IIB 
115TH CONGRESS 
1ST SESSION H. R. 4324 
IN THE SENATE OF THE UNITED STATES 
DECEMBER 18, 2017 
Received; read twice and referred to the Committee on Banking, Housing, and 
Urban Affairs 
AN ACT 
To require the Secretary of the Treasury to make certifi-
cations with respect to United States and foreign finan-
cial institutions’ aircraft-related transactions involving 
Iran, and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
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SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Strengthening Over-
sight of Iran’s Access to Finance Act’’. 
SEC. 2. FINDINGS. 
The Congress finds the following: 
(1) Under the Joint Comprehensive Plan of Ac-
tion (JCPOA), informally known as the Iran nuclear 
deal, the Obama administration agreed to license the 
sale of commercial passenger aircraft to Iran, the 
world’s foremost state sponsor of terrorism and a ju-
risdiction of primary money laundering concern. 
(2) In April 2015, prior to the adoption of the 
JCPOA, Secretary of the Treasury Jacob Lew, in 
publicly advocating for its provisions, stated: ‘‘Make 
no mistake: deal or no deal, we will continue to use 
all our available tools, including sanctions, to 
counter Iran’s menacing behavior. Iran knows that 
our host of sanctions focused on its support for ter-
rorism and its violations of human rights are not, 
and have never been, up for discussion.’’. 
(3) In March 2016 remarks to the Carnegie 
Endowment for International Peace, Secretary Lew, 
in reference to U.S. commitments under the 
JCPOA, stated: ‘‘While we have lifted the nuclear 
sanctions, we continue to enforce sanctions directed 
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at support for terrorism and regional destabilization, 
and missile and human rights violations.’’. 
(4) In an April 2016 forum at the Council on 
Foreign Relations, Secretary Lew stated that, under 
the JCPOA, the U.S. committed to lifting its nu-
clear sanctions, ‘‘but the U.S. financial system is not 
open to Iran, and that is not something that is going 
to change’’. 
(5) In September 2016, the Department of the 
Treasury’s Office of Foreign Assets Control (OFAC) 
issued licenses permitting the export of up to 97 air-
craft for use by Iran Air, the Islamic Republic of 
Iran’s flagship state-owned carrier. These licenses 
included authorization for U.S. financial institutions 
‘‘to engage in all transactions necessary to provide 
financing or other financial services’’ in order to ef-
fectuate the sales. In November 2016, OFAC li-
censed an additional 106 aircraft for purchase by 
Iran Air, which are also eligible for financing au-
thorized by OFAC. 
(6) The Department of the Treasury had sanc-
tioned Iran Air in 2011 for its use of commercial 
passenger aircraft to transport rockets, missiles, and 
other military cargo on behalf of the Islamic Revolu-
tionary Guard Corps (IRGC) and Iran’s Ministry of 
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Defense and Armed Forces Logistics, both of which 
had been designated under Executive Order No. 
13382 for weapons proliferation-related activities. In 
October 2017, the IRGC went on to be designated 
under Executive Order No. 13224 for its support of 
the IRGC-Qods Force, which has provided support 
to terrorist groups such as Hizballah, Hamas, and 
the Taliban. 
(7) Among Iran Air’s sanctionable activities, 
the airline delivered missile or rocket components to 
the Assad government in Syria, which like Iran is 
classified as a state sponsor of terrorism. 
(8) The Assad regime is responsible for a civil 
conflict that has claimed an estimated 400,000 lives, 
including through the government’s deployment of 
chemical weapons and barrel bombs against un-
armed civilians and children. 
(9) Despite being delisted in 2016, Iran Air has 
continued to fly known weapons resupply routes to 
government-controlled areas of Syria. According to 
research by the Foundation for Defense of Democ-
racies, between Implementation Day of the JCPOA 
on January 16, 2016, and May 4, 2017, Iran Air 
operated at least 134 flights to Syria, which in-
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cluded stops in Abadan, Iran, a suspected IRGC 
logistical hub for airlifts to the Assad regime. 
(10) In November 2016 correspondence to the 
Chairman of the House Committee on Financial 
Services, the Department of the Treasury noted that 
the commitment to delist Iran Air under the JCPOA 
‘‘does not affect our ability to designate, or re-des-
ignate, 
any 
Iranian 
airline 
that 
engages 
in 
sanctionable activity. The United States retains the 
ability to designate any individual or entity that en-
gages in sanctionable activities under our authorities 
targeting conduct outside the scope of the JCPOA, 
including Iran’s support for terrorism, human rights 
abuses, ballistic missile program, and other desta-
bilizing activities in the region.’’. 
(11) In April 2017, Iran announced a deal for 
Aseman Airlines to purchase up to 60 commercial 
aircraft, a transaction that would require authoriza-
tion by OFAC. Aseman Airlines’ chief executive offi-
cer, Hossein Alaei, has for decades served as a sen-
ior member of the IRGC. 
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SEC. 3. CERTIFICATIONS FOR AIRCRAFT-RELATED TRANS-
ACTIONS BY UNITED STATES AND FOREIGN 
FINANCIAL INSTITUTIONS. 
(a) IN GENERAL.—Not later than 30 days after au-
thorizing a transaction by a United States or foreign fi-
nancial institution in connection with the export or re-ex-
port of a commercial passenger aircraft to Iran (or, for 
an authorization made after January 16, 2016, but before 
the date of the enactment of this Act, not later than 60 
days after such date of enactment), and every 180 days 
thereafter for the duration of the authorization, the Sec-
retary of the Treasury shall submit the report described 
under subsection (b) to the appropriate congressional com-
mittees. 
(b) REPORT WITH RESPECT TO FINANCIAL INSTITU-
TIONS’ IRAN-RELATED TRANSACTIONS AND DUE DILI-
GENCE.—With respect to a financial institution and a 
transaction described under subsection (a), a report is de-
scribed under this subsection if it contains— 
(1) a list of financial institutions that, since 
January 16, 2016, have conducted transactions au-
thorized by the Secretary in connection with the ex-
port or re-export of commercial passenger aircraft to 
Iran; and 
(2) either— 
(A) a certification that— 
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(i) the transaction does not pose a 
significant money laundering or terrorism 
financing risk to the United States finan-
cial system; 
(ii) the transaction will not benefit an 
Iranian person that, since the date that is 
1 year preceding the date of the certifi-
cation— 
(I) has knowingly transported 
items used for the proliferation of 
weapons of mass destruction, includ-
ing systems designed in whole or in 
part for the delivery of such weapons; 
(II) has knowingly transported 
items used to establish in Syria a per-
manent military presence of either 
Iranian military forces or Iranian 
backed militia; or 
(III) has knowingly provided 
transportation services or material 
support for, or on behalf of, any per-
son designated under Executive Order 
Nos. 13224, 13382, or 13572; and 
(iii) any financial institution described 
under subsection (b)(1) has had since the 
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date such authorization was made, or, if 
the authorization is no longer in effect, 
had for the duration of such authorization, 
appropriate policies, procedures, and proc-
esses in place to avoid engaging in 
sanctionable activities that may result from 
the financial institutions’ exposure to Iran; 
or 
(B) a statement that the Secretary is un-
able to make the certification described under 
subparagraph (A) and a notice that the Sec-
retary will, not later than 60 days after the 
date the determination is submitted to the ap-
propriate congressional committees, issue a re-
port on non-certification described under sub-
section (c) to the appropriate congressional 
committees. 
(c) REPORT ON NON-CERTIFICATION.—With respect 
to a financial institution and a transaction described 
under subsection (a), a report on non-certification is de-
scribed under this subsection if it contains— 
(1) a detailed explanation for why the Secretary 
is unable to make the certification described under 
subsection (b)(2); 
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(2) a notification of whether the Secretary 
will— 
(A) not amend the authorization of the 
transaction with respect to a financial institu-
tion, notwithstanding such non-certification; 
(B) suspend the authorization until the 
Secretary is able to make such certification; 
(C) revoke the authorization; or 
(D) otherwise amend the authorization; 
and 
(3) an explanation of the reasons for any action 
to be taken described under paragraph (2). 
(d) WAIVER.—The President may waive, on a case- 
by-case basis, the provisions of this Act for up to 1 year 
at a time upon certifying to the appropriate congressional 
committees that— 
(1) the Government of Iran has— 
(A) made substantial progress towards 
combating money laundering and terrorism fi-
nancing risk emanating from Iran; or 
(B) has significantly reduced Iran’s— 
(i) destabilizing activities in the re-
gion; or 
(ii) material support for terrorist 
groups; or 
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(2) such waiver is important to the national se-
curity interests of the United States, with an expla-
nation of the reasons therefor. 
(e) TERMINATION.—This section shall cease to be ef-
fective on the date that is 30 days after the date on which 
the President certifies to the appropriate congressional 
committees that— 
(1)(A) the Secretary does not find, under sec-
tion 5318A of title 31, United States Code, that rea-
sonable grounds exist for concluding that Iran is a 
jurisdiction of primary money laundering concern; 
and 
(B) Iran has ceased providing support for acts 
of international terrorism; or 
(2) terminating the provisions of this section is 
vital to the national security interests of the United 
States, with an explanation of the reasons therefor. 
(f) DEFINITIONS.—For purposes of this section: 
(1) APPROPRIATE
CONGRESSIONAL
COMMIT-
TEES.—The term ‘‘appropriate congressional com-
mittees’’ means the committees on Financial Serv-
ices and Foreign Affairs of the House of Represent-
atives and the committees on Banking, Housing, and 
Urban Affairs and Foreign Relations of the Senate. 
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