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

Sanctions



Updated November 8, 2024

Many  Members  in the 118th Congress remain concerned with Iran's ability to raise revenue by selling
petroleum, which has been a long-term target of U.S. sanctions. Iran's petroleum exports reportedly
reached new heights in 2024, with nearly all exports going to the People's Republic of China (PRC).
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 (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. §8513a(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, excluding foreign central banks that do not engage in transactions related
to Iranian petroleum. The statute also excepts from secondary sanctions foreign financial institutions in
countries determined to be significantly reducing their purchases of Iranian crude oil (President Trump
approved the last such exception in 2018). In 2018, President Donald Trump ceased U.S. participation in
the Joint Comprehensive Plan of Action (JCPOA) and issued Executive Order 13846, which reinstated
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. The United States has sanctioned dozens of entities for their role in the
shipment of Iranian petroleum to Asia. Congress enacted measures intended to increase sanctions on
Iranian petroleum in an April 2024 emergency supplemental appropriations package (P.L. 118-50).

Iran's Petroleum   Exports   to the People's Republic   of China  (PRC)
U.S. secondary sanctions aim to deny revenue to the primary malign actor by imposing costs to dissuade
foreign persons from participating in activities that are illegal for U.S. persons. Iranian petroleum exports
reportedly hit a record in the first quarter of2024, with almost all going to China (Figure 1). An
October 2024 Economist investigation estimated that Iranian petroleum and petrochemical sales generated

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

CRS INSIGHT
Prepared for Members and
Committees of Congress

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