Critical Insights

  1. As one of the most complex and far-reaching sanctions programs, the Iran program includes over 20 authorities implemented by the US, EU, and UN. Secondary sanctions were implemented by the US in 2010 through the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA).
  2. Currently, there are more than 1300 Iran-related actors sanctioned by the US.
  3. On November 5, 2018, the US re-sanctioned actors that were previously delisted pursuant to the Joint Comprehensive Plan of Action (JCPOA). The withdrawal included the sanctioning of almost 200 new actors by the US government. The EU and UN have not followed suit, and continue to look for ways to maintain business with Iran.

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