This bill mandates a report from the Director of National Intelligence on China's circumvention of sanctions related to Iranian oil and ballistic missile trade, followed by a determination from the Treasury Secretary on potential sanctionable activities.
Raja Krishnamoorthi
Representative
IL-8
This Act mandates the Director of National Intelligence to report on oil and ballistic missile-related transactions between China and Iran, detailing circumvention tactics. Following this report, the Secretary of the Treasury must determine if China is engaged in sanctionable activities related to these transactions. The bill aims to track and restrict adversarial circumvention of existing embargoes.
New Act Mandates Intelligence Report on China’s Iranian Oil and Missile Transactions Within 180 Days
The “Tracking and Restricting Adversarial Circumvention of Embargoes Act of 2025” is less about immediately slapping on new sanctions and more about turning up the heat and getting the receipts. This legislation mandates a deep dive by the U.S. intelligence community into how the People’s Republic of China (PRC) is interacting with Iran, specifically focusing on oil and missile components. Within 180 days of the bill becoming law, the Director of National Intelligence (DNI) must deliver a detailed report to Congress and the Treasury Secretary.
The Intelligence Mandate: Getting the Facts Straight
This bill tasks the DNI with two specific intelligence assignments. First, the report must analyze China’s purchases of Iranian oil since 2020. This isn't just about counting barrels; it requires an assessment of how China might be using complex financial maneuvers—think shell companies and transshipment points—to bypass existing U.S. sanctions (SEC. 2). Essentially, the DNI has to figure out the financial shell game being played. The second assessment focuses on significant financial transactions by Chinese entities that relate to selling or supplying materials, like chemical precursors, that could support Iran’s ballistic missile program. This targets the supply chain for Iran’s military technology.
The Treasury’s Next Move: The Sanctionable Determination
The real weight of this bill comes six months after the DNI submits that intelligence report. At that point, the Secretary of the Treasury is required to make a formal determination: are the activities detailed in the report actually “sanctionable activities” under current U.S. law (SEC. 3)? This is a critical step because it forces a decision on whether to use existing sanctions authority against Chinese entities based on the intelligence gathered. While the bill doesn't create new sanctions, it formalizes a process that could lead directly to them. For any Chinese entity involved in these transactions—from major state-owned enterprises to smaller logistics firms—this means the spotlight is about to get much brighter, with the very real risk of being cut off from the U.S. financial system.
Who Needs to See the Homework?
This isn't a report that gets filed away. The bill specifies a wide audience of key congressional committees across both the Senate and the House, including Foreign Relations, Armed Services, and Intelligence committees. This broad distribution ensures that multiple oversight bodies are immediately plugged into the intelligence findings. For policymakers, this bill provides a clear, mandated path to gather the necessary facts before making major foreign policy decisions. For the entities currently skirting sanctions, the message is clear: the U.S. government is dedicating significant intelligence resources to track your movements, and a formal determination on penalties is required soon after.