PolicyBrief
S. 3390
119th CongressDec 9th 2025
Tracking and Restricting Adversarial Circumvention of Embargoes Act of 2025
IN COMMITTEE

This bill mandates a report from the Director of National Intelligence on China-Iran oil and missile-related transactions, followed by a Treasury determination on sanctionable activities.

Richard Blumenthal
D

Richard Blumenthal

Senator

CT

LEGISLATION

New Bill Mandates Intelligence Report on China-Iran Sanctions Evasion Within 180 Days

If you’ve ever wondered how global politics and sanctions enforcement actually work behind the scenes, this bill pulls back the curtain on the intelligence and Treasury work that goes into it. The Tracking and Restricting Adversarial Circumvention of Embargoes Act of 2025 is all about getting the facts on the table regarding transactions between China and Iran that might be undermining U.S. sanctions.

The Intelligence Deep Dive: Following the Oil and Missiles

This bill starts with a mandate for the Director of National Intelligence (DNI). The DNI has 180 days from the bill’s enactment to deliver a detailed report to the Treasury Secretary and a long list of Congressional committees (SEC. 2). This isn't just a general overview; the report must specifically analyze transactions between China and Iran since 2020, focusing on two critical areas.

First, the DNI needs to assess China’s purchases of Iranian oil and, crucially, evaluate how China uses transshipment points (think of this as transferring goods between ships or ports to hide the origin) and shell companies (companies that exist only on paper) to avoid sanctions. This provision is designed to expose the specific supply chain tricks used to get sanctioned oil onto the global market. Second, the report must analyze significant financial transactions by Chinese entities related to providing Iran with chemical precursors and other materials that support its ballistic missile program. Essentially, the intelligence community is being told to track the money and materials fueling Iran’s oil sales and its missile development efforts.

The Treasury’s Next Move: Determining Sanctionable Activity

Once the DNI hands over this intelligence dossier, the ball moves to the Treasury Department. Within 180 days of receiving the DNI’s report, the Secretary of the Treasury must make a formal determination: Is China engaging in sanctionable activities? (SEC. 3). This is the key moment where intelligence turns into potential policy action. While the bill itself doesn't impose sanctions, it sets up a strict timeline for the executive branch to decide if the intelligence gathered warrants imposing new financial penalties.

Real-World Stakes: Who Feels This?

This bill might seem like high-level foreign policy, but it has concrete implications for specific players. For regular folks in the US, the impact is indirect—it’s about strengthening the enforcement of existing sanctions. The groups that will feel the pressure are the Chinese entities currently involved in these transactions. If the Treasury Secretary determines they are engaging in sanctionable activities, those companies could face severe restrictions on accessing the U.S. financial system, which is a major deterrent for any global business.

In essence, this legislation is a procedural wrench thrown into the gears of illegal trade. It forces a timeline for intelligence gathering and a formal decision process, ensuring that the question of whether China is actively helping Iran circumvent sanctions gets a definitive answer and potential action. It’s a good example of how Congress uses reporting requirements to compel the executive branch to address specific national security concerns.