Understanding the Sanctions Regime

The U.S. and the E.U. have imposed sanctions on Iran for many years under a proliferation of laws and decrees.  Many of those laws and decrees did not clearly identify whether a particular entity was being sanctioned for participation in the nuclear program, the ballistic missile program, terrorism, or human rights violations.  Some did, however.  The programs and EU decrees listed below are some that clearly imposed non-nuclear-related sanctions on Iranian entities.

U.S. Non-Nuclear Sanctions


The U.S. Treasury Department identifies the legal basis for sanctions with a series of program tags appended to the name of the sanctioned entity on the Specially Designated Nationals list.  The program tags for explicitly non-nuclear sanctions relating to Iran are:


  • IRGC (The IRGC and entities affiliated with it)
  • SDGT (Specially-designated global terrorist)
  • FTO (foreign terrorist organization)
  • HRIT-IR (Human rights violations by Iranians)
  • HRIT-SY (Human rights violations in Syria, includes some Iranians)
  • IRAN-HR (Human rights violations by Iranians)
  • SYRIA (Support for the Assad regime)
  • IRAQ3 (Support for terrorism in Iraq)


The JCPOA lifts non-nuclear sanctions on 28 organizations and 11 individuals sanctioned under these restriction regimes, primarily for being components of the IRGC.  Another 9 individuals, identified in the JCPOA as being IRGC members, are not specifically listed by the U.S. Treasury department, but should be banned under the IRGC restrictions regime.


They include the following organizations:


  • The IRGC
  • Qods Force
  • National Iranian Oil Company (NIOC)
  • Naftiran Intertrade Co.
  • Khatam ol Anbia Construction Base
  • Bonyad Taavon Sepah (IRGC Charitable Organization)
  • Mehr Bank
  • IRGC Air Force al Ghadir Missile Command
  • IRGC Aerospace Force
  • Sepanir Oil and Gas Engineering Company
  • Sahel Consultant Engineers
  • Fater Engineering Institute
  • Rahab Institute
  • Imensazen Consultant Engineers Institute
  • Makin Institute
  • Ghorb Nooh
  • Oriental Oil Kish
  • Bank Saderat (sanctioned under the SDGT regime)
  • Behineh Trading
  • Behnam Shahriyari Trading Company
  • Gharargahe Sazandegi Ghaem
  • Ghorb Karbala
  • Hara Company
  • Iran Marine Industrial Company
  • Omran Sahel
  • Rah Sahel Institute
  • Sepasad Engineering Company
  • Tidewater Middle East Co.


The following individuals specified by U.S. Treasury:


  • Qassem Soleimani (SDGT, Syria, IRGC)
  • Mohammad Reza Naghdi (IRAN-HR, IRGC)
  • Parviz Fattah (IRGC)
  • Mostafa Mohammad Najjar (IRAN-HR; also IRGC BG)
  • Rostam Ghasemi (IRGC)
  • Azim Aghajani (aka Hossein Aghajani, SDGT, IRGC)
  • Ali Ahmadian (IRGC)
  • Mohammad Hejazi (IRGC)
  • Morteza Rezaei (IRGC)
  • Yahya Rahim Safavi (IRGC)
  • Ali Akbar Tabatabaei (SDGT, IRGC)
  • Mohammad Reza Zahedi (SDGT, IRGC)


The following members of the IRGC not specifically listed as such by the U.S. Treasury:


  • Javad Darvish-Vand, (IRGC BG, former Deputy Defense Minister)
  • Ali Fadavi (IRGC RADM, commander of IRGC Navy)
  • Ali Hoseynitash (former IRGC BG, deputy secretary of Supreme National Security Council)
  • Mohammad Pakpur (IRGC BG, commander of IRGC Ground Forces)
  • Hossein Salami (IRGC BG, Deputy Commander of IRGC)
  • Ali Shamshiri (IRGC BG, advisor to Iran's Ministry of Defense)
  • Ahmad Vahidi (IRGC BG, former commander of the Qods Force)
  • Morteza Safari (IRGC RADM, former commander of IRGC Navy)
  • Mohammad Bagher Zolqadr (IRGC BG, former Deputy Interior Minister)
  • Seyyed Mahdi Farahi (IRGC BG and Deputy Minister of Defense)

E.U. Non-Nuclear Sanctions


The European Union does not offer as clean and clear a delineation of the bases for its sanctions as the U.S. Treasury does.  Entities are generally sanctioned under E.U. Council Regulations and implementing directives on an annually-renewed basis.  The published E.U. sanctions list does not necessarily include all programs under which a given entity is designated, moreover.  It is nevertheless possible to identify a number of E.U. Council Regulations that clearly impose non-nuclear-related sanctions on specific Iranian entities.  They include:


  • 363/2013 (Human rights violations in Syria and support to the Assad regime)
  • 359/2011 (Human rights violations in Iran)
  • 235/2011 (Human rights violations in Iran)
  • 124/2013 (Human rights violations in Iran)
  • 1002/2011 (Human rights violations in Iran)
  • 2012/264 (Human rights violations in Iran)
  • 2012/1245 (Human rights violations in Iran)
  • 206/2013 (Human rights violations in Iran)
  • 371/2014 (Human rights violations in Iran)
  • 2015/1334 (Counter-terrorism)
  • 2015/548 (Human rights violations in Iran)
  • 2015/521 (Counter-terrorism)


A smaller number of entities designated under these programs are to be de-listed under the JCPOA:


  • Qods Force (363/2013)
  • Mohammad Reza Naghdi (359/2011)
  • Mohammad Hejazi (2015/548)
  • Qassem Soleimani (363/2013)