June 07, 2017

S.722 – Iran Sanctions


Background: S. 722, Countering Iran’s Destabilizing Activities Act of 2017, was introduced on March 23, 2017. The Senate Foreign Relations Committee marked up the bill on May 25 and reported it out by a vote of 18-3.

Floor Situation: Cloture has been filed on the motion to proceed to this bill, which will ripen by rule one hour after the Senate comes into session Wednesday June 7. 

Executive Summary: On one of his last days in office, outgoing Secretary of State John Kerry praised the nuclear agreement with Iran and said we would “push back” on Iran for its continued support for terrorism and other destabilizing activities. This bill is part of that pushback, codifying sanctions directed at Iran’s threatening behavior. This bill does not violate the nuclear agreement. That agreement was about providing “relief only from nuclear-related sanctions,” as the Obama administration repeatedly said. Moreover, it does not prevent the United States from using sanctions in response to Iran’s non-nuclear threatening behavior. 

Overview of the Issue

Iran continues to present a significant threat to U.S. interests. The director of national intelligence testified last month that “Iran continues to be the foremost state sponsor of terrorism.” RPC has previously analyzed how Iran also continues to provide critical support to Bashar al-Assad in Syria, violate multiple international arms embargoes, and test ballistic missiles.

This bill responds to this destabilizing behavior. It codifies sanctions directed at Iran’s ballistic missile program, violations of arms embargoes, and systematic human rights abuses.

It also addresses Iran’s continued support for terrorism. Executive Order 13224, issued soon after the September 11 terrorist attacks, sanctions entities determined to be supporting international terrorism. Several Iranian-related entities are already sanctioned under that order, including the Islamic Revolutionary Guard Corps – Qods Force, but not the IRGC.

The State Department has said “the IRGC-QF is Iran’s primary mechanism for cultivating and supporting terrorists abroad.” This bill makes a finding that the IRGC, (not just the IRGC-QF), is responsible for supporting terrorism. The bill then requires that the sanctions of Executive Order 13224 be applied against the IRGC.  

This bill does not violate the nuclear agreement with Iran. As the Obama administration said repeatedly, the nuclear agreement was about providing Iran “relief only from nuclear-related sanctions.” As CRS said, the nuclear agreement “did not require the United States to refrain from imposing additional sanctions on Iranian proliferation, human rights abuses, terrorism, or the IRGC.” Furthermore, at the time this bill was introduced, CRS observed that its provisions “do not appear to conflict with the JCPOA insofar as it would not reimpose the lifted sanctions on Iran’s civilian economic sectors.”

By way of example, Iran conducted a ballistic missile test on January 29 of this year. The Treasury Department responded by announcing five days later that it was placing sanctions under Executive Order 13382 on 17 people and entities for their support of Iran’s ballistic missile program. It also sanctioned eight additional IRGC-QF entities under Executive Order 13224. Those sanctions did not violate the nuclear agreement.

Secretary of State John Kerry said in his final days of service, “We still have serious differences with the Government of Iran, and will continue to push back on its support for terrorism, disregard for human rights, and destabilizing regional activities.” This bill is that pushback.

Notable Bill Provisions

Section 4 – Iran ballistic missile sanctions

Directs the president to impose sanctions on any person who knowingly engaged in any activity that materially contributes to Iranian ballistic missile program activities, or any other program for a system to deliver a weapon of mass destruction.

Section 5 – IRGC sanctions

Makes a congressional finding that “the IRGC, not just the IRGC-QF, is responsible for implementing Iran’s international program of destabilizing activities, support for acts of international terrorism, and ballistic missile program.” It then directs the president to impose on the IRGC, 90 days after enactment, the sanctions mandated by Executive Order 13224.

Section 6 – Sanctions for Iran human rights abuses

Directs the secretary of state to submit a list of people determined to be responsible for gross human rights violations committed against individuals in Iran who seek to promote human rights, and provides that the president “may” block any property these abusers of human rights have in the United States.

Section 7 – Enforcement of arms embargoes

Directs the president to impose sanctions on any person who contributes to the transfer of certain arms “to or from Iran.” The prohibited arms transfers is the U.N. arms embargo list.

Section 9 – US-EU sanctions coordination

Requires a report every 180 days of each instance in which either the United States or the European Union has imposed terrorism, proliferation, or human rights sanctions and the other entity has not imposed corresponding sanctions.

Section 12 – Waiver authority

Authorizes the president to waive the requirement in this bill to impose sanctions.

Administration Position

The administration has not taken a public position on the bill at this time. 


The Congressional Budget Office has not issued a formal cost report at this time. 


Leader McConnell has spoken of his expectation that “amendments addressing Russia sanctions are likely to be offered.”