90-Day Clock For Iran Sanctions Begins Pursuant to New U.S. Laws

Latest Developments

President Joe Biden must determine within 90 days whether to impose key sanctions on Iran pursuant to the supplemental appropriations package signed into law on April 24. The package includes two new laws — the Stop Harboring Iranian Petroleum Act, or SHIP Act, and the Mahsa Amini Human Rights and Security Accountability Act, or MAHSA Act. The SHIP Act requires Biden to determine whether to impose sanctions on foreign port operators — for example in China, Tehran’s main customer — that accept Iranian oil shipments. The MAHSA Act requires Biden to determine whether to impose human rights sanctions on Iran’s supreme leader, president, and people and entities tied to their networks of businesses and charities.

Expert Analysis

“President Biden is now on the clock to enforce new sanctions targeting Chinese ports accepting Iranian oil and other actors involved in the illicit flow of Iranian oil. The White House should be putting Beijing on notice that the era of oil sanctions non-enforcement is coming to an end.” — Richard Goldberg, FDD Senior Advisor

“The perpetuation of domestic human rights abuses and the support for global terrorism by the government in Tehran is directed by Ayatollah Ali Khamenei. The MAHSA Act rightly targets the ayatollah, his office, and the office of the president of Iran for sanctions. These restrictive measures must be enforced vigorously to limit the financial flows that allow the government of the Islamic Republic of Iran to continue its campaign of repression against its own people and a global war against the West.” — Tyler Stapleton, Director of Congressional Relations at FDD Action

“Mahsa Amini’s tragic death in 2022 at the hands of the regime’s repressive morality police sparked worldwide protests against the Islamic Republic’s brutality. Almost two years later, the impact of the Women, Life, and Freedom movement continues to be felt as the MAHSA Act finally becomes law — laying the foundation for targeted sanctions on Iran’s supreme leader and his corrupt cronies.” — Nick Stewart, Senior Director of Government Relations at FDD Action

Iranian Oil Sanctions Non-Enforcement

The Biden administration has allowed Iran’s oil exports to surge to 141.7 million barrels of oil in the first quarter of 2024 — a 28 percent increase from the same time last year. In March, Iranian exports reached 1.82 million barrels a day. Iran’s oil exports dropped significantly when the Trump administration reinstated oil sanctions on Iran in October 2018 but began rising when Biden took office. In 2023, revenues from oil exports accounted for 40 percent of Iran’s annual budget.

Tehran has used part of its oil revenues to arm and fund terrorist groups for years. Israeli Defense Minister Yoav Gallant has said that Iran provides Hamas $100 million annually and about $700 million per year to Hezbollah, in addition to several other terrorist groups in Iraq, Syria, Lebanon, and Yemen aligned with Tehran. These groups also receive advanced weapons from Tehran, including Iranian-made guided munitions.

Other Iran Sanctions in the Supplemental

The national security package includes several provisions to crack down on Tehran’s financial support to proxies. The Hamas International Financing Prevention Act imposes new sanctions on actors that financially support Hamas, Islamic Jihad, and other terror groups. These new sanctions also apply to foreign states that provide support to these groups. Likewise, the package includes the End Financing for Hamas and State Sponsors of Terrorism Act. This provision places new restrictions on Iran’s ability to benefit financially from institutions like the International Monetary Fund.

“U.S. Legislators Move to Sanction Iranian Leaders, Oil Trade,” FDD Flash Brief

“Iran’s Oil Exports Continue to Rise,” by Saeed Ghasseminejad

“White House Defends $10 Billion Sanctions Waiver to Iran Following Attack,” FDD Flash Brief

“U.S. Grants Iran Sanctions Wavier Worth $10 Billion,” FDD Flash Brief