Trump Sanctions – What His First 100 Days Reveal – Iran Is #1 Sanctions Target

US Treasury listed the impact of Trump’s first 100 days at the end of April 2025 which revealed a huge amount about the target of US foreign policy enforcement under Trump. It is now abundantly clear that “US Sanctions” cannot be articulated with any clarity unless a clear distinction between Republican and Democrat sanctions (enforcement) policy is made.

As we saw under Obama/Biden’s two terms, Trump 1.0, Biden and now Trump 2.0 – the Republican and Trump roadmap is clear. Iran, its proxies and trade partners is the #1 Trump sanctions target. Trump also made it clear at the end of April 2025 that the US will use secondary sanctions to target Iran oil & petrochemical shipments. This is a major new shift from Biden, whose relatively light enforcement touch on Iran and reluctance to employ US secondary sanctions led to Iran building up 80%+ uranium enrichment.

From a tariff perspective, Trump’s specific targeting is very relevant. Iran’s trade partners include China in particular. Moreover, those jurisdictions offering safe harbour to shipping companies and ship registrations as part of Iran’s Shadow Fleet will be in the sanctions enforcement firing line. It is quite incorrect to assume that US sanctions enforcement will follow the Biden strategy of appeasing Iran with lighter touch enforcement. Furthermore, those trade partners facilitating Iran oil & petrochemical shipments will also be hit hard. Targeted actors from multiple jurisdictions have already been on the receiving end of sanctions enforcement under Trump 2.0.

Oil and petrochemicals traders should be wary of over-reliance on Biden era sanctions enforcement. Instead, the pertinent reference point should be Trump’s first Maximum Pressure on Iran 1.0 2017-21. Trump has deliberately reinforced the message that secondary US sanctions will be applied to any country or person (“US Person” = entity as well) trading Iranian oil and petrochemicals. Such enforcement intent is effective. The last time around, Trump’s Maximum Pressure 1.0 2017-21 had devastating consequences for Iran’s economy and saw a massive drop in Iran’s oil revenues. From pre-sanctions crude export levels of 2.5 million-2.7 million barrels per day (bpd), Iran averaged crude exports of 250,000-400,000 bpd, according to Arab News Daily (02/02/2020)1. International Bank of Yemen, financier for Iran proxy, Lebanon’s Hezbollah, has also been targeted by Trump.

Other areas of US sanctions enforcement under Trump are clear from his first 100 days. South American cartels and transnational criminal organizations have been targeted substantially for narcotics trafficking and human smuggling, illicit finance. China and Russia have been targeted by Trump for hacking and ransomware. The US has targeted a Rwandan Minister supporting Democratic Republic of Congo’s human rights abuses – which mines 80% of the world’s supply of lithium (a key EV battery component) via brutal child slave labour.

One way of pinpointing the way that the US can target rogue US sanctions actors operating in multiple jurisdictions is to focus on the countries of registration, residence or base. Trump’s sanctions enforcement has targeted a wide variety of entities, individuals and vessels from multiple jurisdictions – with individuals and entities in China, Hong Kong and the United Arab Emirates (UAE) and India frequently targeted. But the overriding target is clearly Iran, its trade partners and proxies such as Hezbollah and the Houthis. Where Russian actors have been targeted by Trump, this has been in relation to Russia’s supply of arms and commodities to Iran proxy the Houthis and ransomware attacks. Iran’s nuclear program has already been targeted by the US under Trump (April 9, 2025 – US Treasury designations) – so the thrust of this US Administration’s policy is very clear.

The pertinent question at this juncture has to be how the US under Trump handles Russia. Should peace talks over Ukraine succeed, we may see Russia return to the trade fold in terms of oil & gas, petrochemical sales. This is because a return to normality on the trade front will undoubtedly be key to Russia’s demands. Furthermore, if Trump sees through his very obvious intent to choke off Iran’s oil and petrochemicals revenues – and there is little doubt he will do so – replacement supply will be required to avoid oil price hikes. Which any US President would want to avoid – so Russia could provide a solution.

There remains a lot of perfectly understandable scepticism in the market over whether the US can achieve its goal of reducing Iran to zero oil and petrochemicals revenues. Particularly after the spectacle of largely ineffective G7/EU oil price caps which have failed to impress. This is where the comparison with Trump Maximum Pressure 1.0 comes in – particularly if the Russia peace talks come to fruition. The highly negative impact of Maximum Pressure 1.0 on Iran’s economy is clearly visible.

China’s crude oil imports rose from 1.4M bpd in 2000 to a record 11.1M bpd in 2024. This simply underlines China’s #1 global importer status with a 23% share of global imports in 2023. By 2024, over half of China’s imports came from GCC countries, Iraq, and Iran, while Russia solidified its role as a key supplier, accounting for 20% of total imports. This simply emphasises the weak impact of sanctions on Russia amid the Ukraine conflict.

China’s crude oil imports grew at a compound annual rate (CAGR) of 6.2% from 2010-2024. Critically when one considers the weak impact of global sanctions on Russia from a non-G7 perspective, imports from Russia rose far faster by 15.1% annually, followed by the UAE (14.7%), Iraq (12.9%), Brazil (11.2%), and Oman (7.0%). Imports from Saudi Arabia grew much more slowly (4.0%).

It is highly likely that China and Russia would rather engage legitimately without US censure in global trade than risk the obstacle of being potentially excluded from US Dollar and US markets, and being constantly targeted by US extra-territorial actions involving the dreaded US secondary sanctions enforcement regime – and likely US trade tariff and monetary penalties for sanctions and related trade breaches.

We should not forget that EU sanctions policy has been highly unconvincing – with EU27 Member States free to choose whether to follow agreed EU sanctions policy (that they have collectively agreed to) or not. This has had a major dilutive effect on the impact of G7/EU oil price caps on Russia – with an extraordinarily weak enforcement showing from the EU and particularly the highly compromised EU27 – often very dependent on Russia energy supply. As CREA data shows, Russian revenues from fossil fuels from 22 February 2022 to February 2025 while under G7/EU and Western sanctions stood at EUR 827BN, with 68% or EUR 565.6BN in oil, EUR 175.5BN or 21% in gas and EUR 86 or 11% in coal. Of this, the EU – despite sanctions on Russia’s fossil fuels as part of its own and wider G7 effort – paid out a breathtaking EUR 205.2BN in fossil fuel revenues to Russia. 50% or EUR 102.9BN in oil revenues, 48% or EUR 98.6BN in gas receipts, and EUR 3.6BN in coal revenues.

There is no way that this failed G7 Russia sanctions enforcement outcome can be regarded as a remotely appropriate proxy for the sort of robust enforcement that Trump has stated he intends to pursue against stated US sanctions targets like Iran. As we saw with the change from Obama/Biden’s failed JCPOA/Iran Nuclear Deal from 2015 and Trump’s subsequent exit in 2018 and Maximum Pressure (1.0), Democrat and Republican sanctions enforcement policy is markedly different. There is no reason to suggest that any of this will change under Trump 2.0. As a reminder, Trump’s Maximum Pressure 1.0 from 2017-2021 targeted Iran’s oil and petrochemicals sales and had a devastating impact on Iran’s economy. In stark contrast to the immediate aftermath of the 2015 JCPOA/Iran Nuclear Deal.

Basing future US Sanctions policy under Trump on weak Biden era enforcement data is ultimately going to be highly misleading. Market participants simply cannot afford to rely on generalising “US Sanctions Enforcement” across highly divergent Republican and Democrat approaches. Republican policy of recent times has always put Iran as a major target – Democrat policy far less so. The Democrats have repeatedly, and ultimately ineffectively, tried to engage with the lacklustre EU on foreign policy and sanctions direction. Which has consistently proven to be ineffective.

To date, Trump has simply carried out policy that has been well flagged in advance. Iran, its proxies and trade partners, are well and truly on the US radar, therefore…

As ever when predicting Trump’s next moves – it is rarely rocket science.