Under the Joint Comprehensive Plan of Action (JCPOA), the United States and several other countries agreed to ease certain sanctions on Iran in exchange for Iran’s commitment to limit its nuclear program. This relaxation, however, was limited in scope to any nuclear-related sanctions, and the United States and other parties to the JCPOA continue to have the authority to sanction Iran for any activity related to efforts to further develop its ballistic missile program. The United States may continue to sanction Iran for such activity under Executive Orders 12938 and 13382, and the Departments of State and Treasury continue their efforts to identify sanctionable entities.
The Government Accountability Office released a report September on 28, 2017, examining (1) the extent to which State and Treasury have continued since issuance of the JCPOA to identify entities that are potentially sanctionable and (2) entities that have actually been sanctioned since January 2016. According to the report, State and Treasury have placed 33 entities and 25 individuals on the Specially Designated Nationals List since January 2016.