The Maximum Pressure Act codifies multiple prior executive orders and hardens U.S. sanctions policy toward Iran by expanding the universe of sanctionable conduct, tightening controls on cross-border payments and shipping services, imposing mandatory blocking and visa bans for new categories of Iranian officials and affiliates, and dramatically expanding reporting and congressional review requirements. It also narrows executive discretion to issue waivers or licenses and establishes new statutory conditions that must be certified before sanctions relief may occur.
For compliance officers, banks, insurers, exporters, maritime service providers, defense suppliers, and foreign financial institutions, the bill raises near-term compliance risk: it extends certain blocking authorities, creates new mandatory blocking lists and sectoral restrictions (iron, steel, petrochemicals, mining, automotive, financial services, and others), codifies prohibitions on USD-linked transfers to Iran, and requires repeated public and classified reports that will increase scrutiny and enforcement opportunities. The law also creates new mechanisms for repurposing frozen Iranian assets and a range of enforcement and investigatory initiatives aimed at Iranian kleptocracy and IRGC-linked economic activity.
At a Glance
What It Does
The bill codifies several presidential orders and converts many executive sanctions practices into statute, mandates blocking of property and visa bans for specified Iranian actors (including the Supreme Leader and affiliates), and expands sectoral and ballistic-missile-related sanctions. It also codifies prohibitions on certain fund transfers, tightens maritime and shipping guidance, and reduces the President’s waiver and licensing flexibility until specific certifications are met.
Who It Affects
U.S. and foreign banks and payment platforms that route transactions in U.S. dollars, maritime service providers (port authorities, insurers, classification societies, charterers, managers), exporters in newly-covered sectors (iron, steel, petrochemical, automotive, mining), OFAC/State/Treasury licensing shops, and foreign governments and firms that facilitate Iranian arms, missile, or drone imports.
Why It Matters
The bill replaces discretionary executive posture with statutory rules and congressional checkpoints, increasing legal and compliance exposure for global firms and elevating Congress’ role in any future sanctions relief. That shift raises the cost of doing business with Iran across multiple industries and makes targeted sanctions relief harder to achieve short of a verifiable change in Iranian behavior.
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What This Bill Actually Does
The Maximum Pressure Act converts a dense set of policy preferences and presidential directives into statutory obligations. It directs that listed executive orders remain in force until Congress receives a certification under the Iran Sanctions Act; prevents removal of certain persons from the SDN list unless that same ISA certification is made; and requires the President to reimpose specified sanctions that were lifted previously.
That makes return to the pre-2025 status quo legally conditional rather than discretionary.
On tools and targets, the bill imposes broad blocking and immigration penalties: it requires blocking of property and denies U.S. visas to the Supreme Leader and persons in his office and a catalog of their appointees, affiliates, and facilitators. It expands sectoral sanctions under existing statutes to list new industries (iron, steel, aluminum, copper, manufacturing, mining, textile, petrochemical, automotive, financial, etc.) and instructs Treasury to treat a wide range of maritime services (port authorities, marine insurers, classification societies, charterers, operators, management firms, and other providers) as potential “significant support.” Several provisions add mandatory sanctioning triggers — for example, foreign persons that materially assist Iran’s missile or arms programs or that provide significant financial services to IRGC entities.The bill tightens financial controls: it codifies 31 C.F.R. 560.516 (the pre‑2021 blocking of Iranian accounts) and extends its reach to foreign financial institutions when transactions are conducted in U.S. legal tender; it requires U.S. banks to avoid correspondent or payable‑through relationships with banks that violate those prohibitions; it bars IMF Special Drawing Rights allocations to Iran; and it requires Treasury to compel domestic banks to adopt elevated special measures if certain Iran‑linked instruments (e.g., Instrument in Support of Trade Exchanges) are used.
Critically, the President’s ability to issue waivers or licenses is limited: many waiver authorities terminate on February 1, 2028, and other waiver authorities are explicitly curtailed unless Congress receives an ISA-style certification.Accountability and intelligence layers are expanded. The bill demands frequent, often public reporting (some with classified annexes) on missile proliferation, IRGC and proxy economic penetration, sanctions compliance and violations, Iran’s breakout timeline for enrichment and weaponization, and Iranian disinformation and counterintelligence efforts.
It also creates watchlists (IRGC and militia watchlists), requires Treasury to publish an ‘‘IRGC Watch List’’ of entities with IRGC influence, and instructs GAO (Comptroller General) to audit those lists. Finally, the bill authorizes repurposing or directing of certain frozen Iranian funds to U.S. victims of state‑sponsored terrorism and establishes new initiatives — an Iran Strike Fund, an Iran Labor‑Strike and Civil Society Support Fund, and a DOJ “Iran Kleptocracy Initiative” to target corrupt regime assets.
The Five Things You Need to Know
Section 101 codifies Executive Orders 13606, 13628, 13846, 13871, 13876, 13902, and 13949 and bars removal from the SDN list of persons designated between May 8, 2019 and Jan 20, 2021 unless the President submits ISA-style certification to Congress.
Section 102 requires the President to impose blocking sanctions and visa bans on Iran’s Supreme Leader, his office, appointees, affiliates and facilitators within 30 days, with narrow humanitarian and U.N. Headquarters exceptions.
Section 104 amends the Iran Sanctions Act to add 12 specific, non‑negotiable certification conditions (the Pompeo ‘demands’) and repeals the Act’s prior sunset, so sanctions remain unless those conditions are certified satisfied.
Section 110 codifies 31 C.F.R. 560.516 (pre‑2021 Iran account prohibitions), extends USD‑based restrictions to foreign banks, and requires U.S. banks to sever or limit correspondent/payable‑through relationships with violators unless the President issues a 180‑day suspension tied to ISA certification.
Section 109 sunsets the President’s broad waiver/license authorities for many Iran sanctions on Feb 1, 2028, while Section 107 creates a new statutory congressional review process (30–60 day clock plus joint‑resolution mechanics) before major sanctions relief or licensing actions.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Codify executive orders; freeze SDN removals
This section directs that seven named executive orders remain in force until the President makes an ISA-style certification to Congress. It also bars removal from the OFAC SDN list of Iranian‑linked persons designated in the May 2019–Jan 2021 window unless that same certification is made, and requires reimposition of certain sanctions that had been lifted. Practically, compliance shops should treat those prior designations and measures as persistent statutory commitments rather than ephemeral executive choices.
Supreme Leader and affiliates: mandatory blocking and visa bans
Mandates blocking of property and comprehensive visa ineligibility for the Supreme Leader, Office of the Supreme Leader officials, appointees, and persons who materially assist or act on their behalf. It instructs use of IEEPA blocking authority and creates immediate criminal and civil exposure for violators; humanitarian exceptions and the U.N. Headquarters Agreement are preserved. For practitioners this creates a clear (and broad) category of forbidden counterparties and an elevated OFAC enforcement perimeter.
Toughened termination conditions and no sunset
Amends the Iran Sanctions Act and the Comprehensive Iran Sanctions Act to add a set of substantive, non‑waivable conditions (the 12 Pompeo demands) that Iran must meet before the U.S. may terminate certain sanctions. It also repeals the statutory sunset that previously limited some UN‑related measures. The change converts political/diplomatic yardsticks into legal certification criteria, raising the evidentiary bar for any sanctions relief.
Maritime and shipping: expanded definition of 'significant support'
Directs Treasury to revise OFAC guidance to treat a wide list of maritime service providers — port authorities, importing agents, management firms, charterers, operators, marine insurers, and classification societies — as potential providers of ‘significant support’ to Iran’s shipping sector. That expands secondary sanctions focus from shipowners to the broader ecosystem that enables maritime trade and logistics, and will force maritime insurers and service firms to reassess Iran exposure.
Transfers of funds and USD‑linked prohibitions
Codifies pre‑2021 regulations barring debiting or crediting Iranian accounts (31 C.F.R. 560.516) and makes those rules applicable to foreign financial institutions when transactions use U.S. legal tender. It also directs U.S. financial institutions to avoid correspondent relationships with violators. The President can suspend this restriction in 180‑day increments but only if the ISA certification is provided — a high threshold that tightens the dollar’s gatekeeping role.
Ballistic missile and sectoral expansion
Expands Iran‑related arms and missile sanction triggers, broadens the Iran Sanctions Act to include persons that ‘acquire or develop’ ballistic missiles, and extends sectoral sanctions to new industries (iron, steel, aluminum, petrochemical, automotive, mining, manufacturing, textiles, financial). It requires new watchlists and regular reports on persons and sectors linked to missile proliferation. Companies operating in these sectors should expect greater targeting and mandatory sanctions where ‘significant’ assistance is found.
Congressional review process for sanction relief and licensing
Creates a pre‑clearance and review regime: before major licensing actions, waivers, or termination of sanctions, the President must submit a report to Congress and wait through a 30‑day (up to 60‑day summer) clock during which committees review and can drive a joint resolution to disapprove. The statutory text prescribes detailed floor procedures and short debate windows — a structural change that inserts Congress into executive decisions on Iran sanctions relief.
Victims’ rewards, frozen asset repurposing, and anti‑kleptocracy measures
Raises Rewards for Justice amounts for perpetrators linked to October 7 attacks, directs transfer or use of certain unfrozen Iranian funds for victims of state‑sponsored terrorism, creates an Iran Strike Fund and an Iran Labor Strike & Civil Society Support Fund, and mandates a DOJ 'Iran Kleptocracy Initiative' to focus asset identification and prosecutions. These are explicit resource and enforcement priorities that pair sanction pressure with victim compensation and anti‑corruption investigations.
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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
- Victims of terrorism and U.S. plaintiffs: The bill authorizes repurposing certain frozen Iranian funds and raises Rewards for Justice payouts, expanding avenues for collection and compensation for victims of Iranian‑backed terrorism.
- U.S. enforcement agencies and investigators: Expanded mandatory lists, reporting duties, and the Iran Kleptocracy Initiative give DOJ, Treasury and State stronger legal mandates, more data, and new asset‑seizure and prosecution authorities.
- Iranian civil society and dissidents: Creation of an Iran Labor‑Strike and Civil Society Support Fund and prioritized sanctions on regime economic actors aim to weaken patronage networks and provide targeted assistance to activists and affected families.
- Allied intelligence and policy shops: Statutorily required reporting (ballistic timelines, IRGC/ proxy economic penetrations, disinformation) centralizes analysis and gives partners a clearer U.S. assessment basis for coordinated action.
Who Bears the Cost
- U.S. and foreign banks (correspondent/payment providers): The codification of USD‑based prohibitions and the duty to avoid correspondent relationships with violators increases compliance costs, cuts access to dollar clearing, and raises de‑risking pressure on correspondent banking relationships.
- Maritime and maritime support firms (insurers, classification societies, port operators): The bill brings many previously peripheral maritime actors into the sanctions perimeter, increasing due diligence burdens and potential exclusion from U.S. trade lanes.
- Exporters and manufacturers in newly covered sectors (iron/steel, petrochemicals, automotive, mining): New sectoral sanctions increase the risk of secondary sanctions for supply‑chain participants and may constrain sales and financing.
- Foreign governments and firms trading with Iran: Countries or companies that rely on Iranian imports or provide arms/dual‑use components face elevated secondary sanction risk and strained relations with U.S. enforcement authorities.
- Humanitarian NGOs and medical suppliers: Although the text contains humanitarian exceptions, the expanded reporting and blocking regime raises operational friction and raises the cost of ensuring exemptions are properly structured and licensed.
Key Issues
The Core Tension
The central tension is between using immutable statutory pressure to deny Iran resources and symbols of international normalization, and preserving the executive branch’s ability to negotiate, grant targeted relief, or use diplomatic tools when de‑escalation or verification becomes politically sensible; the bill favors permanence and congressional control over executive flexibility, raising the question whether maximum pressure is worth the diplomatic inflexibility and economic collateral consequences it creates.
The bill solves for leverage by turning executive maximum‑pressure policy into statute, but that solution creates implementation frictions. Requiring ISA‑style certifications tied to a long list of political and military conditions (the 12 demands) places a heavy evidentiary and political burden on the executive branch — proving irreversible, verifiable dismantlement of complex programs (enrichment, missiles, proxy networks) is technically and politically fraught, and Congress’ new review mechanics make timely bilateral diplomacy and conditional, reversible relief politically costly.
Operationally, the expansion of sanctionable categories to include maritime service providers, classification societies, insurers, and a long list of industrial sectors raises the prospect of over‑breadth and unintended collateral damage. Banks and insurers will face acute de‑risking incentives; smaller firms with thin compliance resources may withdraw from legitimate humanitarian or non‑sanctionable commerce out of fear of secondary exposure.
The statute attempts to preserve humanitarian exemptions, but practical use of those exemptions typically requires licences and guidance; the bill’s reporting and public‑listing regime increases reputational risk even where transactions are lawful. Finally, converting flexible executive policy (waivers, diplomatic engagement) into statutory gates reduces diplomatic maneuverability — useful for pressure, but costly where quiet diplomacy or rapid crisis response is needed.
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