Maximum Pressure Act
- Sponsor
- Rep. Nunn, Zachary [R-IA-3]
- Committees
- Intelligence (Permanent Select) Committee (primary)
- Last action
- Apr 1, 2025
Bottom line
The Maximum Pressure Act codifies and intensifies a comprehensive 'maximum pressure' strategy against Iran, making sanctions relief contingent on Iran meeting 12 specific demands and significantly restricting presidential waiver authority.
What it actually does
This bill significantly expands and codifies U.S. sanctions against Iran, its leadership, and affiliated entities, aiming to deny Iran all paths to nuclear weapons, curtail its ballistic missile program, and counter its support for terrorist proxies. It codifies several Trump-era executive orders, imposes new mandatory sanctions on the Supreme Leader and those involved in arms sales, and expands existing sanctions to cover more sectors and activities. The bill also sets strict, comprehensive conditions for any future sanctions relief, effectively codifying the 12 demands laid out by former Secretary of State Pompeo.
Proponents argue
Proponents argue that the bill is essential to counter Iran's destabilizing activities, nuclear ambitions, and support for terrorism, especially in light of the October 7, 2023, attacks. They contend that previous administrations' diplomatic approaches, particularly the Joint Comprehensive Plan of Action (JCPOA), failed to curb Iran's malign behavior and that only sustained, maximum economic pressure will force the regime to change its policies. Supporters highlight the effectiveness of the Trump administration's 'maximum pressure' campaign in reducing Iran's revenue and capacity to fund proxies.
Opponents contend
Critics might argue that such a broad and stringent sanctions regime could further isolate Iran, making diplomatic engagement more difficult and potentially leading to escalation rather than de-escalation. They may contend that it could harm the Iranian populace, potentially fueling anti-American sentiment, and that removing presidential waiver authority limits the executive branch's flexibility in foreign policy and crisis management. Some might also argue that it could push Iran to accelerate its nuclear program if it feels it has nothing to lose from international agreements.
The bill is lengthy and complex, requiring significant time for a thorough review, which may exceed the time typically allotted for public or congressional scrutiny of such a comprehensive measure.
Sec. 101
Codification of Executive Orders and Continuation of Certain Existing Sanctions
This section codifies several Executive Orders (13606, 13628, 13846, 13871, 13876, 13902, and 13949) related to Iran sanctions, ensuring they remain in effect until Iran meets specific certification requirements under the Iran Sanctions Act of 1996. It also prohibits the removal of certain Iranian individuals and entities from the Specially Designated Nationals (SDN) list and reimposes any sanctions lifted between May 8, 2019, and January 20, 2021, until Iran meets the certification requirements.
Supporters argue
Supporters argue that codifying these executive orders ensures a consistent and robust 'maximum pressure' policy, preventing future administrations from easily reversing sanctions and thereby strengthening the U.S. stance against Iran's malign activities.
Critics contend
Critics might contend that codifying executive orders limits the flexibility of future administrations to adapt foreign policy to changing geopolitical circumstances or to pursue diplomatic solutions that might require sanctions relief.
Tradeoffs
This provision balances the desire for policy consistency and strong deterrence against Iran with the executive branch's need for flexibility in foreign policy and diplomatic engagement.
Sec. 102
Sanctions with Respect to the Supreme Leader of Iran
This section mandates sanctions against the Supreme Leader of Iran, officials in his office, and any person appointed by them to state or entity head positions. It also targets those who materially assist, sponsor, or provide support to these individuals or entities, as well as their immediate family members. Sanctions include blocking property and denying visas or admission to the U.S.
Sec. 104
Additional Conditions for Termination and Elimination of Sunset of Sanctions under the Iran Sanctions Act of 1996
This section significantly amends the Iran Sanctions Act of 1996 by adding 12 specific conditions that Iran must meet for sanctions to be terminated, effectively codifying the demands laid out by former Secretary of State Pompeo. These conditions cover nuclear, ballistic missile, terrorism, regional destabilization, hostage-taking, and human rights issues. It also repeals the sunset provision of the Iran Sanctions Act, making the sanctions permanent until these conditions are met.
Sec. 105
Sectoral Sanctions on Iran under the Iran Freedom and Counter-Proliferation Act of 2012
This section expands the scope of sectoral sanctions under the Iran Freedom and Counter-Proliferation Act of 2012 to include iron, steel, aluminum, copper, construction, manufacturing, mining, textile, petrochemical, automotive, and financial sectors, in addition to energy. It also terminates all existing waivers for sanctions under this Act and prohibits the President from issuing new waivers until February 1, 2028.
Sec. 107
Congressional Review of Certain Actions Relating to Sanctions Imposed with Respect to Iran
This section establishes a congressional review process for any presidential action to terminate, waive, or significantly alter sanctions against Iran. The President must submit a report to Congress describing the proposed action and certifying that the sanctioned person has not engaged in sanctionable activity for 10 years. Congress then has a review period (30 or 60 days) during which the President cannot take the action without a joint resolution of approval or if a joint resolution of disapproval is enacted.
Sec. 109
Sunset of Waiver and License Authorities
This section mandates that the President's authority to issue waivers or licenses for sanctions related to Iran, under various specified legislation and executive orders, will cease to apply beginning on February 1, 2028. Any existing waivers or licenses issued under these authorities will also terminate on that date.
Sec. 110
Codification and Application on Transfers of Funds Involving Iran
This section codifies a specific regulation (31 CFR 560.516) that prohibits debiting or crediting Iranian accounts, making it applicable to foreign financial institutions if transactions are conducted in U.S. legal tender. It also prohibits U.S. financial institutions from engaging in significant transactions with foreign financial institutions that violate these prohibitions. The President is generally prohibited from issuing licenses for such transactions, with a limited suspension authority after Iran meets ISA 1996 certification.
Sec. 114
Imposition of Sanctions with Respect to Ballistic Missile Program of Iran
This section adds a new subtitle to the Iran Threat Reduction and Syria Human Rights Act of 2012, mandating sanctions on persons who provide material support to Iran's ballistic missile or drone programs. It requires the President to identify such persons every 180 days, block their property, deny them U.S. entry, and prohibit correspondent accounts for foreign financial institutions that facilitate significant transactions for them. It also mandates sanctions on persons affiliated with key Iranian missile entities and requires a 'Iran Missile Proliferation Watch List'.
Sec. 201
Prohibitions of International Monetary Fund Allocations for Iran
This section amends the Special Drawing Rights Act to prohibit the appropriation of funds for allocating Special Drawing Rights (SDRs) from the International Monetary Fund (IMF) to the Islamic Republic of Iran.
Sec. 204
Additional Sanctions with Respect to Foreign Persons that are Officials, Agents, or Affiliates of, or Owned or Controlled by, Iran's Revolutionary Guard Corps
This section expands the scope of sanctions under the Iran Threat Reduction and Syria Human Rights Act of 2012 by requiring the President to identify, every 180 days, foreign persons who are officials, agents, affiliates of, or owned or controlled by Iran's Revolutionary Guard Corps (IRGC). It also mandates identification of foreign persons attempting to conduct sensitive transactions for these IRGC-linked entities, and lowers the threshold for 'sensitive transactions' to $500,000. It makes sanctions for these activities mandatory.
Sec. 301 & Sec. 302
Prohibition on Future Waivers and Licenses Connected to the Designation of the IRGC (as FTO)
These sections prohibit the President from issuing new waivers or licenses related to the designation of the Islamic Revolutionary Guard Corps (IRGC) under Executive Order 13224 (terrorism sanctions) and as a Foreign Terrorist Organization (FTO) under the Immigration and Nationality Act. Existing waivers and licenses remain in effect but no new ones can be issued until Iran meets the comprehensive certification requirements of the amended Iran Sanctions Act of 1996.
Sec. 303
Codification of Executive Order 14175 Relating to Ansar Allah in Yemen
This section codifies Executive Order 14175, signed on January 22, 2025, which designated Ansar Allah (the Houthis) in Yemen as a Foreign Terrorist Organization (FTO). This gives the executive order the force and effect of enacted law, making the designation permanent unless explicitly changed by Congress.
Sec. 406
Supporting Human Rights for the People of Iran and the Victims of Iranian Human Rights Abuses in Syria, Lebanon, Yemen, and Venezuela
This section declares U.S. policy to support democracy and human rights in Iran and hold Iran accountable for abuses against its own people and those in Iraq, Syria, Lebanon, Yemen, and Venezuela. It mandates a determination within 180 days on whether specific Iranian officials, including the Supreme Leader and various prison and IRGC commanders, meet the criteria for sanctions under existing human rights authorities. It also codifies Executive Orders 13876, 13553, and 13818 related to human rights sanctions.
Sec. 502
Repurposing Frozen Iranian Funds for United States Victims of State Sponsored Terrorism Fund
This section mandates that, within 90 days, the President must make available to the United States Victims of State Sponsored Terrorism Fund specific funds. This includes funds transferred from the Republic of Korea to Qatar (nearly $10 billion) that were subject to a waiver in September 2023, and any other frozen Iranian funds deemed appropriate. This aims to provide compensation to victims of Iranian-sponsored terrorism, including those from the October 7, 2023, attack in Israel.
Sec. 505
Creation of Iran Labor Strike and Civil Society Support Fund
This section establishes the 'Iran Labor Strike and Civil Society Support Fund' to provide financial assistance to Iranian workers engaging in labor strikes and support for families of political prisoners and individuals who have lost income earners due to political repression. The fund will be financed through penalties and fines from Iran-related sanctions violations, asset forfeitures from Iranian regime officials, and congressional appropriations. The Secretary of State, in coordination with the Secretary of the Treasury, will administer the fund.
Sec. 506
Iran Kleptocracy Initiative
This section mandates the Attorney General to establish an 'Iran Kleptocracy Initiative' to investigate, expose, and counteract corruption among Iranian government officials. The initiative's responsibilities include identifying assets held by officials and their proxies, working with Treasury and allied governments to freeze, seize, and repurpose illicitly acquired assets, publishing findings, coordinating with law enforcement for prosecutions and asset recoveries, and submitting annual reports to Congress.
Amends Section 8 of the Iran Sanctions Act of 1996 to add 12 specific conditions, including nuclear, ballistic missile, terrorism, and human rights requirements, that Iran must meet for sanctions to be terminated. This effectively codifies the '12 Demands' previously articulated by former Secretary of State Mike Pompeo.
Sec. 104(a)
Why it matters:This is a standard legislative practice for modifying existing statutes, but the comprehensive nature of the added conditions represents a major policy directive that might be overlooked by a casual reader focusing only on new, standalone sections.
Case for: Supporters argue that these conditions provide a clear, comprehensive, and legally binding framework for what constitutes acceptable behavior from Iran, ensuring that any sanctions relief is tied to fundamental changes across all areas of concern.
Case against: Critics might argue that embedding such a high and broad bar for sanctions termination into law makes diplomatic engagement and incremental progress virtually impossible, locking the U.S. into a maximalist position.
Estimated impact: Transforms the conditions for U.S. sanctions relief on Iran from a discretionary executive decision to a statutory requirement, significantly altering the U.S. negotiating posture.
Establishes a sunset date of February 1, 2028, for the President's authority to issue waivers or licenses for a wide range of Iran-related sanctions, including those authorized by this Act and other specified legislation and executive orders. All existing waivers and licenses under these authorities will also terminate on this date.
Sec. 109
Why it matters:This is a deliberate legislative choice to limit executive power, ensuring that after a certain date, the 'maximum pressure' approach becomes the default unless Congress acts to restore waiver authority or Iran meets the comprehensive conditions for sanctions termination.
Case for: Proponents argue that this forces a definitive policy stance, preventing future administrations from gradually eroding sanctions through waivers and ensuring that Iran faces sustained pressure until fundamental behavioral changes occur.
Case against: Critics contend that this provision severely restricts the executive branch's ability to conduct foreign policy, removing a crucial tool for de-escalation, humanitarian relief, or strategic negotiations, and could lead to unforeseen diplomatic challenges after 2028.
Estimated impact: Significantly curtails presidential foreign policy tools regarding Iran after February 2028, potentially leading to a more rigid and confrontational stance.
Expands the application of regulations prohibiting the debiting or crediting of Iranian accounts (31 CFR 560.516) to foreign financial institutions when transactions are conducted in U.S. legal tender. It also prohibits U.S. financial institutions from engaging in significant transactions with foreign financial institutions that violate these rules.
Sec. 110(a)(2)
Why it matters:This is a technical legislative change that has a broad, substantive effect on international financial transactions involving Iran, designed to tighten the financial noose in a legally precise manner.
Case for: Supporters argue this closes a critical loophole, preventing foreign financial institutions from facilitating U.S. dollar transactions for Iran, thereby significantly increasing the effectiveness of financial sanctions and isolating Iran from the global financial system.
Case against: Critics might contend that this broad application of U.S. law to foreign financial institutions could lead to extraterritoriality concerns, create significant compliance burdens, and potentially push more Iranian transactions into less transparent channels outside the U.S. dollar system.
Estimated impact: Further restricts Iran's access to the global financial system, particularly U.S. dollar transactions, and imposes secondary sanctions risk on a wider array of foreign financial institutions.
Amends sections of the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA) to change the President's authority from 'may impose' to 'shall block and prohibit' certain sanctions. This makes the imposition of sanctions mandatory rather than discretionary for foreign persons supporting Iran's Revolutionary Guard Corps (IRGC) or other sanctioned persons/terrorist organizations.
Sec. 116(b), Sec. 204(b), Sec. 205(b)
Why it matters:This is a common legislative technique to remove executive discretion, but its placement within amendments to existing acts means a casual reader might miss the shift in the binding nature of the sanctions.
Case for: Proponents argue that making these sanctions mandatory ensures consistent and unwavering pressure on the IRGC and its supporters, preventing any future administration from selectively waiving or failing to enforce sanctions due to political considerations.
Case against: Critics might contend that removing executive discretion limits the President's ability to use sanctions as a flexible tool in diplomacy, potentially hindering negotiations or de-escalation efforts where some flexibility might be beneficial.
Estimated impact: Significantly strengthens the enforcement of sanctions against IRGC-linked entities and their supporters by removing executive discretion, leading to broader and more consistent application of penalties.