Summary of Recent United Nations Security Council, European Union, and United States Sanctions Against Iran
April 2008 Issue
 

On March 3, 2008, the United Nations Security Council adopted Resolution 1803 imposing new sanctions on Iran and reiterating its requirement that, inter alia, Iran suspend its uranium enrichment program and its construction of a non-power reactor well-suited for producing high quality plutonium. Both capabilities could enable Iran to produce material for nuclear weapons. The resolution is the third set of sanctions in a series of Security Council resolutions aimed at persuading Iran to suspend these activities and also seeking to curb its development of missiles capable of delivering nuclear weapons. At the same time, this resolution recalled the offer conveyed to Iran in June 2006 of significant incentives were it to suspend its proliferation sensitive nuclear activities and enter into negotiations with the Council’s permanent members (China, France, Russia, the United Kingdom, and the United States) and Germany.

In recent years, in addition to UN sanctions, the European Union (EU) and the United States have each imposed a variety of sanctions on Iranian organizations (both private and governmental) and on Iranian individuals. Like the UN Security Council sanctions, the purpose of the EU sanctions has been to slow nuclear and missile proliferation in Iran. The United States has also imposed sanctions specifically to limit Iran’s nuclear and ballistic missile programs. However, Washington has also imposed additional sanctions on Iranian entities it believes are having a destabilizing impact on the region, supporting international terrorism, or fueling the insurgency in Iraq.

The following synopsis of these various sanctions and the accompanying tables are intended to offer a convenient overview as of March 14, 2008, of the status of these international efforts to alter Iranian behavior.

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The nature of the sanctions imposed by the UN, EU, and U.S. varies according to the authority under which they are imposed.

UN Security Council Resolution 1737
UN Security Council Resolution 1737 (adopted December 23, 2006):

  • demands that Iran suspend activities related to the development of capabilities associated with possible production of nuclear-weapon materials;
  • bans trade with Iran in specifically-designed and dual-use commodities usable in uranium enrichment and plutonium production and in ballistic missiles;
  • bans the provision of training and financing activities to support Iran’s development of such capabilities;
  • limits IAEA technical cooperation with Iran to those projects involving food, agricultural, medical, safety, or other humanitarian purposes or unless for use in light water nuclear power reactors;
  • calls upon all states to exercise vigilance and prevent specialized training and teaching of Iranian nationals in disciplines associated with proliferation;
  • freezes the assets of listed corporate and governmental entities and individuals directly associated with Iran’s sensitive nuclear activities and missile development programs; and
  • requires UN member states to monitor the travel of the listed individuals and to exercise vigilance in permitting these individuals to enter into or transit through member states’ territories.

UN Security Council Resolution 1747
UN Security Council Resolution 1747 (adopted March 24, 2007) maintains existing sanctions and:

  • bans Iran from selling or transferring any arms;
  • calls upon all states to exercise vigilance in supplying heavy conventional weapons (battle tanks, armored combat vehicles, large caliber artillery systems, or combat aircraft) to Iran;
  • calls upon all states and international financial institutions not to enter into new commitments for grants, financial assistance, or concessional loans to the government of Iran;
  • freezes the assets of 28 additional corporate and governmental entities and individuals directly associated with Iran’s sensitive nuclear activities and missile development programs; and
  • calls upon all states to exercise vigilance in permitting travel within their borders of the listed individuals.

UN Security Council Resolution 1803
UN Security Council Resolution 1803 (adopted March 3, 2008) maintains existing sanctions and:

  • bans trade with Iran in dual-use nuclear and missile commodities (except dual use items needed for use in light water reactors, including the Bushehr Nuclear Power Plant being completed by Russia, (Iran’s sole power reactor project));
  • bans travel to any member state of the five persons listed in Annex II of the resolution (see table, below) directly connected to Iran’s sensitive nuclear activities and development of nuclear delivery systems;
  • expands the number of entities and individuals subject to the asset freeze, and individuals subject to “travel vigilance and restraint” provisions the same as those under UNSCRs 1737 and 1747;
  • requires reporting to the UN Security Council committee monitoring implementation of the Iran sanctions resolutions of the movement of individuals sanctioned in Resolution 1737, Resolution 1747, and Annex 1 of Resolution 1803 (see table).
  • calls upon all states to exercise vigilance in entering into new commitments for publicly provided financial support for trade with Iran (including granting of export credits);
  • calls upon all states to exercise vigilance over the activities of financial institutions in their territories with Iranian banks, in particular Bank Melli and Bank Saderat, to avoid possibly supporting Iran’s sensitive nuclear activities or nuclear-capable missile programs; and
  • calls upon all states to inspect cargoes going to Iran on vessels or aircraft operated by Iran Air Cargo and the Islamic Republic Shipping Line if there is reason be believe these include UN-banned items for Iran’s nuclear and missile programs.


Common Position 2007/246/CFSP of the Council of the European Union, Concerning Restrictive Measures Against Iran, Amending Position 2007/140/CFSP of the Council of the EU Concerning Restrictive Measures Against Iran
Common Position 2007/140 (adopted February 27, 2007) implemented UN Security Council Resolution 1737 within the EU. It went beyond Resolution 1737 in that it banned travel within the EU of individuals listed in the Annex to that resolution, while the resolution, itself, only “called upon” UN member states to “exercise vigilance” in allowing the travel of the individuals within their borders.

Common Position 2007/246 (adopted April 23, 2007) amended Common Position 2007/140 to include measures needed to implement UN Security Council Resolution 1747. As noted below, the later Common Position imposes more powerful sanctions than that UN action in a number of respects.

The Common Position, as amended:

  • bans trade with Iran in all nuclear- and missile-relevant commodities contained in the control lists of the Nuclear Suppliers Group and the Missile Technology Control Regime and any other items usable for uranium enrichment or plutonium separation;
  • bans the provision of training and financing activities to support Iran’s development of uranium enrichment and plutonium separation capabilities;
  • freezes the assets of corporate and governmental entities and individuals directly associated with Iran’s sensitive nuclear activities and missile development programs listed in Security Council Resolutions 1737 and 1747, as well as 23 additional entities listed in Common Position 2007/246;
  • bans travel within the EU of individuals listed in Security Council Resolutions 1737 and 1747, as well as 15 additional individuals listed in Common Position 2007/246 [Note: UNSCR 1737 and 1747 only “call upon” states to “exercise vigilance” in monitoring the travel of the individuals listed in those resolutions];
  • bans EU members from making transfers of conventional weapons and military equipment to Iran [Note: UNSCR 1747 does not ban such trade, but only “calls upon states” to “exercise vigilance” in making transfers to Iran of heavy conventional weapons]; and
  • bans member states from entering into new commitments for grants, financial assistance, or concessional loans to the government of Iran [Note: UNSCR 1747 does not ban such transactions, but only “calls upon states” not to enter into them].


U.S. Executive Order (E.O.) 13224
U.S. Executive Order (E.O.) 13224 Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten to Commit, or Support Terrorism (issued December 20, 2002):

  • freezes the assets of those entities listed in the Annex to the Executive Order;
  • prohibits U.S. citizens from engaging in transactions with those entities listed in the Annex; and
  • prohibits U.S. citizens from facilitating a transaction between a foreign entity and an entity listed in the Annex.


U.S. Executive Order 13382
U.S. E.O. 13382 Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters (issued June 28, 2005):

  • prohibits transactions between designees (the entities listed in the Annex and those entities and individuals designated by the Department of State or Department of the Treasury) and any U.S. person; and
  • freezes the assets the designees may have under U.S. jurisdiction.


U.S. Executive Order 13438
U.S. E.O. 13438: Blocking Property of Certain Persons who Threaten Stabilization Efforts in Iraq (issued July 17, 2007):

  • freezes the assets in the United States of those entities listed in the Annex to EO 13438;
  • prohibits U.S. citizens from engaging in transactions with those entities listed in the Annex; and
  • prohibits U.S. citizens from facilitating a transaction between a foreign entity and an entity listed in the Annex.

The U.S. Iran, North Korea and Syria Nonproliferation Act
The U.S. Iran, North Korea and Syria Nonproliferation Act provides for penalties on entities and individuals for the transfer to, or acquisition from, Iran since January 1, 1999 or the transfer to, or acquisition from, Syria since January 1, 2005, of equipment and technology controlled under multilateral export control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the potential to make a material contribution to the development of weapons of mass destruction (WMD) or cruise or ballistic missile systems. These sanctions only apply to the specific aforementioned entities and not to their respective countries or governments.

Note: U.S. Executive Order E.O. 12938 (adopted November 13, 1994; amended on July 28, 1998) imposes penalties on foreign persons that, after November 19, 1990, have engaged or attempted to engage in activities that have materially contributed to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction (WMD) or their means of delivery, including any efforts by any person or foreign country of proliferation concern to manufacture, acquire, possess, develop, transport, transfer, or use such items. On September 26, 2007, Shahid Hemmat Industrial Group (SHIG) and Aerospace Industries Group (AIO), two Iranian entities currently sanctioned under E.O. 13382, were also designated under E. O. 12938.
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The attached table compiles all of the Iranian entities sanctioned under the foregoing authorities. (Because the focus of this analysis on Iranian entities, certain foreign entities that have been sanctioned because of WMD-relevant transactions with Iran have been excluded.) The table reveals that the UN, U.S., and EU have somewhat different lists of sanctioned Iranian entities. The EU appears to have sanctioned the largest number of Iranian entities for proliferation-related activities. However, using a range of authorities to impose sanctions for proliferation- and terrorism-related activities, and for supporting the Iraqi insurgency, the United States has imposed sanctions over a wider range of important Iranian institutions, freezing the assets of a number of Iranian banks, as well as those of the Iranian Ministry of Defense and of the Islamic Revolutionary Guard Corps, an organization with extensive commercial holdings, in addition to its military assets. (It may be noted that for many years, the United States has a comprehensive sanctions program in place that prohibits most transactions with Iran. Thus the freeze on assets under U.S. jurisdiction has only a limited impact at most on Iranian organizations and persons Iranians have been prohibited from direct financial transactions with U.S. financial institutions by the aforementioned comprehensive sanctions program.)

Benjamin Radford and Leonard Spector - Monterey Insititute James Martin Center for Nonproliferation Studies