Iran-China Energy Sanctions Act of 2023

The section heading and operative text were changed from targeting only 'Chinese financial institutions' to targeting 'foreign financial institutions,' expanding the pool of potentially sanctioned entities to include any country's banks or financial institutions.

A new category of significant financial transaction was added: any transaction by a foreign financial institution involving the purchase of Iranian unmanned aerial vehicles (UAVs), UAV parts, or related systems. This is in addition to the existing petroleum/petroleum products provision.

The definition of 'significant financial transaction' now explicitly states it applies 'without regard to the size, number, frequency, or nature of the transaction,' removing any potential argument that small or infrequent transactions fall below a threshold.

The annual presidential determination requirement was expanded to cover both Chinese financial institutions (for petroleum purchases) and any foreign financial institution (for UAV purchases), with findings reported to Congress every year for 5 years.