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. Primary targets of the Act include companies selling refined petroleum and refining products to Iran, as well as international banks that do business with Iran’s most notorious actors. In a mandatory new banking sanction, the Act takes aim specifically at businesses providing any financial services for the Islamic Revolutionary Guards Corps (IRGC), and other entities blacklisted by the U.S. Treasury Department