HR6528-119

In Committee

Tracking and Restricting Adversarial Circumvention of Embargoes Act of 2025

119th Congress Introduced Dec 9, 2025

Legislative Progress

In Committee
Introduced Committee Passed
Dec 9, 2025

Mr. Krishnamoorthi (for himself and Mr. Cline) introduced the following …

Summary

What This Bill Does
This bill requires U.S. intelligence agencies to investigate and report on China's purchases of Iranian oil and China's support for Iran's ballistic missile program. It specifically looks for evidence of sanctions evasion through shell companies and transshipment points. The Secretary of the Treasury must then determine whether China is conducting sanctionable activities.

Who Benefits and How
- U.S. national security apparatus and Congressional oversight: Gain transparency into China-Iran illicit trade and potential sanctions violations
- U.S. oil and gas producers: May indirectly benefit if the findings lead to stricter enforcement of Iranian oil sanctions, reducing competition from sanctioned oil in global markets
- U.S. sanctions compliance industry: May see increased demand for their services if new sanctions or enforcement actions follow

Who Bears the Burden and How
- Chinese state-owned oil companies: Face increased risk of being named in sanctions reports and potential designation as sanctions violators
- Chinese financial institutions and companies trading with Iran: Face potential Treasury sanctions designation if found to be facilitating Iran trade
- Shell companies and intermediaries: Risk exposure and potential sanctions for facilitating China-Iran trade
- Director of National Intelligence and Treasury Department: Must dedicate resources to prepare comprehensive reports

Key Provisions
- Director of National Intelligence must submit a report within 180 days analyzing China-Iran oil and missile transactions
- Report must assess Chinese oil purchases from Iran since 2020, including sanctions evasion methods
- Report must assess Chinese financial transactions supporting Iran's ballistic missile program
- Secretary of Treasury must determine within 6 months after the report whether China is conducting sanctionable activities
- Treasury must report determination to Congress

Model: claude-opus-4
Generated: Dec 27, 2025 17:42

Evidence Chain:

This summary is derived from the structured analysis below. See "Detailed Analysis" for per-title beneficiaries/burden bearers with clause-level evidence links.

Primary Purpose

Requires intelligence reporting on China-Iran oil and ballistic missile transactions and mandates Treasury determination on whether China is conducting sanctionable activities.

Policy Domains

National Security Trade Sanctions Foreign Policy

Legislative Strategy

"Increase transparency and accountability around China's alleged sanctions evasion regarding Iran, potentially setting the stage for new sanctions on Chinese entities"

Likely Beneficiaries

  • US national security apparatus
  • Congressional oversight committees
  • US oil and gas industry (indirectly, by limiting Iranian oil exports)
  • US financial sector (by clarifying sanctions compliance expectations)

Likely Burden Bearers

  • Chinese state-owned enterprises and companies trading with Iran
  • Iranian oil sector
  • Chinese financial institutions involved in Iran transactions
  • Companies using transshipment points to facilitate China-Iran trade

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
National Security Sanctions Foreign Policy
Actor Mappings
"secretary_of_treasury"
→ Secretary of the Treasury
"director_of_national_intelligence"
→ Director of National Intelligence
"appropriate_congressional_committees"
→ Senate/House Banking, Commerce, Armed Services, Foreign Relations/Affairs, and Intelligence committees

Key Definitions

Terms defined in this bill

1 term
"appropriate congressional committees" §2(c)

Includes Senate Banking, Commerce, Armed Services, Foreign Relations, and Intelligence committees; and House Financial Services, Energy and Commerce, Armed Services, Foreign Affairs, and Intelligence committees

We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.

Learn more about our methodology