Legal Brief: COVID-19 Raises Stakes for US Sanctions Against Iran

By Leily Faridzadeh

Editor’s Note: In the 14th installment of our series, the legal team covers the latest developments with U.S. sanctions against Iran, particularly in the context of the Islamic Republic’s efforts to contain the new coronavirus pandemic.

After unilaterally withdrawing from the global nuclear accord with Iran, the Joint Comprehensive Plan of Action, or JCPOA, in May 2018, President Donald Trump warned that the U.S. would exert “maximum economic pressure” on the Islamic Republic to deter malign activity and force the country into negotiating a new deal.

The U.S. commenced 2020 by ratcheting up pressure through new and recurring restrictions, expanding sanctions to the country’s metals industry and other sectors, and enforcing existing measures against Iranian petroleum.

Iran responded by abandoning several of its commitments under the JCPOA and seeking new financial and commercial channels to avoid U.S. jurisdiction. Iran also allegedly increased its involvement in malign cyberactivity, prompting U.S. federal officials and state regulators to issue warnings and advisories to banks and other businesses.

Despite Iran’s noncompliance with the JCPOA, European signatories chose to delay the reimposition of sanctions amid criticism of the commercial and financial embargo of the country by U.N. Special Rapporteur Idriss Jazairy, who called U.S. sanctions “unjust.”

Human Rights Watch claimed in October 2019 that U.S. secondary sanctions were choking off permissible humanitarian transactions with Iran, and the Norwegian Refugee Council claimed in January that it could not find a single international bank willing to transmit funds to refugee communities and victims of natural disasters in the Islamic Republic.

Despite these issues, U.S. officials pressed on in February by designating more individuals and charging foreign firms and their subsidiaries with violating U.S. sanctions by arranging the shipment of goods to Iran. On Feb. 25, U.S. Secretary of State Mike Pompeo disclosed sanctions against 13 entities and individuals in China, Iraq, Russia, and Turkey for transacting with Iran.

The impact of U.S. sanctions on the Iranian people has been amplified by the COVID-19 pandemic, in response to which the Treasury Department’s Office of Foreign Assets Control, or OFAC, published issued a new general license authorizing certain, previously banned transactions with Iran’s central bank.

EU officials and others, including the U.N. High Commissioner for Human Rights, have called on the U.S. to further ease sanctions against Iran. Swiss authorities warned in February that they still could only offer limited aid due to Iran’s financial limitations.

On March 14, Iran’s President Hassan Rouhani called the sanctions unlawful and pushed world leaders to combine their efforts against COVID-19. Undeterred, U.S. officials issued another round of sanctions against Iranian targets, including five nuclear scientists and nine companies allegedly involved in transporting and selling petrochemical products.

On March 20 and 24, China and Russia demanded a lift on sanctions against Iran and criticized U.S. unilateral restrictions against the country as “inhumane.”

Some medical aid had reportedly trickled in to Iran through the first Instex transaction by March 31, but Rouhani stressed that a one-off transfer was insufficient and in April called again on other countries, including Spain, Turkey, and China, to marshal support against U.S. sanctions.

In the U.S., bipartisan groups of federal representatives and senators also urged the administration to lessen the impact of sanctions on Iran and support the country’s request for $5 billion in aid from the International Monetary Fund.

The Treasury Department on April 9 restated its commitment to facilitate humanitarian aid to Iran and OFAC issued guidance for providing such assistance to the country.

Meanwhile, the State Department outlined its efforts to have U.N. sanctions against Iran reimposed pursuant to the JCPOA despite the White House’s withdrawal from the accord two years ago.

The department’s push for U.N. sanctions is supported by a majority of U.S. representatives.

Contact Leily Faridzadeh at

Topics : Sanctions
Source: Iran , U.S.: OFAC , U.S.: Department of Treasury , U.S.: White House/U.S. President , U.S.: Department of State , United Nations
Document Date: May 15, 2020