The Office of Foreign Assets Control (OFAC), a unit of the US Department of the Treasury, administers and enforces the principal US sanctions regime targeting Iran. The program is built on overlapping legal authorities, including the International Emergency Economic Powers Act (IEEPA), the National Emergencies Act, the Iran Sanctions Act of 1996, the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) of 2010, the Iran Threat Reduction and Syria Human Rights Act of 2012, and successive executive orders, most notably E.O. 12959 (1995), E.O. 13599, and E.O. 13846 (2018).
The core operational rules are codified in the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. Part 560. In practice, the regime:
- Imposes a near-total trade and investment embargo on Iran by US persons.
- Blocks property of the Government of Iran and the Central Bank of Iran within US jurisdiction.
- Maintains designations on the Specially Designated Nationals and Blocked Persons (SDN) List, including the Islamic Revolutionary Guard Corps (IRGC), designated as a Foreign Terrorist Organization in 2019.
- Applies secondary sanctions that expose non-US firms to penalties for significant transactions with designated Iranian banks, the energy sector, shipping, and metals.
The Joint Comprehensive Plan of Action (JCPOA) of July 2015 led OFAC to lift many nuclear-related secondary sanctions in January 2016. After the US withdrawal announced by President Trump on 8 May 2018, OFAC reimposed sanctions in two tranches (August and November 2018) under the "maximum pressure" campaign. Limited humanitarian exceptions exist for food, medicine, and medical devices, often channeled through the General License and specific license processes, and via the Swiss Humanitarian Trade Arrangement launched in 2020.
Enforcement actions have produced multi-billion-dollar settlements with banks including BNP Paribas (2014) and Standard Chartered (2012, 2019).
Example
In November 2018, OFAC redesignated the National Iranian Oil Company and dozens of Iranian banks to the SDN List as part of the Trump administration's reimposition of sanctions following US withdrawal from the JCPOA.
Frequently asked questions
Yes, but only under narrow OFAC general or specific licenses, mainly for humanitarian goods (food, medicine, medical devices), personal communications software, and certain informational materials.
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