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GAO-14-598R 1 (2014-05-23)

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GO U.S. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC 20548



May 23, 2014


The Honorable Edward R. Royce
Chairman
Committee on Foreign Affairs
House of Representatives

Iran: State Leads an Interagency Process to Determine Whether to Impose Sanctions
under Section 5(b) of the Iran Sanctions Act

Dear Mr. Chairman:

Iran's efforts to develop its nuclear program threaten regional and global security and present
significant challenges to the United States. The United States and other nations have imposed
sanctions on Iran that have adversely affected the Iranian economy.1 In November 2013, the
United States participated in multilateral talks with Iran regarding the possibility of providing
sanctions relief if Iran addressed international concerns about its nuclear program. These talks
resulted in an agreed-upon joint plan of action to explicitly block near-term Iranian pathways to a
nuclear weapon and allow further talks to reach a long-term comprehensive solution. The
sanctions relief provided for the duration of the talks is currently scheduled to conclude in July
2014.

U.S. sanctions on Iran include those specified in the Iran Sanctions Act of 1996 (Iran Sanctions
Act).2 Section 5(b) of the Iran Sanctions Act authorizes sanctions on persons engaging in
various activities that involve weapons of mass destruction or other military capabilities and are
related to Iran.3 You requested that we review how the Department of State (State) has
implemented the sanctions provisions in Section 5(b). This report describes the process State
and other relevant U.S. agencies use to determine whether to sanction persons under Section
5(b).

To determine the process State and other relevant U.S. agencies use to determine whether to
sanction persons under Section 5(b), we obtained documentation and interviewed State
officials. We interviewed agency officials at the Department of Energy and the Department of
Commerce (agencies identified by State as relevant to the sanctions determination process),
and obtained corroborating documentation about their roles in making this determination. In
'For a description of the effects of sanctions on Iran, see GAO, Iran: U.S. and International Sanctions Have
Adversely Affected the Iranian Economy, GAO 13-326 (Washington, D.C.: Feb. 25, 2013).
21ran and Libya Sanctions Act of 1996, Pub. L. No. 104-172, 110 Stat. 1541, 1543, as amended. The name of the law
was changed to Iran Sanctions Act of 1996 in 2006 by the Iran Freedom Support Act, Pub. L. No. 109-293.
3Under section 14(15) of the Iran Sanctions Act, in general, the term  person means (i) a natural person; (ii) a
corporation, business association, partnership, society, trust, financial institution, insurer, underwriter, guarantor, and
any other business organization, any other nongovernmental entity, organization or group, and any governmental
entity operating as a business enterprise; and (iii) any successor to any entity described in clause (ii). Also, the term
person does not include a government or governmental entity that is not operating as a business enterprise.


GAO-14-598R Iran Sanctions


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