Iran is subject to targeted sanctions from the EU and comprehensive sanctions from the US. Since November 2018, US sanctions have restricted Iranian access to the international financial system and targeted almost every sector of the Iranian economy.
International sanctions on Iran frequently involve a range of competing priorities. For example, while the EU has generally opposed US plans to increase sanctions on Iran, on 8 January 2019, the EU itself imposed new sanctions on individuals associated with Iran’s intelligence services in response to allegations of Iranian assassinations in Netherlands, Denmark and France.
In 2018, Germany, France and the UK began discussions to create a special purpose vehicle (SPV) to circumvent US sanctions. While the SPV was initially designed as a potential mechanism for clearing Iranian oil transactions in euros, its scope was restricted for fear of provoking US financial penalties on European institutions. Analysis indicates that the SPV is now more likely to be used for providing humanitarian goods to Iran, which are not currently subject to US sanctions.
In November 2018, seventeen Saudi officials were added to the US Specially Designated Nationals (SDN) list for their roles in the killing of journalist Jamal Khashoggi. The individuals were designated pursuant to Executive Order 13818, which allows the US Treasury to target perpetrators of serious human rights abuse. In the same month, Canada and the EU also imposed asset freezes and travel bans against the same seventeen individuals.
The government of Sudan and non-state militant groups operating in the country are currently subject to a US and UN arms embargo. Four individuals who are deemed to have contributed to instability in Darfur, western Sudan, are subject to a US and UN asset freeze and travel ban. UN sanctions against Sudan have been adopted by the EU.
Syria has been on the US State Sponsors of Terrorism list since 1979, and the US in particular has imposed various restrictions on economic activity since then. Most recently, the ongoing Syrian civil war has resulted in sanctions by the US, EU and a number of other countries. These sanctions have targeted the regime of President Assad and his associates, and also include restrictions on investment, financing, trade in petroleum and chemical products, gold and precious metals, and provision of equipment that could be used in human rights abuses by the Syrian and Iranian governments.
As the Assad regime consolidates control over the country, Russian and Chinese companies have already made some investments in reconstruction, and other international companies are eyeing lucrative reconstruction projects. However, the US and EU have indicated they do not intend to lift sanctions without a political settlement.
There are two separate sanctions regimes that affect Yemen directly. Since 2012, the UN, US, and EU have imposed a travel ban and asset freeze on certain Yemeni nationals for supporting Houthi rebels in the Yemen civil war and undermining the internationally recognised Yemeni government. The US and UN have also imposed similar sanctions on individuals in Yemen associated with Al Qaeda in the Arabian Peninsula (AQAP), an Islamist militant organisation.
Most sanctions on Iraq were lifted following the US invasion in 2003. However, some targeted US, EU, and UN sanctions remain on the arms trade, and individuals and companies seen as destabilising the country, such as those linked to the regime of former president Saddam Hussein, terrorist entities, and Iranian-backed and other militias.
In April 2011, the UN Security Council imposed sanctions on Libya in response to human rights violations by the regime of Muammar Ghaddafi, the head of state of Libya from 1969 to 2011. While the UN sanctions were lifted following Ghaddafi’s death in October 2011, the Libyan Investment Authority (LIA) and the Libya African Investment Portfolio, two investment vehicles of the Libyan government, are currently subject to UN asset freezes due to an ongoing governance dispute between rival governments in Tripoli and eastern Libya. According to the UN, sanctions will be lifted if the internationally recognised government can regain control of all of the LIA’s assets. In addition, since 2016 several Libyans have been subject to US sanctions for contributing to the ongoing instability in Libya.