According to the Congressional Research Service (CRS) and the U.S. Department of the Treasury, the Obama administration lifted nuclear-related secondary sanctions on January 16, 2016, under the Joint Comprehensive Plan of Action (JCPOA), while leaving primary U.S. trade embargoes and non-nuclear sanctions in place. However, the U.S. re-imposed all sanctions lifted by Obama in November 2018, meaning a comprehensive web of primary, secondary, and sector-specific sanctions remains active. [1, 2, 3, 4, 5]
Sanctions Lifted or Waived by Obama (January 2016)
Following verification by the International Atomic Energy Agency (IAEA) that Iran had met its nuclear commitments, President Barack Obama signed an executive order revoking or waiving secondary sanctions that penalized non-U.S. companies and foreign governments for doing business with Iran: [1, 2]
- Oil, Gas, and Petrochemicals. The U.S. lifted secondary sanctions restricting the purchase, acquisition, sale, transport, or marketing of Iranian crude oil, petroleum products, and petrochemicals. [1, 2]
- Banking and Financial Sectors. Restrictions on foreign financial institutions conducting transactions with the Central Bank of Iran and designated Iranian banks were removed, restoring Iran's access to international currency markets and the SWIFT financial messaging system. This action also unfroze an estimated $50 billion to $150 billion in overseas Iranian assets. [1, 2]
- Shipping, Shipbuilding, and Ports. Penalties on foreign entities providing port services, vessel registration, insurance, or shipping support to Iran's maritime sector were lifted. [1]
- Industrial and Metals Sectors. Secondary sanctions targeting Iran's automotive sector as well as trade in gold, precious metals, graphite, raw or semi-finished metals, and coal were suspended. [1]
- Targeted Licensing and Designations. The Treasury Department removed roughly 400 Iranian individuals, companies, vessels, and aircraft from its blocked persons list. The administration also created narrow exceptions to the U.S. trade embargo, permitting case-by-case licensing for commercial passenger aircraft sales (such as Boeing and Airbus) and lifting the import ban on Iranian carpets and certain foodstuffs like pistachios. [1, 2]
Sanctions Obama Kept in Place
- Primary U.S. Trade Embargo. Under the Iranian Transactions and Sanctions Regulations (ITSR), U.S. citizens, permanent residents, and domestic companies remained strictly prohibited from almost all trade, investment, and financial transactions with Iran.
- Non-Nuclear Executive Orders. Eight separate executive orders remained active, targeting Iran for support of terrorism, ballistic missile development, human rights abuses, and regional destabilization.
- Key Entity Designations. Sanctions remained firmly in place against the Islamic Revolutionary Guard Corps (IRGC), the Quds Force, and designated terrorist groups like Hezbollah. [1, 2, 3]
Sanctions Remaining in Effect
In May 2018, the Trump administration withdrew from the JCPOA, and by November 5, 2018, the U.S. fully re-imposed every sanction Obama had lifted. According to the Congressional Research Service and the U.S. Department of State, the active sanctions regime encompasses both the re-imposed Obama-era penalties and subsequent expansions: [1, 2, 3, 4]
- Comprehensive Trade and Asset Freeze. A near-total ban prohibits U.S. persons from trading with Iran and blocks all Government of Iran property within U.S. jurisdiction.
- Energy and Maritime Restrictions. Secondary sanctions heavily penalize foreign buyers, insurers, and shippers involved in Iran's oil, gas, petrochemical, and maritime sectors, alongside ongoing operations targeting Iran's "shadow fleet" of tankers and fraudulent ship registries. (Occasional short-term waivers have occurred, such as a temporary 60-day oil sanction pause during diplomatic negotiations in mid-2026).
- Financial Isolation. Foreign banks face severe penalties and loss of access to the U.S. financial system if they conduct significant transactions with the Central Bank of Iran or sanctioned Iranian institutions.
- Broad Economic Sectors. U.S. secondary sanctions cover Iran's automotive, manufacturing, construction, mining, textiles, iron, steel, aluminum, and copper industries.
- Leadership, Military, and Weapons. Strict sanctions target Supreme Leader Ali Khamenei's office, the IRGC, Iran's arms trade, drone and ballistic missile programs, and human rights violators.
- Humanitarian Exemptions. Food, medicine, medical devices, and agricultural commodities remain legally exempt from U.S. sanctions, though financial restrictions frequently complicate payment processing for these goods. [1, 2, 3, 4]

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