U.S. Sanctions on Iran in 2020

In 2020, the United States ratcheted up its “maximum pressure” campaign to force Tehran to negotiate a new and broader deal on Iran’s nuclear program, missiles test, intervention in the Middle East and support for extremist movements. U.S. sanctions on Iran caused “a currency crisis, mounting public debt, and rising inflation,” Secretary of State Mike Pompeo said on November 18. “The regime desperately needs an economic lifeline… The maximum pressure campaign is working, sanctions will continue, and the United States will not hesitate to impose painful consequences on those who engage in sanctionable activity.”

2020 was also marked by tensions, especially after the U.S. killing of General Qassem Soleimani, the commander of Iran’s elite Qods Force, in a drone strike in January 3. In retaliation, Iran launched more than a dozen missiles at two Iraqi bases housing U.S. troops. More than 100 troops reported brain injuries of various seriousness. Iraqi militias supported by Iran—many under the umbrella of the Popular Mobilization Forces—launched small-scale attacks against the U.S. Embassy in Baghdad, bases housing U.S. soldiers and coalition convoys.

But the majority of the Trump administration’s actions against Iran centered on a wide array of sanctions, on the military, banks, the airline and shipping industries, arms suppliers, media outlets, technology firms, and companies in other countries buying oil from or trading with Iran. The U.S. also sanctioned top Iranian officials, notably the head of the Supreme National Security Council, the Interior Minister, the head of the Atomic Energy Organization of Iran, and five members of the Guardian Council. The following is a timeline of sanctions imposed under the Trump administration.

January 10: President Trump issued an executive order authorizing sanctions on the construction, manufacturing, textiles and mining sectors. Mining and metals have historically been one of the regime's largest non-oil sources of export revenue, some 10 percent. The Treasury Department sanctioned 17 Iranian metals producers and mining companies, two firms based in China and one in the Seychelles involved in the metals industry, and one ship that transferred steel to China.

The Treasury Department also sanctioned eight senior security officials – including Ali Shamkhani, the head of the Supreme National Security Council – for their involvement in missile strikes on January 7 on two Iraqi military bases housing U.S. troops. The attacks were retaliation for the killing of General Qassem Soleimani, the head of the elite Qods Force, in a U.S. drone strike.

January 17: The State Department sanctioned an Islamic Revolutionary Guard Corps (IRGC) commander for his involvement in the crackdown on demonstrators in November 2019. Brigadier General Hassan Shahvarpour “oversaw the massacre of 148 helpless Iranians in the Mahshahr region,” Special Representative for Iran Brian Hook told reporters. Hook said that information about Shahvarpour and other regime officials came from some 88,000 tips received by the State Department from Iranians. 

January 23: The Treasury Department sanctioned two Hong Kong-based companies, one China-based company and one United Arab Emirates-based company for purchasing Iranian oil and petrochemical products. “Iran’s petrochemical and petroleum sectors are primary sources of funding for the Iranian regime’s global terrorist activities and enable its persistent use of violence against its own people,” Treasury Secretary Steven Mnuchin said. The State Department sanctioned two Hong-Kong based firms and one Chinese company along with two executive officers for involvement in the purchase, sale or transport of Iranian petrochemical products. 

January 30: The State Department and Treasury Department sanctioned the Atomic Energy Organization of Iran (AEOI) and its chief, Ali Akbar Salehi. Hook accused Salehi of having “personally inaugurated the installation of new advanced centrifuges to expand [Iran’s] uranium enrichment capacity.” Enriched uranium can be used to produce energy or fuel a nuclear bomb.

February 20: Special Representative Hook announced sanctions on five key members of Iran’s Guardian Council, an unelected panel of 12 Islamic jurists and scholars: Ahmad Jannati, Abbas Ali Kadkhodaei, Siamak Rahpeyk, Mohammad Hasan Sadeghi Moghadam and Mohammad Yazdi. The council disqualified more than 9,000 out of some 14,000 candidates who registered to run in parliamentary elections, scheduled for February 21. “The Trump administration will not tolerate the manipulation of elections to favor the regime’s malign agenda, and this action exposes those senior regime officials responsible for preventing the Iranian people from freely choosing their leaders,” Treasury Secretary Mnuchin said. “The United States will continue to support the democratic aspirations of Iranians.”

February 25: The State Department announced sanctions on 13 foreign companies and individuals for supporting Iran's missile program. The entities were based in China, Iraq, Russia, and Turkey. The State Department said that the action was based on a periodic review required under the Iran, North Korea, and Syria Nonproliferation Act.

March 17: Secretary of State Mike Pompeo announced new sanctions on a petrochemical smuggling network and Iran’s nuclear program. The State Department designated nine companies in South Africa, Hong Kong and China, as well as three Iranian nationals, for purchasing, selling and transporting petrochemical products from Iran.

March 26: The United States sanctioned 20 front companies, senior officials and business associates based in Iran and Iraq for funneling money to the Qods Force, the external operations arm of the IRGC, and transferring weapons to Iraqi militias backed by Iran.

May 1: The Treasury Department sanctioned Amir Dianat, a dual Iranian-Iraqi national, for supporting Iranian arms smuggling operations. Dianat’s company, Taif Mining Services LLC, was also designated as a front company for the Qods Force. “The Iranian regime and its supporters continue to prioritize the funding of international terrorist organizations over the health and well-being of the Iranian people,” Treasury Secretary Mnuchin said.

May 19: The Treasury Department sanctioned a China-based company for providing services to Mahan Air, an Iranian airline sanctioned in 2011 for supporting the elite Qods Force. Mahan Air has transported fighters, weapons, equipment and funds to support the Syrian regime and Iranian proxies across the Middle East, including Hezbollah. Shanghai Saint Logistics Limited was the seventh company sanctioned for acting as a general sales agent for Mahan Air. 

Interior Minister Abdolreza Rahmani Fazli

May 20: The United States sanctioned Interior Minister Abdolreza Rahmani Fazli for human rights abuses. Fazli allegedly authorized police to use lethal force on protestors in November 2019. The Treasury Department also sanctioned seven Law Enforcement Forces (LEF) officials and an IRGC commander who were involved in the bloody crackdown. The United States also sanctioned two prisons and a wealthy foundation controlled by the LEF.

The State Department imposed visa restrictions on Ali Fallahian, who headed the Ministry of Intelligence and Security from 1989 to 1997. Fallahian was allegedly involved in assassinations and attacks across the world, including the killing of a U.S. exchange student in the Gaza Strip in 1995 and the bombing of a Jewish community center in Buenos Aires that left 85 dead in 1994.

May 27: Secretary Pompeo announced the end of waivers allowing British, Chinese and Russian companies to work at three Iranian nuclear sites. The work focused on ways to contain or limit Iran’s ability to use its nuclear program to build a bomb. The foreign projects were part of the 2015 nuclear deal between Iran and the world’s six major powers. Foreign companies involved were given 60 days to wind down activities on three projects or they would face U.S. sanctions. 

June 8: The United States expanded sanctions on Iran’s shipping industry. The Treasury Department designated Islamic Republic of Iran Shipping Lines (IRISL) and its Shanghai-based subsidiary, E-Sail Shipping Company Ltd, along with more than 100 ships and tankers. “IRISL has repeatedly transported items related to Iran’s ballistic missile and military programs and is also a longstanding carrier of other proliferation-sensitive items,” including items that can be used in Iran’s nuclear program, Secretary Pompeo said. He had announced the measures six months ago but delayed implementation for 180 days to allow exporters to find alternative ways to ship humanitarian goods, which are exempt from U.S. sanctions, to the Islamic Republic.

June 25: The Treasury Department sanctioned four companies in Iran’s metals sector, a key source of export revenue. It also sanctioned four sales agents—one based in Germany and three based in the United Arab Emirates—that are owned or controlled by Mobarakeh Steel Company, Iran’s largest steel manufacturer.

August 19: The Treasury Department sanctioned two companies based in the United Arab Emirates for providing parts and logistics services to Iranian airline Mahan Air. “The Iranian regime uses Mahan Air as a tool to spread its destabilizing agenda around the world, including to the corrupt regimes in Syria and Venezuela, as well as terrorist groups throughout the Middle East,” Secretary Mnuchin said.

August 21: The State Department imposed visa restrictions on 14 officials involved in “gross violations of human rights on behalf of the Iranian regime.” Secretary Pompeo said that 13 were assassins who carried out “a brutal and intricately planned” assassination of Dr. Kazem Rajavi, the first revolutionary ambassador to the U.N. office in Geneva who resigned in 1980. Hojatollah Khodaei Souri, the former director of notorious Evin Prison, was the 14th official sanctioned. “These actions send a message of support to the Islamic Republic of Iran’s many victims worldwide that we will promote accountability for those who spread terror and violence,” Pompeo said. “The United States will continue to pressure Iran to treat its own people with dignity and respect.”

September 3: The State Department sanctioned five companies for the purchase, acquisition, sale, transport and marketing of Iranian petroleum. The Treasury also sanctioned six companies with ties to Triliance Petrochemical – a Hong Kong-based company with branches in Iran, China, Germany and the United Arab Emirates. The Treasury had sanctioned Triliance in January 2020 for transferring the equivalent of millions of dollars to the National Iranian Oil Company.

A Treasury diagram detailing Rana's global operations

September 17: The Treasury Department sanctioned two groups for cyber espionage. The new sanctions covered Rana Intelligence Computing Company, an Iranian cyber firm, and a cyber espionage group dubbed “Advanced Persistent Threat 39 (APT 39)” by U.S. cyber security companies. The Treasury also designated 45 individuals employed by Rana. All were allegedly working – directly or indirectly – for the Ministry of Intelligence and Security (MOIS).    

September 19: The United States reimposed U.N. sanctions on Iran that had been lifted as part of the 2015 nuclear deal. Secretary Pompeo declared that the United States would unilaterally reenact five sets of U.N. sanctions from 2006 through 2010, despite opposition from the other five major powers that brokered the nuclear deal and most of the 15-member Security Council. The old sanctions reimposed by the United States included: Resolution 1696, Resolution 1737, Resolution 1747, Resolution 1803 and Resolution 1929.

September 21: The United States sanctioned 24 government organizations, companies, officials and suppliers connected to Iran’s conventional arms, nuclear and missile programs. The new sanctions targeted:

  • Iran’s Ministry of Defense and Armed Force Logistics (MODAFL)
  • Iran’s Defense Industries Organization (DIO), the state-run conglomerate that oversees domestic military manufacturing, and its director Mehrdad Akhlaghi-Ketabchi
  • Three AEOI deputy directors and the AEOI spokesperson
  • Six individuals and four companies that supplied liquid fuel for ballistic missiles and space rockets
  • Five Iranian nationals involved in procuring nuclear material or acquiring knowledge on nuclear technology 
  • Two Iranian officials who supervised or installed advanced centrifuge installation
  • Nicholas Maduro, the president of Venezuela, for the purchase or sale “of arms or related material, including spare parts” from Iran

October 8: The Treasury Department sanctioned 18 major Iranian banks to stop illicit access to U.S. dollars. Most Iranian banks, including the Central Bank that facilitates trade and regulates currency, were already sanctioned. The new measures mainly hit private banks that had limited or no involvement illicit activities. They were designated because the Trump administration had declared Iran’s entire financial sector a threat to the United States. One bank was affiliated with the military.

October 19: The State Department sanctioned six companies and two individuals based in China and Hong Kong for doing business with companies owned or controlled by IRISL. IRISL and its Shanghai-based subsidiary, E-Sail Shipping Company Ltd, had been sanctioned in June 2020 for transporting items related to Iran’s ballistic missile and military programs.

IRGC election
A Treasury Department infographic on IRGC front companies

October 22: The United States sanctioned five government entities – some disguised as media outlets – for trying to influence the U.S. elections. The Treasury Department designated the IRGC, the Qods Force, Bayan Gostar Institute, Iranian Islamic Radio and Television Union and International Union of Virtual Media. It alleged that Iran ran disinformation campaigns to sow discord among readers via social media and messaging applications.


October 26: The United States sanctioned Iran’s Ministry of Petroleum and Minister of Petroleum, the National Iranian Oil Company (NIOC), the National Iranian Tanker Company (NITC), and 21 other individuals, entities and vessels. NIOC, NITC and the National Petrochemical Company had already been sanctioned, but under different authorities. The Trump administration designated them under a counterterrorism authority for supporting the Qods Force.

October 29: The State Department and Treasury Department sanctioned 11 companies based in Iran, China and Singapore for purchasing and selling Iranian oil. Four Iranian men and one Chinese woman were also added to the sanctions list. “The Iranian regime benefits from a global network of entities facilitating the Iranian petrochemical sector,” Secretary Mnuchin said. “The United States remains committed to targeting any revenue source the Iranian regime uses to fund terrorist groups and oppress the Iranian people.”

November 10: The Treasury Department sanctioned six companies and four individuals for supplying electronic components to an Iranian military firm. Two of the companies were based in Iran, one in Hong Kong, one in China and one in Brunei. Another firm claimed to have offices in China, Singapore, Taiwan and the UAE. Two of the individuals were Iranian nationals and two were Taiwanese nationals.

Intelligence Minister Mahmoud Alavi

November 18: The Treasury Department sanctioned Intelligence Minister Mahmoud Alavi for complicity in human rights abuses, including the violent crackdown on protestors in November 2019. It also designated Bonyad Mostazafan—or the Foundation of the Oppressed—as well as 10 men and 51 companies controlled or owned by the foundation and involved in the energy, finance and mining sectors. The foundation, allegedly controlled by Supreme Leader Ayatollah Ali Khamenei, was established after the 1979 revolution to help the poor and disabled. Khamenei “uses Bonyad Mostazafan to reward his allies under the pretense of charity,” Secretary Mnuchin said.

The State Department separately sanctioned two senior Revolutionary Guards—Brigadier General Heidar Abbaszadeh and Colonel Reza Papi—for their roles in the 2019 protests, when nearly 150 people were killed in the city of Mahshahr. “Both protesters and bystanders were targeted by snipers on rooftops, tracked down and surrounded by armored vehicles, and sprayed with machine-gun fire,” Secretary Pompeo said. “When protesters sought refuge in nearby marshlands, regime forces set fire to the area and then shot those trying to escape.”

November 25: The State Department sanctioned four companies for supporting Iran’s missile program, under the Iran, North Korea, and Syrian Nonproliferation Act. Two of the companies—Chengdu Best Materials Co. Ltd. and Zibo Elim Trade Co., Ltd. —were located in China. Nilco Group and Joint Stock Company Elecon were located in Russia.

December 3: The Treasury Department sanctioned an Iranian firm, Shahid Meisami Group, and its director for chemical weapons research. The shop was a subsidiary of the Iranian Organization of Defensive Innovation and Research (SPND), established in 2011 by the prominent nuclear scientist Mohsen Fakhrizadeh. The United States sanctioned SPND in 2014 for conducting research on weapons of mass destruction. Fakhrizadeh, long suspected by Western and Israeli intelligence of heading Iran’s nuclear weapons program, was assassinated in November 2020. 

December 8: The Treasury Department sanctioned Hasan Irlu, Iran's diplomatic envoy to the Houthis in Yemen, for allegedly helping to provide advanced weapons and training to the rebels. The Trump administration also sanctioned Yousef al Muraj, a Pakistani operative with alleged ties to the IRGC. It also sanctioned al Mustafa International University, which it claimed was a center for militia recruitment by the IRGC.

December 14: The Treasury Department sanctioned two Iranians allegedly involved in the disappearance of former FBI agent Robert Levinson. Levinson was abducted on Iran’s Kish Island in March 2007. Thirteen years later, in March 2020, Levinson’s wife and children said that they believed he had died in Iranian custody, based on information provided by U.S. officials. Mohammad Baseri and Ahmad Khazai, senior Ministry of Intelligence and Security officials, “were involved in the abduction, detention, and probable death of Mr. Levinson,” Secretary Pompeo said.

December 15: The State Department designated Saraya al Mukhtar, a Bahrain-based militia with ties to Iran, as a terrorist organization. Saraya al Mukhtar “plotted attacks against U.S. personnel in Bahrain and has offered cash rewards for the assassination of Bahraini officials,” Secretary Pompeo said. It also allegedly received financial and logistic support from Iran’s Islamic Revolutionary Guard Corps. Saraya al Mukhtar’s goal is to overthrow the monarchy. The listing cut off Saraya al Mukhtar from the U.S. financial system and banned U.S. citizens from dealing with it.

December 16: The Treasury Department sanctioned four companies – two based in China and two based in the UAE – for facilitating the export of Iranian oil by a previously designated firm, Triliance. Four companies, including Triliance, were sanctioned in January 2020 for collectively transferring hundreds of millions of dollars’ worth of exports from the National Iranian Oil Company.

Concurrently, the State Department sanctioned Vietnam Gas and Chemicals Transportation Corporation and its managing director for involvement in Iranian oil sales. 


Photo Credits: Fazli by Fars News Agency, CC BY 4.0, via Wikimedia Commons; Alavi by Tasnim News Agency, CC BY 4.0, via Wikimedia Commons