Renewing the Iran Sanctions Waivers (Part 1): Nuclear Activities

April 22, 2019

Weapon Program: 

  • Nuclear


Patrick Clawson


Washington Institute for Near East Policy

As the May 2 deadline for waiver extensions approaches, much attention has been devoted to the temporary waivers for Iranian energy exports—namely, gas and electricity deliveries to Iraq, and oil deliveries to eight countries. On April 22, Secretary of State Mike Pompeo announced that the latter deliveries would no longer be permitted. By contrast, the waivers for some Iranian nuclear activities have received little attention, apart from an April 9 letter from nine senators to President Donald Trump demanding their end.


All U.S. laws regarding sanctions on Iran permit national security waivers, usually temporary; some laws allow permanent exemptions, and of course the president can modify any executive order. During President Trump’s term, the State Department appears to have granted waivers for the following sanctions:

  • The Iran Freedom and Counterproliferation Act of 2012, specifically sections 1244 (covering energy, shipping, shipbuilding, and ports), 1245 (adding specially designated nationals and any sector of Iran’s economy determined to be “controlled directly or indirectly by Iran’s Revolutionary Guard Corps”), 1246 (“nuclear, military, or ballistic missile” items and precious metals), and 1247 (insurance for the previously cited activities). These sanctions can be waived for up to 180 days.
  • The Iran Threat Reduction and Syria Human Rights Act of 2012, sections 212(a) (covering insurance for Iranian oil shipments) and 213(a) (government borrowing), which can be waived for up to 180 days.
  • The Iran Sanctions Act of 1996, section 5(a) (covering oil and gas investment), which can be waived for up to 180 days.
  • The National Defense Authorization Act for fiscal year 2012, section 1245(d)(1) (covering foreign banks involved with Iran’s oil trade), which can be waived for up to 120 days.


Read the full article at The Washington Institute for Near East Policy.