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Chapter 3: Sanctions against Iran

photo_chapter33. Sanctions against Iran

3.1 Overview

The US first imposed economic and political sanctions against Iran in 1979, in response to Iran’s Islamic revolution and the 1979-81 hostage crisis. Additional US sanctions were imposed in 1984 due to the implication of Iran’s proxy Hezbollah (see section 2.2) in the bombing of the US Marine base in Beirut. In the same year, the US for the first time designated Iran a ‘state sponsor of terrorism’.206

While the focus of these sanctions changed over time, they generally pursue a range of objectives simultaneously. Until the 1990s, they were intended to force Iran to cease supporting acts of terrorism and to generally restrict Iran’s strategic power in the Middle East. Since the mid-2000s, an additional aim is to ensure a purely civilian use of Iran’s nuclear programme.207 Besides the US, the United Nations Security Council and various regional and national authorities, including the member states of the European Union, Japan, South Korea, Canada, Australia, Norway, Switzerland and others have also imposed escalating rounds of sanctions on Iran.208

An increasing number of nuclear-related sanctions imposed since 2010 target Iran’s ability to sell crude oil, import refined petroleum products and make it more difficult for Iran’s Central Bank and other financial institutions to engage in international transactions.209 The overall aim was to prevent Iran from manufacturing nuclear weapons and to pressure the Iranian government to meet its obligations under international agreements, including the Nuclear Nonproliferation Treaty (NPT), International Atomic Energy Agency (IAEA) safeguards agreements and UN Security Council resolutions.210

Among the implemented sanctions different types can be distinguished, namely those targeting:

  • Financial and banking services;
  • Oil exports;
  • Trade;
  • Financial assets and freedom of travel;
  • Weapon development.

According to currently available information, Iran will receive limited sanctions relief as specified by the 2013 interim nuclear deal.e Upon implementation of the Joint Comprehensive Plan of Action (JCPA), which was signed in Vienna on 14 July 2015, more sanctions relief is envisaged. In the case of the US, the detailed implications require new guidance by the Department of the Treasury.211

US sanctions to be suspended in line with the JCPA are primarily those that sanction foreign entities and countries for conducting specified transactions with Iran (the so-called ‘secondary sanctions’). While US sanctions that generally prohibit transactions of US firms with Iran are not being changed, the JCPA allows the sale to Iran of commercial aircraft and related parts exclusively for civil aviation use, and the importation of Iranian luxury products. The US will revoke the designations of numerous specified Iranian economic entities and persons, including the National Iranian Oil Company (NIOC), various Iranian banks, and energy- and shipping-related institutions. In addition, some entities sanctioned under the Iran-North Korea-Syria Non-Proliferation Act (INKSNA) will be removed from that list, while the overall Act will remain in force.212

Restrictions imposed by UN Security Council resolutions related to the purchase and sale of conventional arms and related material, as well as those related to ballistic missiles and technology, will remain in place for, respectively, another 5 and 8 years, or until the International Atomic Energy Agency (IAEA) confirms that all nuclear activity in Iran is serving peaceful purposes, depending on what is earlier.213

Exemptions to these expected relieves as stipulated in the Plan of Action include:

  • US sanctions on Iran related to human rights abuses, terrorism and missile activities will remain in place.
  • 8 years after the adoption date and if IAEA concludes that all nuclear activity in Iran remains peaceful, the US will seek legislative action to terminate or modify nuclear-related sanctions.
  • The EU’s arms embargo and restrictions on transfer of ballistic missiles will remain in place for another eight years.
  • After 5 years, UN sanctions on conventional weapons that were linked to Iran’s nuclear activities will terminate.
  • After 8 years, UN sanctions on Iran’s ballistic missiles programme that were linked to Iran’s nuclear activities will terminate.
  • US and international sanctions on Iran’s conventional weapons and missile capabilities will remain in place.214

In addition, UN Security Council resolutions on arms embargoes against entities of concern and that receive Iranian arms will remain in place, including the Houthis in Yemen, Shia militants in Iraq and Hezbollah in Lebanon.215

3.2 US, EU and UN terrorism- and nuclear-related sanctions

Table 1 provides an overview of key economic and political sanctions imposed on Iran by the international community over the years. The table focuses on sanctions imposed by the US, the UN and the EU. Those sanctions which have been suspended in connection with the 2013 interim Joint Action Plan, or are currently expected to be fully or partially relieved upon implementation of the July 2015 nuclear deal, are marked in italics.216

 

Table 1: US, UN and EU sanctions against Iran targeting terrorism, human rights violations and nuclear weapon development

 

Imposed by

Year

Authority

Type

Sanctioned activities / Requirements

Source

US

1981

Executive orders

Blocked property & assets

Carter Administration Executive Orders blocked Iranian assets held in the United States. About US$ 50 million in Iranian diplomatic property and accounts remain blocked, in addition to other past financial disputes.

US

1984

Export Administration Act (Section 6(j) (P.L. 96-72);
Section 620A of the Foreign Assistance Act, FAA (P.L. 87-95) and Section 40 of the Arms Export Control Act (P.L. 95-92, as amended); and
Section 1621 of the IFIA (P.L. 95-118, as amended (added by Section 327 of the Anti-Terrorism and Effective Death Penalty Act of 1996 [P.L. 104-132])

Economic & financial sanctions; Licensing requirements

Iran’s inclusion in ‘State Sponsors of Terrorism’ list leads to restrictions on US foreign assistance; ban on defence exports and sales; certain controls over exports of dual-use items; requirement of validated export licenses (with an implied presumption of denial) for trade in goods or technology that are controlled by the Department of Commerce for national security or foreign policy reasons. Miscellaneous financial and other restrictions.

217

US

1985

Section 307 of the FAA

Economic sanctions

Iran unable to benefit from US contributions to international organisations. Proportionate cuts in US contributions if these institutions work in Iran.

218

US

1987

Executive Order 12613

Economic sanctions

Bans US oil companies from importing Iranian oil into the US.

219

US

1992

Iran-Iraq Arms Nonproliferation Act

Economic sanctions

Calls for sanctioning any person or entity assisting in any transfer of goods or technology to Iraq or Iran whenever there is reason to believe that such transfer could contribute to that country’s acquisition of chemical, biological, nuclear or advanced conventional weapons.

220

US

1995

Executive order 12947 and amendments

Economic sanctions

Blocks any transaction with terrorist organisations disrupting the Middle East peace process (incl. Hamas & Hezbollah) or entities supporting such organisations

221

US

1995

Executive Order 12957

Economic sanctions

Prohibits certain transactions for US persons or entities with respect to the development of Iranian petroleum resources.

222

US

1995

Executive Order 12959 (amending Executive Order 12613)

Economic sanctions

Bans US firms from exporting to Iran, importing from Iran or investing in Iran, with limited exemptions.

US

1996

Sections 620G and 620H of the Foreign Assistance Act, as added by the Anti- Terrorism and Effective Death Penalty Act (Sections 325 and 326 of P.L. 104-132)

Economic sanctions

Withholds US foreign assistance to countries that assist or sell arms to terrorism-list countries. Section 321 also makes it a criminal offence for US persons to conduct financial transactions with terrorism-list governments.

223

US

1996

Iran Sanctions Act (ISA) of 1996

Economic sanctions

Persons doing business with Iran, particularly certain investments directly and significantly contributing to the enhancement of the ability of Iran to develop petroleum resources.

224

US

1997

Executive Order 13059 (amending Executive Order 12959)

Economic sanctions

Prohibits certain transactions with respect to Iran, including US companies knowingly exporting goods to a third country for incorporation into products destined for Iran

225

US

2000

Iran-North Korea-Syria Nonproliferation Act (INKSNA) (incl. Executive Order 12938 from 1994)

Economic sanctions

Individuals or corporations that have assisted Iran’s WMD programmes. Sanctions imposed include prohibition on US exportation of arms and dual-use items to the sanctioned entity, and, under Executive Order 12938, a ban on US government procurement and on imports to the US from the sanctioned entity.

226

US

2001

Executive Order 13224 (ISA Extension Act)

Economic sanctions

Freezes US-based assets of, and imposes a ban on US transactions with, entities determined to be supporting international terrorism (not Iran-specific)

227

US

2005/
2007

Executive Order 13382

Economic sanctions

Blocks assets of proliferators of WMD and their supporters.

228

UN

2006

Security Council Resolution 1696

Economic & diplomatic sanctions

Iran to suspend uranium enrichment.

229

UN

2006

Security Council Resolution 1737

Economic & diplomatic sanctions

Ban in relation to nuclear and ballistic missile programmes on export/procurement of arms and related material from Iran, and on supply of various conventional weapons and related materiel to Iran.

Travel ban and assets freeze on designated persons and entities.

230

US

2006

Iran Freedom Support Act (ISA Extension)

Economic sanctions

Firms or persons determined to have sold to Iran (1) technology useful for weapons of mass destruction (WMD) or (2) “destabilizing numbers and types” of advanced conventional weapons.

231

US

2007

Executive Order 13438

Personal sanctions

Persons, including Qods Force officers and figures linked to Iraqi Shia militia, who are posing a threat to Iraqi stability, presumably by providing arms or funds to Shia militias there.

232

UN

2007

Security Council Resolution 1747

Economic, financial & diplomatic sanctions

Reaffirms UN Resolution 1737 (2006).
Adds restrictions on states and financial institutions not to provide loans or other financing to Iran, except for humanitarian and developmental purposes. Asset freeze of selected IRGC members.

233

UN

2008

Security Council Resolution 1803

Economic & diplomatic sanctions

Tightened restrictions on proliferation-sensitive nuclear activities; increased vigilance over Iranian banks. Mandates states to inspect cargos.

234

UN

2008

Security Council Resolution 1835

Economic & diplomatic sanctions

Reaffirms earlier UN resolutions on uranium enrichment.

235

UN

2010

Security Council Resolution 1929

Economic, financial & diplomatic sanctions

Adds measures directed against 41 named entities and individuals, including enterprises linked to the IRGC, defence industry, banks and the national shipping line.

236

EU

2010

Council Decision 2010/413/CFSP

Economic sanctions

Trade restrictions on direct or indirect supply, sale or transfer of items, materials, equipment, goods and technology related to nuclear weapons, including enrichment-related, reprocessing or heavy water-related technology; arms and ammunitions; dual-use technology.

237

US

2010

CISADA Section 103, 104, 105, 106 (ISA expansion/replacement)

Financial sanction, economic sanctions, visa ban

Consolidates previous sanctions.
Mandatory sanctions with respect to financial institutions, imposition of sanctions on certain persons who are responsible for or complicit in human rights abuses, prohibition on procurement contracts with persons that export sensitive technology to Iran, harmonization of criminal penalties for violations of sanctions, increased capacity for efforts to combat unlawful or terrorist financing, sanctions on firms that conduct any type of transaction in Iran’s energy sector.
Section 104 specifically refers to foreign banks that conduct significant transactions with the IRGC or any of its agents or affiliates that are sanctioned under any Executive Order. It also sanctions any entity that assists Iran’s Central Bank efforts to help the IRGC acquire WMD or support international terrorism.

238

US

2010

Executive Order 13553 (amending section 105 of CISADA)

Economic sanctions

CISADA sanctions against Iranians determined to be responsible for or complicit in post-2009 Iranian elections human rights abuses.

239

US

2011

Executive Order 13572

Personal sanctions

Individuals, including the IRGC-Qods Force, Qods Force officers including chief commander Qassem Soleimani, determined to be responsible for human rights abuses and repression of the Syrian people.

240

US

2011

Executive Order 13574

Financial sanction

Authorizing the implementation of certain sanctions set forth in the Iran Sanctions Act of 1996, as amended.

241

US

2011

Executive Order 13590

Economic sanctions

Imposition of certain sanctions with respect to the provision of goods, services, technology, or support for Iran’s energy and petrochemical sectors.

242

US

2012

National Defense Authorization Act (NDAA) for Fiscal Year 2012 – Section 1245

Financial sanctions

Cuts off from the US financial system any foreign financial institutions that knowingly facilitate significant financial transactions with the Central Bank of Iran (“CBI”) or with Iranian financial institutions designated by US Treasury.

243

EU

2012

Council Regulation (EU) 264/2012

Economic & financial sanctions

Restrictions on activities contributing to human rights violations in Iran, including sale, supply, transfer or export, directly or indirectly, of equipment which might be used for internal repression, or provision, directly or indirectly, of financing or financial assistance for such equipment.

244

EU

2012

Council Regulation (EU) 267/2012 (considering dual-use goods and technology as set out in Annex I to Council Regulation (EC) 428/2009) and amendingCouncilDecision 2010/413

Economic & financial sanctions

Restrictions on trade in dual-use goods and technology, key petrochemical industry equipment and technology. Ban on import of Iranian crude oil, petroleum products and petrochemical products. Prohibition of investment in the petrochemical industry. Prohibition of trade in gold, precious metals and diamonds with Iran, delivery of newly printed banknotes and coinage to or for the benefit of the Central Bank of Iran.

245

US

2012

Executive Order 13599

Financial sanction

Impounds US-based assets of Central Bank of Iran, or of any Iranian government-controlled entity. US persons are prohibited from any dealings with such entities.

246

US

2012

Executive Order 13622

Financial sanctions

Additional sanctions on the purchase of Iranian crude oil and petrochemical products, or helping Iran to purchase bank notes or precious metals.

247

US

2012

TRA Sections 211, 220, 221

Economic & financial sanctions; Visa ban

Sanctions on provision of vessels or shipping services to transport goods related to proliferation or terrorism activities.
Provision of specialized financial messaging services to the Central

Bank of Iran and other sanctioned Iranian financial institutions.
Identification of, and immigration restrictions on, senior officials of the Government of Iran and their family members.

248

US

2012

TRA (except Sections 211, 220, 221)

Economic sanctions; Visa ban

Expansion of ISA to additional sectors, including energy, transportation of crude oils, WMD, etc.
Measures
related to human rights abuses, including visa ban. Sanctions with respect to Iran’s Revolutionary Guard Corps.

249

US

2012

Executive Order 13606 (GHRAVITY)

Economic sanctions

Blocks the US-based property and essentially bars US entry and bans any US trade with persons and entities linked to grave human rights abuses by the Governments of Iran and Syria via information technology.

250

US

2012

Executive order 13608

Economic sanctions

Gives the Department of the Treasury the ability to identify and sanction (by cutting them off the US market) any non-US persons who help Iran (or Syria) evade US and multilateral sanctions.

251

US

2012

Executive Order 13628 (pursuant to TRA)

Economic sanctions

Blocks the property of persons/firms determined to have committed the censorship, limited free expression, or assisted in jamming communications.

252

US

2013

Executive Order 13645

Economic & financial sanctions

Blocks US-based property and prohibits US bank accounts for foreign banks that conduct transactions in Iran’s currency, the rial, or hold rial accounts. Expands application of Executive Order 13622 (above) to helping Iran acquire precious stones or jewels. Blocks US-based property of any person that conducts transactions with any Iranian entity on the list of Specially Designated Nationals (SDNs) or Blocked Persons.

253

Abbreviations: CISADA – Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010; FAA – Foreign Assistance Act; IEEPA – International Emergency Powers Act; IFIA – International Financial Institutions Act ; INKNSA – Iran-North Korea-Syria Nonproliferation Act; IRGC – Iranian Revolutionary Guard Corps; ISA – Iran Sanctions Act; TRA – Iran Threat Reduction and Syria Human Rights Act; WMD – Weapons of Mass Destruction.

Sources: see table, and:
US Department of Treasury (n.d.), “Resource Center – Iran Sanctions”, online: http://www.treasury.gov/resource-center/sanctions/Programs/pages/iran.aspx , accessed in October 2015;
Bureau of Economic and Business Affairs (2012, September 28), “Iran Sanctions Contained in the Iran Threat Reduction and Syria Human Rights Act (ITRSHRA)“, US Department of State, online: http://www.state.gov/e/eb/rls/fs/2012/198393.htm, accessed in August 2015;
Borhani, S. (2015, April), “List of non-nuclear U.S. sanctions on Iran”, online: http://www.avvo.com/legal-guides/ugc/list-and-description-of-non-nuclear-u-s-sanctions-on-iran, accessed in August 2015;
Katzman, K. (2015, August 4),
Iran Sanctions, Washington, United States: Congressional Research Service;
Rennack, D.E. (2015, April 15),
State Sponsors of Acts of International Terrorism—Legislative Parameters: In Brief, Washington, United States: Congressional Research Service;
Luers, W., Bieri, I. and P. Lewis (2012),
Weighing Benefits and Costs of International Sanctions Against Iran, New York, United States: The Iran Project.

Notes & References

e. This preliminary sanctions relief included Iran’s purchase and sale of gold and other precious metals, export of petrochemical products, automotive industry and certain associated services.

206. Laub, Z. (2015, July), “International sanctions on Iran”, Website Council on Foreign Relations, online: http://www.cfr.org/iran/international-sanctions-iran/p20258, accessed in August 2015.

207. Katzman, K. (2015, August 4), Iran Sanctions, Washington, United States: Congressional Research Service.

208. US Department of State (n.d.), “Iran sanctions”, online: http://www.state.gov/e/eb/tfs/spi/iran/index.htm¸accessed in October 2015.

209. Katzman, K. (2015, August 4), Iran Sanctions, Washington, United States: Congressional Research Service;
Iran Matters (n.d.), “Sanctions”, Harvard University’s Belfer Center, online: http://iranmatters.belfercenter.org/sanctions, accessed in August 2015.

210. Katzman, K. (2015, August 4), Iran Sanctions, Washington, United States: Congressional Research Service;
Iran Matters (n.d.), “Sanctions”, Harvard University’s Belfer Center, online: http://iranmatters.belfercenter.org/sanctions, accessed in August 2015.

211. United States Institute of Peace (2015, August 10), “US Treasury: New guidance on sanctions”, online: http://iranprimer.usip.org/blog/2015/aug/10/us-treasury-new-guidance-sanctions, accessed in October 2015.

212. Katzman, K. (2015, August 4), Iran Sanctions, Washington, United States: Congressional Research Service, p.60-62.

213. The White House (2015), The Iran Nuclear Deal: What You Need to Know About the JCPOA, Washington DC, United States: The US Government, p.24.

214. Geranmayah, E. (2015, July 17), “Explainer: The Iran nuclear deal”, European Council on Foreign Relations, online: http://www.ecfr.eu/article/iran_explainer3070¸accessed in October 2015;
Katzman, K. (2015, August 4), Iran Sanctions, Washington, United States: Congressional Research Service, p.60-62.

215. The White House (2015), The Iran Nuclear Deal: What You Need to Know About the JCPOA, Washington DC, United States: The US Government, p.24.

216. EU+3 and Islamic Republic of Iran (2015, July 14), Joint Comprehensive Plan of Action – Annex II and Annex V, Vienna, Austria;
Katzman, K. (2015, August 4), Iran Sanctions, Washington, United States: Congressional Research Service, p.59-62.

217. US Congress (1977, August 4), An Act to Amend the Foreign Assistance Act of 1961 to Authorize International Security Assistance Programs for Fiscal Year 1978, to Amend the Arms Export Control Act to Make Certain Changes in the Authorities of That Act, and For Other Purposes, Public Law 95-92;
US Congress (1979, September 29), An Act to Provide Authority to Regulate Exports, to Improve the Efficiency of Export Regulation, and to Minimize Interference With the Ability to Engage in Commerce, Public Law 96-72;
US Congress (1996, April 24), Antiterrorism and Effective Death Penalty Act of 1996, Public Law 104-132;
Committee on International Relations & Committee On Foreign Relations (2003, July), Legislation on Foreign Relations Through 2002, US Government, p.308-309;
US Government (2014, December 19), Foreign Assistance Act of 1961;
US Government (1996, August 5), Public Law 104–172.

218. Committee on International Relations Committee on Foreign Relations (2003, July), Legislation on Foreign Relations Through 2002, Volume I–A of Volumes I–A and I–B, US Government, p.162-164.

219.  The US President (1987, October 30), “Executive Order No. 12613 October 30, 1987 Prohibiting Imports from Iran”, Federal Register 41940.

220. US Congress, “H.R.5434 – Iran-Iraq Arms Non-Proliferation Act of 1992”, online: https://www.congress.gov/bill/102nd-congress/house-bill/5434, accessed in August 2015.

221. The US President (1995, January 25), Executive Order 12947 of January 23, 1995 Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process, Federal Register, Vol. 60(16).

222. The US President (1995, March 15), Executive Order 12957 – Prohibiting Certain Transactions With Respect to the Development of Iranian Petroleum Resources, Federal Register, Vol.60(52).

223. US Government (2014, December 19), Foreign Assistance Act of 1961; US Government (1996, August 5), Public Law 104–172.

224. US Congress (1996, August 5), Iran and Libya Sanctions Act of 1996.

225. The US President (1997, August 21), “Executive Order 13059 of August 19, 1997 Prohibiting Certain Transactions With Respect to Iran”, Federal Register, Vol.62(162).

226. The US President (1994), “Executive Order 12938 Proliferation of Weapons of Mass Destruction”, Federal Register, Vol.59(220);
US Department of State (n.d.), “Iran, North Korea, and Syria Nonproliferation Act Sanctions (INKSNA)”, online: http://www.state.gov/t/isn/inksna/, accessed in October 2015;
US Congress (2000, March 14), An Act to provide for the application of measures to foreign persons who transfer to Iran certain goods, services, or technology, and for other purposes.

227. The US President (2001, September 25), “Executive Order 13224 blocking Terrorist Property and a summary of the Terrorism Sanctions Regulations”, Federal Register, Vol.66(186).

228. The US President (2005, July 1), “Executive Order 13382 Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters”, Federal Register, Vol. 70(126).

229. United Nations Security Council (2006, July 31), “Security Council Demands Iran Suspend Uranium Enrichment by 31 August, or Face Possible Economic, Diplomatic Sanctions”, online: http://www.un.org/press/en/2006/sc8792.doc.htm, accessed in October 2015.

230. United Nations Security Council (2006, December 27), Resolution 1737 (2006) Adopted by the Security Council at its 5612th meeting, on 23 December 2006.

231. US Congress (2006, September 30), Iran Freedom Support Act, Public Law 109–293.

232. The US President (July 17, 2007), “Executive Order 13438 Blocking Property of Certain Persons Who Threaten Stabilization Efforts in Iraq”, Federal Register, Vol. 72(138).

233. United Nations Security Council (2007, March 24), Resolution 1747 (2007) Adopted by the Security Council at its 5647th meeting on 24 March 2007.

234. United Nations Security Council (2008, March 3), Resolution 1803 (2008) Adopted by the Security Council at its 5848th meeting, on 3 March 2008.

235. United Nations Security Council (2008, September 27), Resolution 1835 (2008) Adopted by the Security Council at its 5984th meeting, on 27 September 2008.

236. United Nations Security Council (2010, June 9), “Security Council imposes additional sanctions on Iran, voting 12 in favour to 2 against, with 1 abstention”, online: http://www.un.org/press/en/2010/sc9948.doc.htm¸accessed in October 2015.

237. European Council (2010, July 26), “Council Decision 2010/413/CFSP concerning restrictive measures against Iran and repealing Common Position 2007/140/CFSP”, Official Journal of the European Union, L195.

238. US Department of the Treasury (2010), CISADA – The New U.S. Sanctions on Iran;
US Department of the Treasury (2010, July), Comprehensive Iran Sanctions, Accountability, And Divestment Act of 2010, Public Law 111-195.

239. The US President (2010, September 28), “Executive Order 13553 Blocking Property of Certain Persons With Respect to Serious Human Rights Abuses by the Government of Iran and Taking Certain Other Actions”, Federal Register, Vol.75(190).

240. The US President (2011, April 29), “Executive Order 13572 Blocking Property of Certain Persons With Respect to Human Rights Abuses in Syria”, Federal Register, Vol.76(85).

241. The US President (2011, May 23), “Executive Order 13574 Concerning Further Sanctions on Iran”, Federal Register, Vol.76(101).

242. The US President (2011, November 21), “Executive Order 13590 – Iran Sanctions”, Federal Register, Vol.76(226).

243. US Congress (2011, December 31), National Defense Authorization Act for Fiscal Year 2012.

244. Council of the European Union (2012, March 24), “Council Regulation (EU) No 264/2012 amending Regulation (EU) No 359/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Iran”, Official Journal of the European Union, L87/26

245. Council of the European Union (2012, March 23), “Council Regulation (EU) No 267/2012 concerning restrictive measures against Iran and repealing Regulation (EU) No 961/2010”, Official Journal of the European Union, L88/1

246. The US President (2012, February 8), “Executive Order 13599—Blocking Property of the Government of Iran and Iranian Financial Institutions”, Federal Register, Vol.77(26).

247. The US President (2012, July 30), “Executive Order 13622—Authorizing Additional Sanctions With Respect to Iran”, Federal Register, Vol.77(149).

248. US Congress (2012), Iran Threat Reduction and Syria Human Rights Act of 2012.

249. US Congress (2012), Iran Threat Reduction and Syria Human Rights Act of 2012.

250. The US President (2012, April 22), “Executive Order 13606 Blocking the Property and Suspending Entry Into the United States of Certain Persons With Respect to Grave Human Rights Abuses by the Governments of Iran and Syria via Information Technology”, Federal Register, Vol.77(79).

251. The US President (2012, May 1), “Executive Order 13608 Prohibiting Certain Transactions With and Suspending Entry Into the United States of Foreign Sanctions Evaders With Respect to Iran and Syria”, Federal Register, Vol. 77(86).

252. The US President (2012, October 9), “Executive Order 13628 Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 and Additional Sanctions With Respect to Iran”, Federal Register ,Vol. 77(198).

253. The US President (2013, June 3), “Executive Order 13645 Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Freedom and Counter-Proliferation Act of 2012 and Additional Sanctions With Respect To Iran”, Federal Register, Vol.78(108).