H.R. 2194, the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, would strengthen the underlying Iran Sanctions Act (ISA) by imposing an array of tough new economic penalties aimed at persuading Iran to change its conduct. The Act reinforces and goes far beyond recently-enacted UN Sanctions. Targets of the Act range from business entities involved in refined petroleum sales to Iran or support for Iran’s domestic refining efforts to international banking institutions involved with Iran’s Islamic Revolutionary Guards Corps (IRGC) or with Iran’s illicit nuclear program or its support for terrorism.