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          aCongressional
            R.fesearch Service






Iran's Petroleum Exports to China and U.S.

Sanctions



Updated February 28, 2024

The October 2023 attacks on Israel by Hamas, a foreign terrorist organization (FTO) with financial ties to
Iran, have increased Congress' concern with Iran's ability to raise revenue in international markets. Iran's
petroleum exports reportedly reached new heights in 2023, with most of the increase attributed to trade
with China. The evasive techniques used to obscure Iranian petroleum exports complicate efforts to
identify Iran's trade patterns, and use sanctions effectively in furtherance of U.S. foreign policy.

Background: U.S. Sanctions
U.S. efforts to limit Iranian income from petroleum and petroleum products (hereinafter petroleum) via
sanctions go back decades. Section 1245 of the FY2012 National Defense Authorization Act (P.L. 112-81)
(22 U.S.C. § 8513a) directed the President to block from the U.S. financial system foreign financial
institutions that conduct transactions with Iran's Central Bank or other designated Iranian banks whose
assets are blocked under the provision, except for foreign central banks that do not engage in transactions
related to Iranian petroleum. The statute excepts from these secondary sanctions foreign financial
institutions in countries determined to be significantly reducing their purchases of Iranian petroleum
(President Trump approved the last such exception in 2018). In 2018, President Trump abrogated U.S.
participation in the Joint Comprehensive Plan of Action (JCPOA), and issued Executive Order 13846, to
reinstate those sanctions that had been terminated in meeting requirements of the JCPOA. The Secretary
of State has authority to designate for sanctions any person determined to have engaged in a transaction
related to the purchase, acquisition, sale, transport, or marketing of Iranian petroleum. The United
States has imposed sanctions on dozens of entities for their role in the illicit shipment of Iranian
petroleum to Asia under E.O. 13846.

Iran's Petroleum   Exports  to China
U.S. secondary sanctions are intended to impose financial or other costs to dissuade foreign persons (third
parties) from participating in activities that U.S. persons cannot engage in-all with the intention of
denying revenue to the primary malign actor. With China's increasing imports of Iranian petroleum,
Chinese buyers may have concluded that the economic benefits of continuing to buy Iranian petroleum
exceed the risks of potential U.S. sanctions for several reasons.

                                                                   Congressional Research Service
                                                                   https://crsreports.congress.gov
                                                                                         IN12267

CRS INSIGHT
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Committees of Congress

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