Guide to Iran Sanctions - Money and Oil

several online sources ^ | Friday, October 13, 2023 | self

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October 12, 2023 - Recently, Sec. of State Blinken made a remark, charging Republicans with exploiting the crisis: the HAMAS terror attack against Israel, that began on October 6, 2023.

During 2018, President Trump finally decided to stop implementing the 2015 Iran Nuclear Agreement. See: United States withdrawal from the Joint Comprehensive Plan of Action [JCPOA]. EXCERPT:

"After the Trump administration twice certified Iran's compliance in 2017, in May 2018 the United States withdrew from JCPOA as Trump pledged he would negotiate a better deal."

The Iran nuclear deal is intertwined with financial sanctions that are explained in Section 1245 of the National Defense Authorization Act (NDAA) for Fiscal Year 2012.

Presently, other than nuclear issues, an alarm has been raised, regarding $6 billion dollars made available, by the Biden Administration, to Iran - the terrorist state that sponsors HAMAS in the Gaza Strip. But:

Blinken insisted on Sunday [October 8th] that none of the $6bn had yet been liquidated. "Not a single dollar has been spent from that account. The account is closely regulated by the US treasury department, so it can only be used for things like food, medicine, medical equipment - that's what this is about," he told CNN.

- Blinken: Republicans 'playing politics' in attacking Biden over Israeli crisis [Guardian article, Sunday, October 8, 2023]

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From the National Defense Authorization Act for Fiscal Year 2012; Public Law 112-81, PDF file pg. 351; amended through Public Law 115-91, enacted December 12, 2017: PDF file pg. 356:

SEC. 1245 [22 U.S.C. 8513a] IMPOSITION OF SANCTIONS WITH RESPECT TO THE FINANCIAL SECTOR OF IRAN.

(a) FINDINGS. Congress makes the following findings:

(1) On November 21, 2011, the Secretary of the Treasury issued a finding under Section 5318A of Title 31, United States Code, that identified Iran as a jurisdiction of primary money laundering concern.

(2) In that finding, the Financial Crimes Enforcement Network of the Department of the Treasury wrote, "The Central Bank of Iran, which regulates Iranian banks, has assisted designated Iranian banks by transferring billions of dollars to these banks in 2011. In mid-2011, the CBI transferred several billion dollars to designated banks, including Saderat, Mellat, EDBI and Melli, through a variety of payment schemes. In making these transfers, the CBI attempted to evade sanctions by minimizing the direct involvement of large international banks with both CBI and designated Iranian banks."

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If you look for info regarding sanctions against Iran, the following brief glossary may help:

Abbrv		Description
CISADA		Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2012; Public Law 111-195 enacted July 1, 2010 (PDF file)
EIA		Energy Information Administration
GDP		Gross Domestic Product
ISA		Iran Sanctions Act (1996) (PDF file); originally called the Iran and Libya Sanctions Act (ILSA)
IAEA		International Atomic Energy Agency (IAEA Board Reports)
IFSR		Iranian Financial Sanctions Regulations
ITRA		Iran Threat Reduction Act (see ITRSHRA)
ITRSHRA		Iran Threat Reduction and Syrian Human Rights Act of 2012; Public Law 112-158 (PDF file) (22 USC Ch. 94 online)
JCPOA		Joint Comprehensive Plan of Action (at Wikipedia); part of UN Security Council Resolution 2231
JPA		Joint Plan of Action; interim nuclear plan signed between Iran and the P5+1 countries in November 2013 (also see JCPOA)
NCRI		National Council of Resistance of Iran; based in Paris
NDAA		National Defense Authorization Act[s]
NIOC		National Iranian Oil Company
NITC		National Iranian Tanker Company
NPT		Non-Proliferation of Nuclear Weapons Treaty (1968)
OFAC		U.S. Dept. of the Treasury, Office of Foreign Assets Control

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Iran Sanctions 2016 - Congressional Research Service - webpage:

Scroll down to: "Foreign Exchange Reserves 'Lock Up' Provision of ITRSHRA" - EXCERPT:

Post-JCPOA Status: Waived

The ability of Iran to repatriate its earned hard currency to the [Iranian] Central Bank was impeded by a provision of the ITRSHRA which went into effect on February 6, 2013, 180 days after enactment. Section 504 of the Iran Threat Reduction Act [ITRA/ITRSHRA] amended Public Law 112-81 (adding "clause ii" to Paragraph D(1)) by requiring that any funds owed to Iran as a result of exempted transactions (oil purchases, for example) be credited to an account located in the country with primary jurisdiction over the foreign bank making the transaction.

Waiver Provision

The waiver provision that applies to the sanctions imposed under the FY2012 NDAA (Public Law 112-81) applies to this hard currency "lock-up" provision.

To implement the JPA, a waiver was issued under Public Law 112-81 to allow Iran to receive some hard currency from ongoing oil sales in eight installments during the JPA period. Iran remained unable under the JPA to remove hard currency from existing accounts abroad. As of Implementation Day, the restriction has been waived completely, enabling Iran to gain access to hard currency from ongoing purchases of its oil.

Scroll down to: "Oil Export Sanctions: Section 1245 of the FY2012 NDAA Sanctioning Transactions with Iran's Central Bank - EXCERPT:"

In 2011, Congress sought to reduce Iran's exportation of oil outright by imposing sanctions on the mechanisms that importers use to pay Iran for oil. The sanctions imposed penalties on transactions with Iran's Central Bank. Section 1245 of the FY2012 National Defense Authorization Act (NDAA, Public Law 112-81, signed on December 31, 2011):

Sanctions on transactions for oil apply only if the President certifies to Congress 90 days after enactment (by March 30, 2012), based on a report by the Energy Information Administration to be completed 60 days after enactment (by February 29, 2012) that the oil market is adequately supplied. The EIA report and Administration certification are required every 90 days thereafter. The first required EIA report was issued on February 29, 2012. On March 30, 2012, President Obama determined that there was a sufficient supply of oil worldwide to permit countries to reduce oil purchases from Iran. An EIA report of April 27, 2012, and Administration determination of June 11, 2012, made similar findings and certifications, triggering the sanctions as of June 28, 2012. Subsequent EIA reports and Administration determinations kept the sanctions triggers in place.

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The United States became a total petroleum net exporter in 2020, but became a net importer in 2022. (EIA - Oil and petroleum products explained)

U.S. Strategic Petroleum Reserve Stocks:

U.S. Ending Stocks of Crude Oil in SPR (Thousand Barrels)

Year	Jan	Feb	Mar	Apr	May	Jun	Jul	Aug	Sep	Oct	Nov	Dec
2018	664,234	665,458	665,456	663,966	660,167	660,015	660,013	660,011	660,009	654,840	649,567	649,139
2019	649,139	649,126	649,126	648,588	644,818	644,818	644,818	644,818	644,818	641,153	634,967	634,967
2020	634,967	634,967	634,967	637,826	648,326	656,023	656,140	647,530	642,186	638,556	638,085	638,086
2021	638,085	637,773	637,774	633,428	627,585	621,304	621,302	621,302	617,768	610,646	601,467	593,682
2022	588,317	578,872	566,061	547,866	523,109	493,324	468,006	445,057	416,393	398,569	388,419	372,030
2023	371,579	371,579	371,175	363,723	354,366	347,158	347,454

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[linMcHlp]

Addition to the Glossary:

CBI - Central Bank of Iran

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BREAKING: US, Qatar refreeze $6 billion in Iran hostage payment

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Qatar Intends to Fulfill US-Iran Deal on $6 Billion