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handle is hein.crs/goveplf0001 and id is 1 raw text is: Iran's Petroleum Exports to China and U.S.
Sanctions
Updated May 8, 2024
Many Members in the 118th Congress remain concerned with Iran's ability to raise revenue in
international markets. Iran's petroleum exports have reportedly reached new heights in 2024, with most
exports destined for China. Techniques used to obscure Iranian petroleum exports complicate efforts to
identify Iran's trade patterns and to 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(d) of the FY2012 National Defense Authorization Act (NDAA,
P.L. 112-81; 22 U.S.C. s8513a(d)) directed the President to block from the U.S. financial system foreign
financial institutions that knowingly conduct any significant financial transaction with sanctioned
Iranian banks, including Iran's Central Bank, except for foreign central banks that do not engage in
transactions related to Iranian petroleum. The statute also excepts from such secondary sanctions foreign
financial institutions in countries determined to be significantly reducing their purchases of Iranian crude
oil (President Donald Trump approved the last such exception in 2018). In 2018, President Trump ceased
U.S. participation in the Joint Comprehensive Plan of Action (JCPOA) and issued Executive Order
13846, which reinstates those sanctions that had been terminated pursuant to the JCPOA. E.O. 13846
authorizes sanctions targeting persons, including foreign financial institutions, that the Secretary of the
Treasury determines to have knowingly engaged in a significant transaction for the purchase, acquisition,
sale, transport, or marketing of Iranian petroleum or petroleum products. 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. As part of an emergency supplemental appropriations package signed into law by the President in
April 2024 (P.L. 118-50), Congress enacted two measures related to sanctions on Iranian petroleum
(discussed below).
Iran's Petroleum Exports to the People's Republic of China (PRC)
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. Iranian petroleum exports reportedly hit a record in the first
Congressional Research Service
https://crsreports.congress.gov
IN12267
CRS INSIGHT
Prepared for Members and
Committees of Congress

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