Maximum Pressure Act Aims to Permanently Expand Iran Sanctions, Curb Presidential Waivers, and Reshape U.S. Policy

The Maximum Pressure Act proposes a sweeping overhaul of U.S. policy towards Iran, aiming to codify and significantly expand economic sanctions while severely limiting the President's authority to waive them. This legislation seeks to permanently embed a strategy of intense economic and diplomatic pressure, mandating new sanctions, making existing ones harder to lift, and establishing extensive congressional oversight over any future changes to Iran sanctions policy.

Locking Down the Sanctions Playbook

A core thrust of the Maximum Pressure Act is to make current and future sanctions against Iran more rigid and long-lasting. The bill codifies several existing executive orders related to Iran sanctions, essentially giving them the force of law (Sec. 101, Sec. 5). For instance, Executive Orders like 13846, which reimposed sanctions after the U.S. withdrawal from the JCPOA, and 13871, targeting Iran's metals sector, would become statutory. Critically, the Act seeks to eliminate the "sunset" clauses for sanctions under the Iran Sanctions Act of 1996, making them permanent unless Iran meets an exhaustive list of 12 stringent conditions previously outlined by former Secretary of State Pompeo (Sec. 104). These conditions range from complete nuclear dismantlement and halting ballistic missile development to ending support for groups like Hezbollah and Hamas, and withdrawing forces from Syria.

Furthermore, the bill dramatically curtails the President's ability to ease sanctions. It establishes a mandatory 30-day congressional review period (extendable to 60 days) before the President can take any action to terminate, waive, or significantly alter U.S. foreign policy through licensing actions related to a wide array of Iran sanctions (Sec. 107). If Congress passes a joint resolution of disapproval, the President would be blocked from taking that action. Adding another layer, the Act sets a deadline of February 1, 2028, to terminate the President's authority to issue waivers or licenses for many Iran-related sanctions under various laws, including the International Emergency Economic Powers Act (Sec. 109).

Turning Up the Heat: New Targets and Broader Nets

The Act doesn't just reinforce old sanctions; it mandates a host of new ones and expands the scope of existing measures. Within 30 days of enactment, sanctions would be required against Iran's Supreme Leader, his office, and individuals appointed by him or his office to state positions or as heads of entities, both in and outside Iran. This also extends to their immediate family members and anyone providing them material support (Sec. 102). Similarly, sanctions are mandated for foreign persons involved in international arms sales to or from Iran (Sec. 103).

Economic sectors are also squarely in the crosshairs. The bill amends the Iran Freedom and Counter-Proliferation Act of 2012 to explicitly add "iron, steel, aluminum, copper, construction, manufacturing, mining, textile, petrochemical, automotive, financial" sectors to the list of those subject to sanctions (Sec. 105). It also expands sanctions related to Iran's ballistic missile program, lowering the threshold for what constitutes a contribution to Iran's capabilities (Sec. 113, Sec. 114). For example, anyone operating in sectors identified as supporting Iran's ballistic missile development (with specific mention of chemical, computer science, construction, electronic, metallurgy, mining, research, and telecommunications sectors for initial assessment) could face property blocking and visa denials (Sec. 114). Financial institutions aren't spared; the bill mandates sanctions on those facilitating significant transactions for Iranian human rights abusers, those exporting sensitive technology to Iran (Sec. 115), or those dealing with the Islamic Revolutionary Guard Corps (IRGC) and its affiliates (Sec. 116, Sec. 204, Sec. 205). The definition of what constitutes significant support to Iran's shipping sector is also broadened to include a wide array of maritime service providers (Sec. 108).

Beyond Sanctions: Money, Intel, and Civil Society

The Maximum Pressure Act extends beyond direct sanctions, incorporating measures related to financial flows, intelligence gathering, and support for Iranian civil society. It directs that certain frozen Iranian funds, including those transferred from South Korea to Qatar, be made available to the United States Victims of State Sponsored Terrorism Fund (Sec. 502). The bill also proposes to increase the rewards offered under the "Rewards for Justice" program for information leading to the arrest or conviction of those involved in the October 7, 2023, terrorist attacks against Israel (Sec. 501).

Two new initiatives are proposed: an "Iran Labor Strike and Civil Society Support Fund" to provide financial aid to Iranian workers on strike and support families of political prisoners (Sec. 505), and an "Iran Kleptocracy Initiative" directing the Attorney General to investigate corruption by Iranian government officials and recover illicit assets (Sec. 506). The bill also codifies a prohibition on allocating International Monetary Fund Special Drawing Rights to Iran (Sec. 201) and requires presidential certification to Congress before removing Iran's designation as a jurisdiction of primary money laundering concern (Sec. 202).

Finally, the Act mandates a barrage of reports to Congress. These cover everything from Iran's nuclear breakout timeline (Sec. 409) and ballistic missile program (Sec. 114) to sanctions violations (Sec. 404), the net worth of the Supreme Leader (Sec. 407), Iranian disinformation campaigns (Sec. 410), and the impact of sanctions relief on terrorism (Sec. 405, Sec. 412). This extensive reporting framework aims to keep Congress closely informed and involved in the execution of U.S. policy towards Iran.

The Bottom Line: What This Means in the Real World

If enacted, the Maximum Pressure Act would represent a significant hardening of U.S. policy towards Iran, making it much more difficult for any future administration to pursue diplomacy or sanctions relief without extensive congressional involvement or outright prohibition.

For international businesses and financial institutions, the risks of engaging in any activity remotely connected to Iran would skyrocket. The expanded sectoral sanctions, broader definitions of support, and targeting of entities merely operating in certain Iranian sectors (Sec. 105, Sec. 114) mean that even indirect links could trigger severe penalties. Banks, insurers, shipping companies, and manufacturers across numerous industries—from construction to automotive to tech—would need to exercise extreme due diligence or disengage entirely. For example, a European company selling advanced manufacturing equipment could find itself sanctioned if that equipment is deemed to support Iran's manufacturing sector, now explicitly targeted (Sec. 105).

For the U.S. government, the President's hands would be substantially tied in conducting foreign policy. The ability to quickly offer sanctions relief as a diplomatic tool, or to respond to changing geopolitical circumstances with nuance, would be severely hampered by the congressional review requirements and outright bans on waivers (Sec. 107, Sec. 109). This effectively locks in a confrontational posture.

For ordinary Iranians, while some humanitarian exceptions for food and medicine are mentioned (e.g., Sec. 102, Sec. 114), the comprehensive nature of these sanctions is likely to deepen economic hardship. Restrictions on Iran's core industries and its access to the global financial system can lead to inflation, currency devaluation, and shortages, impacting the daily lives of citizens far beyond the intended targets. The support funds for labor strikes and civil society (Sec. 505) aim to help, but their impact might be overshadowed by broader economic distress.

This legislation signals a long-term commitment to a strategy of intense economic coercion, with significant implications for global commerce, U.S. foreign policy flexibility, and the lives of people both inside and outside Iran.