Iran and Libya Sanctions Act

Bill Clinton signed the Act on 5 August 1996 as Public Law 104-172. It required sanctions on foreign companies that invested more than $20m in Iran's petroleum sector. In September 2006 it was renamed the Iran Sanctions Act, because it no longer applied to Libya.

Its first test came at South Pars. In September 1997 Total signed a $2bn deal for phases 2 and 3 of the Iranian gas field, with Gazprom and Petronas as partners, and the project was the first found to breach the Act. On 18 May 1998 Washington invoked the Act's national-interest waiver for all three firms. Brussels had first promised to work more closely with Washington against weapons proliferation and terrorism.

The case became the standard example of a mandatory sanctions statute bending to a presidential waiver written into its own text. The Graham Act of 2026 carries a clause of the same design in section 115, which Donald Trump invoked on 16 October 2026.