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 700 Iran-related actors sanctioned by the US.
  3. Approximately 500 individuals, companies, vessels, and aircraft were delisted by the US, EU, and UN in 2016 pursuant to the JCPOA. The US withdrawal from the nuclear agreement will result in the re-sanctioning of previously delisted entities, including, for example, the Islamic Republic of Iran Shipping Lines.

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