum and petrochemical trade since June 2022, demonstrates our determination to target sanction evasion efforts.”
“Today’s action further demonstrates the complex sanctions evasion methods Iran employs to illicitly sell petroleum and petrochemical products,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to implement sanctions against those actors facilitating these sales.”
Three additional Iranian officials – Hassan Asgari, the governor of Sanandaj, Alireza Moradi, the commander of LEF forces in Sanandaj, and Mohammad Taghi Osanloo, the IRGC Ground Forces commander that oversees Iran’s West Azerbaijan province – involved in the crackdown on protests were sanctioned on November 23.
By the end of 2022, the administration had given up any pretense of pursuing a return to the JCPOA. The escalation of violence within Iran as the regime cracked down on protests, combined with Iran’s growing support for Russia’s aggression in Iran, prompted increasing sanctions by the United States and Europe.
On December 8, 2022, Treasury sanctioned an evasion network led by businessman Sitki Ayan that facilitated the sale of hundreds of millions of dollars worth of oil for the IRGC. A few weeks later, on the 21st, new sanctions targeted the Prosecutor General involved in the prosecution of protestors, as well as leaders of military and paramilitary organizations violently cracking down and detaining protestors, and a company that procures and provides security forces with tools of suppression.
New sanctions were issued on January 6, 2023, targeting suppliers of Iranian drones used to target civilian infrastructure in Ukraine.
On the 23rd, another round of sanctions was directed at a foundation linked to the IRGC, including five of its board members, four senior IRGC commanders, and Iran’s deputy minister of intelligence and security. This action was coordinated with Britain and the European Union.
“Along with our partners, we will continue to hold the Iranian regime accountable so long as it relies upon violence, sham trials, the execution of protestors, and other means of suppressing its people,” said undersecretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson.
In February 2023, the Treasury sanctioned eight senior executives of Paravar Pars Company (Paravar Pars), an Iran-based firm that was previously sanctioned by the United States and European Union for manufacturing Shahed-series unmanned aerial vehicles (UAVs) for Iran’s Islamic Revolutionary Guard Corps Aerospace Force (IRGC ASF). Sanctions were also applied to six Iran-based petrochemical manufacturers or their subsidiaries and three firms in Malaysia and Singapore involved in facilitating the sale and shipment of Iranian petroleum and petrochemicals to Asia. “Iran increasingly turning to buyers in East Asia to sell its petrochemical and petroleum products, in violation of U.S. sanctions,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States remains focused on targeting Tehran’s sources of illicit revenue, and will continue to enforce its sanctions against those who wittingly facilitate this trade.”
Another round of sanctions was announced on March 9, 2023, involving 39 entities involved in a “shadow banking” network. “Iran cultivates complex sanctions evasion networks where foreign buyers, exchange houses, and dozens of front companies cooperatively help sanctioned Iranian companies to continue to trade,” said Deputy Secretary of the Treasury Wally Adeyemo. “Today’s action demonstrates the United States’ commitment to enforcing our sanctions and our ability to disrupt Iran’s foreign financial networks, which it uses to launder funds.”
The same day, the department designated a network of five companies and one individual for supporting Iran’s unmanned aerial vehicle (UAV) procurement efforts. “Iran is directly implicated in the Ukrainian civilian casualties that result from Russia’s use of Iranian UAVs in Ukraine,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to target global Iranian procurement networks that supply Russia with deadly UAVs for use in its illegal war in Ukraine.”
On March 21, sanctions were imposed on four entities and three people in Iran and Turkey, accusing them of involvement in the procurement of equipment to support Iran’s drone and weapons programs.
On June 6, 2023, the Treasury sanctioned a network of seven individuals and six entities in Iran, the People’s Republic of China (PRC), and Hong Kong in connection with Iran’s ballistic missile program. The department said,
This network has conducted financial transactions and facilitated procurement of sensitive and critical parts and technology for key actors in Iran’s ballistic missile development, including Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and its affiliated organizations, Parchin Chemicals Industries (PCI), Aerospace Industries Organization (AIO), Iran Electronics Industries (IEI), and P.B. Sadr, which is PCI’s key intermediary for the procurement of parts to develop missile propellant. PCI, the main beneficiary of this network, is a subsidiary of MODAFL’s Defense Industries Organization (DIO) and produces ammunition, explosives, and solid propellants for rockets and missiles. Iran’s Defense Attaché in Beijing was also sanctioned for his involvement in coordinating military-related procurements from the PRC for Iranian end-users.
In April 2023, the administration renewed a series of waivers that permit Russian-state-controlled firms to make billions of dollars for work at the Fordow nuclear plant where Iran is enriching uranium. Another waiver allows Iran to pay Russia to provide it with limited amounts of enriched uranium, which is used to power a Tehran-based research reactor. Russia can also continue working at the Bushehr nuclear power plant. The administration restored sanctions on Russia’s construction of two new Iranian nuclear power plants.
The International Court of Justice ruled in April 2023 that it did not have jurisdiction to rule on an Iranian legal effort to force the U.S. to release nearly $2 billion in frozen Iranian central bank assets used to compensate victims of terror attacks linked to Iran.
The Treasury Department continued to focus on Iran’s UAV program and announced designating
one individual and six entities in a sanctions evasion network that has facilitated Iran’s procurement of electronic components for its destabilizing military programs, including those used in unmanned aerial vehicles (UAVs). Particularly, this action targets the head of U.S.-designated Iran’s Pardazan System Namad Arman (PASNA), and the entity’s Iran-, Malaysia-, Hong Kong-, and PRC-based front companies and suppliers that have enabled PASNA’s procurement of goods and technology.
Treasury also targeted four senior officials of the Islamic Revolutionary Guard Corps Intelligence Organization (IRGC-IO) for its role in the hostage-taking or wrongful detention of U.S. nationals in Iran.
In May 2023, the European Union imposed sanctions for “serious human rights violations in Iran” on the commander of the Tehran Police Relief Unit of Iran’s Law Enforcement Forces, the spokesman of the Iranian Police, the secretary of the Supreme Council of Cyberspace of Iran (SCC), the IRGC Cooperative Foundation, which is the body responsible for managing the Islamic Revolutionary Guard Corps’ investments, and the Student Basij Organization (SBO), which acts as the IRGC’s violent enforcers on university campuses. The EU has refused, however, to designate the IRGC as a terrorist organization.
Despite all the sanctions imposed to date, Iran has not relented in its pursuit of nuclear weapons and is getting closer to achieving its goal. In testimony before Congress in March 2023, Treasury Secretary Janet Yellen acknowledged “the toughest possible sanctions on Iran” had not changed its behavior. “Sometimes a regime is so committed to a program, that even when the population of that country is suffering immensely because of sanctions we’ve imposed, they continue to prioritize activities that are the ones we’re trying to stop,” she explained.
Gen. Mark Milley, chairman of the Joint Chiefs of Staff, told Congress on March 23, 2023, “From the time of an Iranian decision…Iran could produce fissile material for a nuclear weapon in less than two weeks, and would only take several more months to produce an actual nuclear weapon” (Wall Street Journal, March 23, 2023).
The JCPOA and accompanying UN Security Council Resolution 2231 established sunset dates for most of the restrictions they placed on Iran. To prevent such expirations, European governments could reimpose all sanctions waived by that agreement. According to Henry Rome and Louis Dugit-Gros, “Europe currently regards the threat of snapback as more useful than actual snapback, arguing that Tehran’s worries about reactivated sanctions have helped deter it from enriching uranium to 90 percent or taking other steps to build a nuclear weapon. European officials are concerned that exercising snapback now would motivate Tehran to take such steps, with little prospect that the resultant economic consequences would compel it to reverse course.” Furthermore, China and Russia would use their veto in the Security Council to prevent the UN from approving any sanctions. Consequently, three components of Resolution 2231 will expire on October 18:
- A provision under which Iran is “called upon not to undertake any activity related to ballistic missiles designed to be capable of delivering nuclear weapons.”
- The requirement that countries obtain Security Council permission before transferring certain missiles, drones, and related technology to or from Iran.
- The requirement that all UN member states freeze the assets of twenty-three individuals and sixty-one entities involved in Iran’s nuclear and ballistic missile programs.
Additional sanctions imposed by the EU and Great Britain are also due to expire in October but, unlike Resolution 2231, are not removed automatically. Those measures include:
- Restrictions on individuals and entities involved in Iran’s missile, nuclear, and other weapons programs, including transposition (i.e., copying) of UN designations as well as a broader list of autonomous sanctions.
- Sanctions on more than 300 individuals and entities that were suspended when the JCPOA was implemented, along with other sectoral sanctions suspended at the same time.
- The prohibition on transferring “all types” of weaponry and ballistic missile-related technology to Iran or providing related services.
- Sanctions on transactions and services related to certain types of metal and software.
- Prohibitions on providing aviation and shipping services to Iranian aircraft and vessels suspected of involvement in illicit activity.
The sunsetting of sanctions puts pressure on both Iran and the West. Iran has an incentive to negotiate a new or revised nuclear agreement to avoid the possibility of snapback sanctions being imposed. The West has reason to use snapback as a stick to pressure Iran to restrain its nuclear program and other malevolent activities, if not sign a deal. Tehran may be willing to call the West’s bluff since it already has found ways to circumvent the existing restrictions and can count on its allies to prevent the renewal or imposition of new UN sanctions.
France, Germany, and Great Britain announced they would keep in place sanctions on the IRGC and on trade in ballistic missiles. However, this decision will not prevent the lifting of UN sanctions on ballistic missiles, opening the door for other countries, such as Russia and China, to work with Iran.
On the day Iran released its hostages in exchange for $6 billion and the release of Iranians in U.S. jails, the Treasury Department announced it was sanctioning Mahmoud Ahmadinejad, the former president of Iran, “for enabling the wrongful detention of our citizens, causing immeasurable pain and suffering for both the victims and their families.”
The funds that were unfrozen to win the hostages' release were to be held in the humanitarian channel in Qatar that was established to facilitate the flow of assistance to the people of Iran and is exempt from sanctions.
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