Sanctions-related Statute - Iran-Iraq Arms Non-Proliferation Act of 1992 (IIANPA)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (598 words)

Notes:

IIANPA is not particularly notable for ordinary sanctions compliance purposes, but there are two aspects of it of continued relevance.

1) The secondary sanction-like provision of Sec. 1604, which is administered by the State Department, is still active, and several entities have been sanctioned pursuant to it since the inception of the statute. In practice, however, it is not clear whether this statute will ever be relevant again, at least with respect to Iran. provides for a procurement ban and export license ban upon a determination that a person has knowingly transferred goods or technology so as to contribute knowingly and materially to the efforts by Iran to acquire chemical, biological, or nuclear weapons or to acquire destabilizing numbers and types of advanced conventional weapons. However, more recent mandatory sanctions, most significantly

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Iran-Iraq Arms Non-Proliferation Act of 1992 (IIANPA)

TURBOFAC Commentary (598 words)