II 

118TH CONGRESS 

1ST SESSION S. 3235 

To require a strategy to counter the role of the People’s Republic of China 

in evasion of sanctions imposed by the United States with respect to 

Iran, and for other purposes. 

IN THE SENATE OF THE UNITED STATES 

NOVEMBER 7, 2023 

Mr. RISCH (for himself and Mr. RUBIO) introduced the following bill; which 

was read twice and referred to the Committee on Foreign Relations 

A BILL 

To require a strategy to counter the role of the People’s 

Republic of China in evasion of sanctions imposed by 

the United States with respect to Iran, and for other 

purposes. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘End Iranian Terrorism 

5 Act of 2023’’. 

6 SEC. 2. SENSE OF CONGRESS. 

7 It is the sense of Congress that— 


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1 (1) the Islamic Republic of Iran has long pro2 vided hundreds of millions of dollars in material sup3 port to Hamas and other terrorist groups, such as 

4 Palestinian Islamic Jihad, that directly threaten 

5 Israel; 

6 (2) Iran poses a threat to regional and global 

7 security and has earned approximately 

8 $80,000,000,000 in oil revenues since 2021; 

9 (3) the People’s Republic of China, seeking to 

10 secure reliable sources of Middle Eastern energy, 

11 has purchased roughly $47,000,000,000 in Iranian 

12 petroleum products since 2021 and is undercutting 

13 the enforcement of sanctions imposed by the United 

14 States with respect to Iran; 

15 (4) illicit purchases of Iranian petroleum prod16 ucts by the People’s Republic of China and other 

17 countries fund the Iranian regime’s suppression of 

18 human rights in Iran, provide valuable resources for 

19 Iran’s terrorist proxies, and provide additional re20 sources for support by Iran for the Russian Federa21 tion in its unprovoked war in Ukraine, contrary to 

22 United States policy; 

23 (5) lack of sanctions and sanctions enforcement 

24 directly undercuts United States policy objectives in 


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1 the Indo-Pacific region, Europe, the Middle East, 

2 and beyond; 

3 (6) increasing encroachment by the People’s 

4 Republic of China in the Middle East and North Af5 rica, include involvement of the People’s Republic of 

6 China in illicit oil trade, runs counter to the national 

7 security interests of the United States; and 

8 (7) the United States should immediately en9 force existing sanctions, including sanctions provided 

10 for in Executive Order 13846 (50 U.S.C. 1701 note; 

11 relating to reimposing certain sanctions with respect 

12 to Iran), and expand sanctions designations to in13 clude persons that store Iranian oil, ship-to-ship oil 

14 transfer operators, ports and port operators, refin15 eries and refinery operators, and other individuals 

16 and entities, particularly in the People’s Republic of 

17 China, dealing in Iranian-origin oil and petrochemi18 cals. 

19 SEC. 3. APPROPRIATE CONGRESSIONAL COMMITTEES DE20 FINED. 

21 In this Act, the term ‘‘appropriate congressional com22 mittees’’ means— 

23 (1) the Committee on Foreign Relations and 

24 the Committee on Banking, Housing, and Urban Af25 fairs of the Senate; and 


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1 (2) the Committee on Foreign Affairs and the 

2 Committee on Financial Services of the House of 

3 Representatives. 

4 SEC. 4. STRATEGY TO COUNTER ROLE OF THE PEOPLE’S 

5 REPUBLIC OF CHINA IN EVASION OF SANC6 TIONS WITH RESPECT TO IRAN. 

7 (a) IN GENERAL.—Not later than 120 days after the 

8 date of the enactment of this Act, the Secretary of State, 

9 in consultation with the heads of other appropriate Fed10 eral agencies, shall submit to the appropriate congres11 sional committees a written strategy, and provide to those 

12 committees an accompanying briefing, on the role of the 

13 People’s Republic of China in evasion of sanctions imposed 

14 by the United States with respect to Iranian-origin petro15 leum products that includes an assessment of options— 

16 (1) to strengthen the enforcement of such sanc17 tions; and 

18 (2) to expand sanctions designations targeting 

19 the involvement of the People’s Republic of China in 

20 the production, transportation, storage, refining, and 

21 sale of Iranian-origin petroleum products. 

22 (b) ELEMENTS.—The strategy required by subsection 

23 (a) shall include— 

24 (1) a description of the use of sanctions in ef25 fect before the date of the enactment of this Act to 


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1 target individuals and entities of the People’s Re2 public of China that are directly or indirectly associ3 ated with smuggling of Iranian-origin petroleum 

4 products; 

5 (2) an assessment of— 

6 (A) the People’s Republic of China’s petro7 leum refining capabilities; 

8 (B) which of the People’s Republic of Chi9 na’s refineries are at high risk of processing 

10 Iranian-origin petroleum products and why; 

11 (C) Iranian-owned entities operating in the 

12 People’s Republic of China and involved in pe13 troleum refining supply chains; 

14 (D) the People’s Republic of China’s role 

15 in global petroleum refining supply chains; 

16 (E) how the People’s Republic of China 

17 leverages its role in global petroleum supply 

18 chains to achieve political objectives; 

19 (F) the People’s Republic of China’s petro20 leum importing and exporting partners; 

21 (G) what percent of the People’s Republic 

22 of China’s energy consumption is linked to ille23 gally imported Iranian-origin petroleum prod24 ucts; 


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1 (H) the amount of money the People’s Re2 public of China saves by illegally importing dis3 counted Iranian-origin petroleum products rath4 er than paying market price; 

5 (I) what level of influence the Chinese 

6 Communist Party holds over non-state, semi7 independent ‘‘teapot’’ refineries; and 

8 (J) the challenges limiting the ability of 

9 the United States to impose or enforce sanc10 tions with respect to such refineries, includ11 ing— 

12 (i) Lawen Namu Petroleum Trading 

13 Company; 

14 (ii) Qihang Energy; and 

15 (iii) Shangang Guomao; 

16 (3) a detailed plan for— 

17 (A) monitoring the maritime domain for 

18 smuggling of Iranian-origin petroleum products 

19 in violation of sanctions imposed by the United 

20 States, including through— 

21 (i) automatic identification system 

22 monitoring; 

23 (ii) satellite imagery; 

24 (iii) vessel comparison and tanker 

25 classification; 


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1 (iv) receiving tips from operators; and 

2 (v) creating a database of reported 

3 potential sanctions violations; 

4 (B) identifying the individuals, entities, 

5 and vessels responsible for such smuggling, in6 cluding— 

7 (i) vessels— 

8 (I) operated by the National Ira9 nian Tanker Company or any other 

10 Chinese or Iranian entity subject to 

11 sanctions imposed by the United 

12 States; 

13 (II) transporting petrochemicals 

14 subject to sanctions; 

15 (III) conducting ship-to-ship 

16 transfers of such petrochemicals; 

17 (IV) with deactivated automatic 

18 identification systems; or 

19 (V) that engage in ‘‘flag hop20 ping’’ by changing national registries; 

21 (ii) individuals or entities— 

22 (I) storing petrochemicals subject 

23 to sanctions; or 

24 (II) refining or otherwise proc25 essing such petrochemicals; and 


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1 (iii) through the use of port entry and 

2 docking permission of vessels subject to 

3 sanctions; 

4 (C) assessing the viability of seizing tar5 gets identified as belonging to entities smug6 gling Iranian-origin petroleum products in vio7 lation of sanctions imposed by the United 

8 States, including— 

9 (i) location; 

10 (ii) origin and destination; 

11 (iii) seaworthiness; and 

12 (iv) asset value; 

13 (D) seizing, prosecuting, and, if appro14 priate, liquidating viable targets identified as 

15 belonging to entities involved in such smug16 gling; 

17 (E) deterring individuals and entities from 

18 violating sanctions by educating and engag19 ing— 

20 (i) insurance providers; 

21 (ii) parent companies; and 

22 (iii) vessel operators; 

23 (F) collaborating with allies and partners 

24 of the United States engaged in the Arabian 

25 Peninsula, including through standing or new 


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1 maritime task forces, to build sanctions enforce2 ment capacity through assistance and training 

3 to defense and law enforcement services; and 

4 (G) using public communications and glob5 al diplomatic engagements to highlight the role 

6 of petroleum product smuggling in supporting 

7 Iran’s human rights abuses and destabilizing 

8 terrorism activities; and 

9 (4) an assessment of— 

10 (A) the total number of vessels smuggling 

11 Iranian-origin petroleum products; 

12 (B) the total number of vessels smuggling 

13 such petroleum products destined for the Peo14 ple’s Republic of China; 

15 (C) the number of vessels smuggling such 

16 petroleum products specifically from the Islamic 

17 Revolutionary Guard Corps; 

18 (D) the most strategic locations for inter19 cepting smuggled Iranian-origin petroleum 

20 products destined for the People’s Republic of 

21 China; 

22 (E) interference from the People’s Repub23 lic of China in attempts by the United States 

24 to investigate or enforce sanctions on Iranian 

25 petroleum product exports; 


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1 (F) the effectiveness of the use of sanc2 tions with respect to insurers of entities that 

3 own or operate vessels involved in smuggling 

4 Iranian-origin petroleum products; 

5 (G) the distinction between the total num6 ber of suspected violations of sanctions related 

7 to smuggling of Iranian-origin petroleum prod8 ucts and the number of vessels legally viable to 

9 seize and prosecute in litigation, if any, and an 

10 accompanying explanation for each; 

11 (H) the personnel and resources needed to 

12 enforce sanctions with respect to Iranian-origin 

13 petroleum products; and 

14 (I) the impact of smuggled Iranian-origin 

15 petroleum products on global energy markets. 

16 (c) FORM.—The strategy required by subsection (a) 

17 shall be submitted in unclassified form, but may include 

18 a classified index. 

19 SEC. 5. IMPOSITION OF SANCTIONS. 

20 (a) IN GENERAL.—Not later than 180 days after the 

21 date of the enactment of this Act, the President shall— 

22 (1) identify each foreign entity, including any 

23 member of the Chinese Communist Party or an enti24 ty organized under the laws of the People’s Republic 

25 of China or otherwise subject to the jurisdiction of 


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1 the People’s Republic of China, that the President 

2 determines meets the criteria for the imposition of 

3 sanctions under— 

4 (A) the Iran Sanctions Act of 1996 (Public 

5 Law 104–172;50 U.S.C. 1701 note); 

6 (B) the Comprehensive Iran Sanctions, Ac7 countability, and Divestment Act of 2010 (22 

8 U.S.C. 8501 et seq.); 

9 (C) section 1245 of the National Defense 

10 Authorization Act for Fiscal Year 2012 (22 

11 U.S.C. 8513a); 

12 (D) the Iran Threat Reduction and Syria 

13 Human Rights Act of 2012 (22 U.S.C. 8701 et 

14 seq.); 

15 (E) the Iran Freedom and Counter-Pro16 liferation Act of 2012 (22 U.S.C. 8801 et seq.); 

17 (F) title I of the Countering America’s Ad18 versaries Through Sanctions Act (22 U.S.C. 

19 9401 et seq.); 

20 (G) any Executive order imposing sanc21 tions with respect to Iran issued under the au22 thority provided by the International Emer23 gency Economic Powers Act (50 U.S.C. 1701 et 

24 seq.); or 


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1 (H) any other provision of law imposing 

2 sanctions with respect to Iran; and 

3 (2) impose sanctions applicable under existing 

4 law with respect to each such entity. 

5 (b) REPORT REQUIRED.—Not later than 30 days 

6 after the imposition of sanctions under subsection (a) with 

7 respect to a foreign entity, the President shall submit to 

8 the appropriate congressional committees a report on the 

9 sanctions imposed. 

Æ 


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