Enhanced Iran Sanctions Act of 2025

Sanctions changed from mandatory ('shall impose') to discretionary ('may impose'), giving the President the option not to sanction qualifying foreign persons.

The presidential waiver standard was lowered from 'vital to the national interests of the United States' to simply 'in the national interests of the United States,' making it easier for the President to grant waivers.

The waiver renewal process was simplified: the requirement to submit the renewal report at least 15 days before expiration was removed, but a new requirement was added that reoccurring waivers must include steps taken to implement the phase-out plan.

The entire Interagency Working Group on Iranian Sanctions section (former Section 5) was deleted, including provisions for a multilateral contact group with like-minded nations to coordinate enforcement.

The Rewards for Justice Program amendment (moved from Section 6 to Section 3) was expanded to cover persons evading sanctions with proceeds from 'oil, condensates, or other petroleum or petrochemical products' rather than the narrower 'sale of intercepted oil, gas, liquefied natural gas, petrochemical products, or related products.'

The humanitarian assistance exception was narrowed to apply only to transactions 'to or for the people of Iran,' and a new exception was added for authorized intelligence, law enforcement, or national security activities.

A new termination provision (subsection f) ends the sanctions requirement 30 days after the President certifies that Iran no longer supports international terrorism AND has verifiably dismantled its nuclear, biological, chemical weapons and ballistic missile programs.

A new requirement mandates that the President issue regulations or guidance within 60 days after enactment to implement the sanctions provisions.

The list of covered petroleum products was narrowed: 'gas' and 'liquefied natural gas' were removed, leaving only 'oil, condensates, or other petroleum or petrochemical product.' However, 'refining' and 'transfer' were added as covered activities.

The 50 percent ownership or control threshold for imposing sanctions on related entities was removed entirely. In its place, the bill now covers corporate officers, principal executive officers, and persons performing similar functions (broader than just 'corporate officer').

The rules of construction subsection was deleted, which had included a safe harbor protecting persons who relied in good faith on certificates of origin or other documentation confirming petroleum did not originate from Iran, and a provision requiring consistency with OFAC Frequently Asked Questions 398-402.

Visa revocation no longer takes effect 'immediately' or 'automatically cancels' other visas; instead it now takes effect in accordance with section 221(i) of the Immigration and Nationality Act, which provides for a more structured process.