While it has been the “year of Russia” when it comes to sanctions, the collapse of the nuclear talks (JCPOA) as well as the social repression in the country have also shifted the focus to Iran to an extent.

As the U.S. continued to designate members of the Islamic Revolutionary Guards Forces (IRGF) as Specially Designated Nationals (SDNs), it has also placed on the black list many key companies that assist its unmanned aerial vehicle (UAV) sector.  It seems the U.S. will continue to pile on the pressure on Iran, as a bipartisan bill surfaced in Congress targeting the key source of income for the country.  

Introduced by U.S. Senators Marco Rubio (R-FL), Maggie Hassan (D-NH), and Jacky Rosen (D-NV) the Stop Harboring Iranian Petroleum (SHIP) Act purports to sanction illicit purchases of Iranian oil and hold the regime’s enablers accountable.

Specifically, the bill foresees the imposition of sanctions against entities that engage in the illicit Iranian oil trade, including through ship-to-ship transfers of, entities that own refineries the processes Iranian oil, as well as entities that are included on the OFAC SDN list.  In addition, it requires a report from the U.S. Administration regarding the increase of exports of petroleum and petroleum products from Iran.

From the remarks made by some of the sponsors of the bill, it seems also that an indirect target is China.  Since the inception of the Russia-Ukraine war, the China-Russia-Iran axis have further solidified, where these countries significantly increased their economic ties with each other. As China seeks to continue its technological advancement, it procures a significant amount of its energy from Iranian sources.

By seeking to impose sanctions on foreign entities – including owners and operators of ports, ships and refineries – that knowingly transport, offload or refine Iranian oil or its products, the U.S. is looking to further flex its secondary sanctions muscle on Iran.  It remains to be seen what, if any, implications this would have on jurisdictions, such as the EU and the UK, that do not have an embargo on Iran like the U.S..The SHIP Act: U.S. Takes Aim at Iran's Oil Trade and China's Role in the Middle East