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. 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 Guard Corps (IRGC), Iran’s illicit nuclear program or its support for terrorism. The Conference text would augment the sanctions regime envisioned in the earlier versions of the Act passed by the House and the Senate by supplementing the energy sanctions in those versions with an additional, powerful set of banking prohibitions.