Biden and Iran Sanctions

During his campaign, Joe Biden said his administration would impose “targeted sanctions against Iranian support for terrorism and Iran’s ballistic missile program” and promised “ironclad support for Israel.” He also said the U.S. could snap back sanctions if necessary.

On March 9, 2021, Secretary of State Tony Blinken announced sanctions on Islamic Revolutionary Guard Corps (IRGC) interrogators Ali Hemmatian and Masoud Safdari “for their involvement in gross violations of human rights, namely the torture and/or cruel, inhuman, or degrading treatment or punishment (CIDTP) of political prisoners and persons detained during protests in 2019 and 2020 in Iran.” The two men and their families are now barred from entry into the United States.

Also, in March, the administration approved a 120-day sanctions waiver to allow Iraq to purchase natural gas and electricity from Iran. President Trump approved similar waivers in 2019 and 2020.

In April 2021, negotiations on returning to the nuclear deal (JCPOA) with Iran began in Vienna. During those talks, the United States and Iran agreed through intermediaries to establish a working group to discuss the lifting of sanctions imposed by President Trump. At the outset, the State Department said the administration was prepared to lift all the sanctions reimposed and new ones enacted by President Trump. Iran, meanwhile, insisted that all sanctions U.S. and international sanctions be lifted before it would return to compliance with the nuclear deal.

In what was viewed as an effort to encourage Iranian cooperation in the negotiations, the Treasury Department repealed sanctions on former senior National Iranian Oil Co. officials and several companies involved in shipping and trading petrochemical products on June 10, 2021. The administration denied there was any connection to the negotiations. “These actions demonstrate our commitment to lifting sanctions in the event of a change in status or behavior by sanctioned persons,” Secretary of State Blinken said in a statement accompanying the notice of the action.

Nevertheless, opponents of the nuclear deal were critical. “Lifting sanctions during negotiations shows weakness to Iran and tells Tehran to continue its nefarious activities, including nuclear extortion and sending conventional arms to U.S. adversaries,” said Anthony Ruggiero, a former top national security adviser to President Trump. Likewise, Senator Ted Cruz criticized the move to dismantle sanctions “before even the pretense of a deal.”

Iranian sources claimed in late June that Biden negotiators had agreed to lift all sanctions imposed by President Trump, including those related to insrurance, oil, and shipping. Officials in the administration did not directly deny the claim; instead, they said only that negotiations were continuing. U.S. National Security Adviser Jake Sullivan said there was still “a fair distance to travel” in the talks, including the lifting of sanctions.

Meanwhile, on June 22, 2021, the Justice Department seized 33 of Iran’s state-linked news website domains which it said were “disguised as news organizations or media outlets, targeted the United States with disinformation campaigns and malign influence operations.”

In June 2021, Iran elected Ebrahim Raisi president. The United States imposed sanctions on Raisi in 2019 over his human rights record, which included “administrative oversight over the executions of individuals who were juveniles at the time of their crime and the torture and other cruel, inhuman or degrading treatment or punishment of prisoners in Iran, including amputations.”

The sanctions could complicate U.S. relations with Iran as they prohibit any dealings with him.

In September 2021, in response to a plot to kidnap a U.S.-based journalist and human rights activist, sanctions were imposed on senior Iran-based intelligence official Alireza Shahvaroghi Farahani, who led a network of affiliates, including Mahmoud Khazein, Kiya Sadeghi, and Omid Noori, tasked with planning this kidnapping on U.S. soil as well as targeting Iranian dissidents in the United Kingdom, Canada, and the United Arab Emirates.

In October 2021, the Treasury Department announced sanctions against Iranian companies and their executives linked to the development of armed drones for attacks on U.S. forces and allies used by terror groups supported by Iran, including Hezbollah in Lebanon, Hamas in the Gaza Strip and the Houthis in Yemen. According to Haaretz, Israel passed intelligence on the Iranian drone program to the United States, including those sanctioned.

Three individuals linked to the Islamic Revolutionary Guard Corps – Yousef Aboutalebi, Saeed Aghajani (Air Force), and Abdollah Mehrabi (Aerospace Force Self Sufficiency Jihad Organization). Mohammad Ebrahim Zargar Tehrani was subject to secondary sanctions for his involvement in the Kimia Part Sivan Company. That company was also sanctioned for its links to the Islamic Revolutionary Guard Corps (Irgc)-Qods Force. Another company, Oje Parvaz Mado Nafar Company, was sanctioned for its link to the Islamic Revolutionary Guard Corps.

In December 2021, the Biden administration targeted government officials and organizations involved in the repression of protesters and political activists, and prisons where activists have been held in brutal conditions. The following entities were added to the U.S. sanctions list: Iran’s Counter-Terror Special Forces, The Isfahan Central Prison (CAATSA-Iran), The Zahedan Prison (CAATSA-Iran), and Special Units Of Iran’s Law Enforcement Forces were added to the list of sanctioned Iranian organizations. At the same time, several individuals associated with these organizations were also sanctioned: Seyed Reza Mousavi Azami (Special Units Of Iran’s Law Enforcement Forces), Mohsen Ebrahimi (Iran’s Counter-Terror Special Forces), Ali Hemmatian, (IRGC), Hassan Karami (Special Units Of Iran’s Law Enforcement Forces), Mohammad Karami (CAATSA – IRAN), Soghra Khodadadi (CAATSA – IRAN), Masoud Safdari (IRGC), and Leila Vaseghi (IRAN-HR).

The administration also began taking measures to tighten existing sanctions. A delegation was sent to the UAE, Iran’s second-largest trade partner and a conduit for Iran’s trade and financial transactions with other countries, with the message that petrochemical companies and banks circumventing sanctions will “face extreme risk if this continues.” Similar messages may be forthcoming for companies violating sanctions in Malaysia, Turkey, and China.

The failure of sanctions, however, was exemplified by the fact that Iran’s oil revenuies increased 40%, to about $25 billion in 2021. Iran’s oil minister expected the country’s production would reach the level it had been before the U.S. withdrawal from the nuclear deal in May 2018 and the imposition of unilateral sanctions.

According to the Wall Street Journal, “Iran established a clandestine banking and finance system to handle tens of billions of dollars in annual trade banned under U.S.-led sanctions, enabling Tehran to endure the economic siege and giving it leverage in multilateral nuclear talks.... [and] buying it time to advance its nuclear program even while negotiations were under way.”

On March 30, 2022, the Treasury Department sanctioned an Iran-based procurement agent and his network of companies that procured ballistic missile propellant-related materials for the Islamic Revolutionary Guard Corps Research and Self Sufficiency Jihad Organization (IRGC RSSJO), the IRGC unit responsible for the research and development of ballistic missiles, as well as Iran’s Parchin Chemical Industries (PCI), an element of Iran’s Defense Industries Organization (DIO). A key Iranian intermediary involved in the procurement of parts used to develop missile propellant on behalf of PCI was also sanctioned. 

The action followed Iran’s missile attack on Erbil, Iraq on March 13 and the Iranian enabled Houthi missi.le attack against a Saudi Aramco facility on March 25 as well as other missile attacks by Iranian proxies against Saudi Arabia and the United Arab Emirates. “This action reinforces the United States’ commitment to preventing the Iranian regime’s development and use of advanced ballistic missiles,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson.  “While the United States continues to seek Iran’s return to full compliance with the Joint Comprehensive Plan of Action, we will not hesitate to target those who support Iran’s ballistic missile program.  We will also work with other partners in the region to hold Iran accountable for its actions, including gross violations of the sovereignty of its neighbors.”

Sources: Mohammad Ayatollahi Tabaar, “No Matter Who Is U.S. President, Iran Will Drive a Harder Bargain Than Before,” Foreign Affairs, (October 20, 2020).
Steven Erlanger, “Biden Wants to Rejoin Iran Nuclear Deal, but It Won’t Be Easy,” New York Times, (November 17, 2020).
Thomas L. Friedman, “Biden Made Sure ‘Trump Is Not Going to Be President for Four More Years,’” New York Times, (December 2, 2020).
“Officials: US Rescinds Trump Move to Enforce UN Sanctions on Iran, Eases Travel Restrictions on Iranian Diplomats at UN,” AP, (February 18, 2021).
Rachel Oswald, “Blinken tells House panel to expect firmness toward Iran, China,” Roll Call, (March 10, 2021).
“Designation of Iranian Officials Due to Involvement in Gross Violations of Human Rights,” State Department, (March 9, 2021).
Steven Erlanger, “Iran Nuclear Talks Start on Positive Note in Vienna,” New York Times, (April 9, 2021).
Qassim Abdul-Zahra and Samya Kullab, “No timetable for withdrawal of troops after US, Iraq talks,” AP, (April 7, 2021).
Ian Talley and Laurence Norman, “U.S. Lifts Some Iran Sanctions Amid Stalled Nuclear Talks,” Wall Street Journal, (June 10, 2021).
Farnaz Fassihi, “A Roadblock for Iran’s President-Elect: He’s on the U.S. Sanctions List,” New York Times, (June 19, 2021).
“United States Seizes Websites Used by the Iranian Islamic Radio and Television Union and Kata’ib Hizballah,” Department of Justice, (June 22, 2021).
David Rose, “Iran’s president Ebrahim Raisi watched as opponents were tortured,” The Times [London], (June 23, 2021).
Humeyra Pamuk and Parisa Hafezi, “Iran says U.S. to lift oil sanctions, Germany cautious on matter,” Reuters, (June 23, 2021).
Antony J. Blinken, “Sanctioning Iranian Intelligence Affiliates for Targeting Dissidents Abroad,” U.S. Department of State, (September 3, 2021).
“Counter Terrorism Designations and Designation Update; Iran-related Designations; Non-Proliferation Designations,” U.S. Department of the Treasury, (October 29, 2021).
Ian Talley, “U.S. Takes Aim at Iran’s Drone Program, Seeing Risk to Mideast Stability,” Wall Street Journal, (October 29, 2021).
Jonathan Lis, “Israel Passed on Iran Drone Intel to U.S. Before It Imposed New Sanctions,” Haaretz, (October 30, 2021).
“Global Magnitsky Designation; Iran-related Designations; Syria Designations; CAATSA - Iran-related Designations,” U.S. Department of the Treasury, (December 7, 2021).
Laurence Norman, “U.S. Moves to Tighten Iran Sanctions Enforcement as Nuclear Talks Stall,” Wall Street Journal, (December 9, 2021).
Yossi Melman, “Awash in Oil Money, Iran Has All the Time in the World – Unlike Israel,” Haaretz, (February 9, 2022).
Ian Talley, “Clandestine Finance System Helped Iran Withstand Sanctions Crush, Documents Show,” Wall Street Journal, (March 18, 2022).
“Treasury Sanctions Key Actors in Iran’s Ballistic Missile Program,” U.S. Department of the Treasury, (March 30, 2022).