In the past, U.S. and European sanctions against Iran have focused heavily on its nuclear and ballistic missile programs. But over the last two years, that focus appears to have shifted.

Since U.S. President Joe Biden took office in 2021, nearly half of all sanctions designations by the United States and the European Union against Iran have targeted human rights violators. The overwhelming majority of those designations have come in the last nine months, following the death in custody of Mahsa Amini and the outbreak of the “Women, Life, Freedom” protests in Iran.

Of the remaining half, most have been aimed at sanctions evaders in the energy sector and entities contributing to Iran’s drone program. Notable increases in these designations appear to be tied, respectively, to the declining prospects for restoring the 2015 Joint Comprehensive Plan of Action (JCPOA) and Iran’s transfers of military drones to Russia for use against Ukraine.

The Wisconsin Project on Nuclear Arms Control compiled a data set that tallies Iran-related targeted designations by the United States and the European Union between January 20, 2021, and June 19, 2023. The data set identifies a total of 610 designations, comprising 418 additions or updates to the U.S. Specially Designated Nationals and Blocked Persons List (SDN List) and 192 additions or updates to the EU Consolidated List.[1]

U.S. Sanctions Energy, EU Focuses on Human Rights

U.S. sanctions during this period most heavily targeted Iran’s energy sector, including entities smuggling oil for the Islamic Revolutionary Guard Corps (IRGC) as well as those operating in or trading with Iran’s petrochemical industry. The first sanctions announcement by the Biden administration specifically targeting petrochemical sales was on June 16, 2022. This and subsequent actions aimed at the petrochemical industry were done under Executive Order 13846, which reimposed certain sanctions following the U.S. withdrawal from the JCPOA in 2018. In its first year, the Biden administration refrained from using this executive order to add new sanctions, as it wanted to distance itself from the Trump administration’s “maximum pressure” strategy and, more importantly, restore the deal. The increase in such sanctions in June 2022 and following, therefore, likely reflected a growing pessimism within the administration about the future of the JCPOA.

Although the United States also made over 100 designations related to human rights during this period, the European Union made even more: human rights violators accounted for 169 of the EU’s 192 designations against Iran.

Joint Focus on Drones

The remainder of EU designations targeted drone entities and were mostly imposed using Council Regulation (EU) No 269/2014, related to the conflict in Ukraine. In line with its commitments under the JCPOA, the European Union has not taken any sanctions action against Iran’s energy sector or nuclear or missile programs since 2016.

The United States only began explicitly targeting such entities in October 2021, but it increased the pace in the fall of 2022 following Iran’s transfer of drones to Russia. And, unlike the European Union, the United States has also begun sanctioning parties in third countries such as China and Turkey that have supplied Iran’s drone program. These designations have largely been imposed under Executive Order 13382—intended to target proliferators of weapons of mass destruction (WMD) and their supporters—even though there is no evidence the drones can or would be used to deliver WMD.

Meanwhile, U.S. drone designations have seemingly supplanted those related to Iran’s missile and nuclear programs. Since taking office, the Biden administration has not made a single sanctions announcement directly targeting Iran’s nuclear program and has made only two related to the ballistic missile program, in March 2022 and June 2023. The absence of nuclear-related sanctions may partially reflect an effort by the Biden administration to avoid a provocation while it was trying to reinstate the JCPOA. Or it may be due to a lack of good targets, with most entities involved in Iran’s nuclear and missile work already subject to sanctions, whereas the drone industry represents relatively fertile ground for new designations. Finally, the shift may reflect a re-evaluation of priorities around an evolving threat picture, as Iran, its non-state partners, and now Russia make increasing use of Iranian-made drones in conflicts that touch upon U.S. interests around the globe.