This bill forbids the issuance of any license or waiver for transactions involving Iranian individuals and entities that were on the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list under Executive Order 13224 as of January 20, 2021, unless the President certifies to four specific congressional committees that those persons have ceased involvement in terrorism. The certification requirement is the gatekeeper: without it, Treasury may not grant licenses or waivers that would otherwise permit dealings with the named parties.
Why it matters: the measure narrows the executive branch’s room to negotiate or provide targeted relief for a defined set of Iran-linked persons by turning sanctions relief into a politically accountable act requiring an explicit presidential declaration to oversight committees. That shifts practical control over when and whether to relax certain sanctions away from Treasury and toward a public, congressional checkpoint — with consequences for diplomacy, enforcement discretion, and commercial actors seeking licenses for transactions touching the specified persons.
At a Glance
What It Does
The bill bars OFAC or other agencies from issuing licenses or waivers for transactions with Iranian individuals and entities that were on the EO 13224 SDN list as of Jan 20, 2021, unless the President certifies those persons have stopped participating in terrorism. It preserves any OFAC general licenses that were already in effect on Jan 20, 2021.
Who It Affects
Directly affects OFAC/Treasury licensing practice, the Executive Branch’s ability to grant targeted sanctions relief, and any U.S. or foreign parties seeking authorization to transact with the named Iranian SDNs. It also engages four congressional committees that must receive presidential certifications.
Why It Matters
Professionals in sanctions compliance, foreign policy, and export control need to know that longstanding SDNs tied to terrorism will be insulated from ad hoc relief absent a formal presidential certification to Congress, creating a higher political and procedural bar to reopening economic channels with those actors.
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What This Bill Actually Does
The bill creates a near-absolute prohibition on issuing licenses or waivers for transactions with a narrowly defined group: Iranian persons who appear on OFAC’s Specially Designated Nationals list because they were designated under Executive Order 13224, as that list stood on January 20, 2021. That means any attempt by a U.S. person or foreign party to obtain a Treasury license, or for Treasury to issue a waiver, enabling a transaction with those named individuals or entities is blocked unless the President makes a formal certification.
The certification must state that the covered foreign persons have ceased involvement in terrorism, and the statute specifies four congressional bodies to which the President must report: two committees in the House (Foreign Affairs; Financial Services) and two in the Senate (Foreign Relations; Banking, Housing, and Urban Affairs). The bill does not define the evidentiary standard for ‘‘ceased involvement in terrorism’’ or set deadlines for when certifications must be made, which leaves the substance and timing of any review to executive practice.Finally, the bill expressly preserves any OFAC general licenses that were in effect on January 20, 2021.
That carve-out means preexisting blanket authorizations remain usable even for transactions involving the persons on the enumerated list; the prohibition functions primarily against new, discretionary licenses or waivers issued after that date unless the presidential certification is made. The combination of a fixed historical list and a high-certification threshold channels sanction-relief decisions into an inter-branch, politically visible process rather than administrative waiver practice.
The Five Things You Need to Know
The bill prohibits issuance of any license or other waiver for transactions with Iranian persons who were on OFAC’s EO 13224 SDN list on January 20, 2021, unless the President provides a specific certification.
The required presidential certification must declare that the named foreign persons have ceased involvement in terrorism and be sent to four committees: House Foreign Affairs, House Financial Services, Senate Foreign Relations, and Senate Banking.
‘Sanctioned persons’ are limited to Iranian individuals and entities on the OFAC SDN list pursuant to Executive Order 13224 as of Jan 20, 2021 — the bill does not sweep in persons designated after that date.
The statute explicitly preserves any OFAC general licenses that were in effect on January 20, 2021, so those preexisting general authorizations remain valid.
The bill does not define the evidentiary standard, timing, or procedural steps for the President’s certification, leaving those implementation details to the Executive Branch.
Section-by-Section Breakdown
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Short title
Designates the act as the ‘‘No Sanctions Relief for Terrorists Act.’
Prohibition on new licenses or waivers without presidential certification
Establishes the substantive rule: Treasury (and any agency issuing licenses or waivers for covered transactions) may not grant a license or waiver for transactions with the persons described in subsection (b) unless the President certifies they have ceased involvement in terrorism. Practically, this converts the decision to grant targeted relief into a presidentially attested action that must be communicated to Congress before any license or waiver takes effect.
Definition of covered foreign persons
Defines the covered population as Iranian individuals and entities that, as of Jan 20, 2021, were listed on OFAC’s SDN list pursuant to Executive Order 13224 (the EO targeting terrorism-related actors). By pegging the list to a fixed historical snapshot, the bill confines its prohibition to a closed set of designations rather than to all EO 13224 designees over time.
Rule preserving preexisting general licenses
Clarifies that the prohibition cannot be read to alter any OFAC general license that was already in effect on Jan 20, 2021. That is a narrow preservation: it protects broad, preexisting blanket authorizations but does not preserve discretionary, case-by-case licenses or future general licenses issued after that date.
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Explore Foreign Affairs in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Congressional oversight committees — The House Foreign Affairs, House Financial Services, Senate Foreign Relations, and Senate Banking committees gain an explicit statutory checkpoint and a mandatory presidential notification before relief can be granted to the enumerated SDNs, increasing congressional visibility and leverage.
- Victims and plaintiffs in terrorism-related matters — Keeping sanctions relief off the table absent clear presidential certification preserves economic pressure on the listed Iranian actors, which proponents argue helps ensure accountability and preserves assets for potential judicial remedies.
- Sanctions enforcement personnel — OFAC and law enforcement units that prioritize strict enforcement gain a statutory barrier against ad hoc or politically-driven relief, reducing administrative discretion that could otherwise be used to soften restrictions.
Who Bears the Cost
- Executive branch foreign policy and diplomatic teams — The bill removes or complicates a tool (targeted licensing/waivers) that the President and Treasury use to close deals, secure detentions/transfers, or carve out transactional exceptions during negotiations with Iran or third parties.
- U.S. and foreign companies seeking licenses — Businesses that need case-by-case licenses to interact with affected persons face higher uncertainty and likely longer waits because licensing would be stalled absent a presidential certification to Congress.
- Third‑party states and humanitarian actors — Parties that rely on quick, discrete sanctions relief for humanitarian or deconfliction purposes may see those pathways narrowed, increasing the risk that legitimate aid or contingency arrangements are delayed or blocked.
- Treasury/agency operational capacity — Agencies will shoulder the practical burden of implementing the prescriptive prohibition and responding to congressional inquiries tied to certifications, potentially increasing administrative workload without an appropriation in the text.
Key Issues
The Core Tension
The central tension is between ensuring accountability and pressure on actors tied to terrorism (by blocking relief absent clear presidential affirmation) and preserving the Executive Branch’s flexibility to use narrow licensing or waivers as diplomatic, humanitarian, or crisis-management tools; the bill resolves that tension by favoring accountability and congressional visibility, but at the cost of administrative uncertainty and reduced diplomatic tools.
The bill ties sanctions relief for a specified group of Iran-linked SDNs to a presidential certification without defining the facts, procedures, or standard the President must apply. That creates implementation ambiguity: does the President need intelligence corroboration, judicial findings, or merely a policy determination?
The lack of criteria invites politicization of the certification and places Congress in the position of evaluating an executive attestation without statutory guidance on evidentiary sufficiency.
By fixing the covered population to the EO 13224 SDNs as of Jan 20, 2021, the bill draws a bright line that excludes persons designated later and freezes a snapshot of targets. That produces odd incentives: newly designated individuals can, in theory, be handled differently from those on the frozen list, and foreign actors might time designations or negotiations to fall outside the statutory snapshot.
The preservation of general licenses effective Jan 20, 2021, mitigates some operational disruption but creates a patchwork where blanket permissions remain while discretionary relief is barred. Finally, the statute does not address emergency or humanitarian exceptions, nor does it state whether courts may review presidential certifications or agency refusals to issue licenses under this regime — raising separation-of-powers and practical access-to-relief questions.
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