The United States has used economic sanctions targeting the energy sector that is so vital to Iran’s economy with varying degrees of intensity since the Iran Hostage Crisis of 1979. By and large, the sanctions did not have their intended effect. By 2010, Iran was the foremost state-sponsor of terrorism and was on the brink of acquiring the capability to develop nuclear weapons—a phenomenon that could have cataclysmic repercussions for American interests in the Middle East and beyond. In July 2010, Congress passed and President Obama signed the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, in an effort to use the most drastic sanctions measures yet to finally change the course of Iran’s behavior. This Comment begins by tracing the history of United States petroleum-related sanctions against Iran through various inflection points since 1979. This Comment then discusses the political context, content, and preliminary implementation of the latest round of sanctions against Iran. Thereafter, this Comment critically analyzes the legal bases, political challenges, and inherent policy difficulties surrounding the new sanctions law. Finally, this Comment proposes a number of policy recommendations for the President and Congress in light of the changing policy landscape. In sum, this Comment concludes that a far-reaching, robustly applied, multilateral sanctions policy remains the last, best hope of peacefully preventing Iran from acquiring weapons of mass destruction.

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