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GAO-17-779R 1 (2017-09-28)

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



September 28, 2017


Congressional Requesters



Iran Sanctions: U.S. Agencies Continue to Implement Processes for Identifying
Potentially Sanctionable Entities

Iran's efforts to develop a nuclear weapons program have threatened regional and global
security and presented significant challenges to the United States. In response to these and
other actions, the United States and other nations imposed sanctions on Iran that have
adversely affected the Iranian economy. In July 2015, multilateral talks with Iran culminated in
the Joint Comprehensive Plan of Action (JCPOA), in which the United States and several other
countries agreed to ease certain sanctions on Iran in exchange for Iran's commitment to limit its
nuclear program as detailed in JCPOA. Also in July 2015, the United Nations called upon Iran
not to undertake any activity related to ballistic missiles designed to be capable of delivering
nuclear weapons-including launches using such ballistic missile technology-until 8 years after
October 18, 2015.1 On January 16, 2016-JCPOA's Implementation Day (Implementation
Day)-the International Atomic Energy Agency verified that Iran had implemented certain
commitments under JCPOA. Also on that day, U.S., European Union, and United Nations
nuclear-related sanctions on Iran specified in JCPOA were lifted, but U.S. sanctions on ballistic
missile procurement and transfers-including those that can be imposed pursuant to Executive
Orders (EO) 12938 and 13382 and the Iran, North Korea, and Syria Nonproliferation Act
(INKSNA)-were not.2 The Departments of State (State) and the Treasury (Treasury) implement
and enforce U.S. sanctions on Iran. In 2015, we reported on State's and Treasury's processes
for imposing sanctions on entities involved in activities related to ballistic missiles.3




1S.C. Res. 2231, U.N. Doc. SIRES/2231 (July 20, 2015). This provision applies until the earlier of 8 years from the
JCPOA Adoption Day (October 2015) or until the date the International Atomic Energy Agency submits a report
confirming the Broader Conclusion that for a given year all nuclear material in Iran remained in peaceful activities.

2Exec. Order No. 13,382, 70 Fed. Reg. 38,567 (June 28, 2005), reprinted as amended in 50 U.S.C. § 1701 note;
Exec. Order No. 12,938, 59 Fed. Reg. 59,099 (Nov. 14, 1994), reprinted as amended in 50 U.S.C. § 1701 note; and
Iran, North Korea, and Syria Nonproliferation Act, Pub. L. No. 106-178, §§ 1-7, 114 Stat. 38 (Mar. 14, 2000), codified
as amended at 50 U.S.C. § 1701 note (this law was originally enacted as the Iran Nonproliferation Act of 2000; Syria
was added to the act by the Iran Nonproliferation Amendments Act of 2005, Pub. L. No. 109-112, § 4, 119 Stat. 2366,
2369 (Nov. 22, 2005); and North Korea was added by the North Korea Nonproliferation Act of 2006, Pub. L. No. 109-
2353, 120 Stat. 2015 (Oct. 13, 2006)).
3GAO, Nonproliferation: State Should Minimize Reporting Delays That May Affect Sanctions on Trade with Iran,
North Korea, and Syria, GAO-1 5-519 (Washington, D.C.: May 22, 2015) and North Korea Sanctions: United States
Has Increased Flexibility to Impose Sanctions, but United Nations Is Impeded by a Lack of Member State Reports,
GAO-15-485 (Washington, D.C.: May 13, 2015).


GAO-17-779R Iran Sanctions


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