It is the policy of the United States to deter Iran from developing its nuclear program, supporting terrorism, and abusing human rights by limiting the development of Iran’s energy sector, which is vital to its economy and government. The Iran Sanctions Act of 1996 (ISA), as amended, provides for sanctions against firms determined to have made certain investments in Iran’s energy sector. While the ISA applies to all firms, U.S. firms were already prohibited from investing in Iran under a U.S. trade embargo, and the ISA was enacted to encourage foreign firms to withdraw from the Iranian market. However, no sanctions have been imposed under the ISA by any prior administration.