Tracking and Restricting Adversarial Circumvention of Embargoes Act of 2025
Summary
What This Bill Does
The Tracking and Restricting Adversarial Circumvention of Embargoes Act requires the Director of National Intelligence to send Congress and the Treasury Secretary a report within 180 days analyzing transactions between China and Iran involving Iranian oil purchases and ballistic-missile-related materials. The report must assess China-based purchases of Iranian oil since 2020, including transshipment points and shell companies used to avoid sanctions exposure, and significant financial transactions by China-based entities tied to chemical precursors or other materials that may support the Iranian ballistic missile program. Within six months after that intelligence report, the Treasury Secretary must determine whether China is conducting sanctionable activities and report that determination to Congress.
Who Benefits and How
Congressional oversight committees benefit from a focused intelligence record on China-Iran sanctions evasion. Treasury sanctions officials and OFAC investigators benefit from an evidence base for determining sanctionable activity. United States national-security policymakers benefit from a clearer map of oil, finance, shell-company, and ballistic-missile procurement channels. Domestic sanctions-compliance professionals may benefit if the report produces clearer risk indicators for China-Iran transactions.
Who Bears the Burden and How
DNI analysts must produce the 180-day report covering oil purchases, transshipment routes, shell companies, chemical precursors, financial transactions, and ballistic-missile support. Treasury sanctions officials must make a follow-on sanctionable-activity determination within six months. China-based oil purchasers, precursor suppliers, shell-company intermediaries, and financial institutions face greater sanctions scrutiny and enforcement exposure. Iranian oil exporters face increased risk if the report identifies transaction routes that support sanctionable determinations.
Key Provisions
- Requires a DNI report within 180 days on China-Iran oil and ballistic-missile-related transactions.
- Requires assessment of Chinese purchases of Iranian oil since 2020, including transshipment and shell-company methods.
- Requires assessment of China-based financial transactions tied to chemical precursors or materials for the Iranian ballistic missile program.
- Directs Treasury to determine within six months whether China is conducting sanctionable activities.
- Requires Treasury to report the sanctionable-activity determination to Congress.
Evidence Chain:
This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.
At a Glance
What This Bill Does
Requires intelligence and Treasury reporting on China-Iran oil, shell-company, transshipment, and ballistic-missile precursor transactions, followed by a Treasury determination on sanctionable activity.
Key Policy Areas
Sanctions, Foreign Affairs, Energy, National Security
Primary Purpose
Requires intelligence and Treasury reporting on China-Iran oil, shell-company, transshipment, and ballistic-missile precursor transactions, followed by a Treasury determination on sanctionable activity.
Policy Domains
Substantive provisions
Identified Gains
- Congressional oversight committees
- Treasury sanctions officials
- OFAC investigators
- United States national-security policymakers
- Sanctions-compliance professionals
Identified Costs
- Director of National Intelligence
- Treasury Secretary
- China-based oil purchasers
- China-based precursor suppliers
- Shell-company intermediaries
- Iranian oil exporters
Sponsors
Legislative Progress
In CommitteeMr. Krishnamoorthi (for himself and Mr. Cline) introduced the following …
Referred to the Committee on Foreign Affairs, and in addition …
Introduced in House
Stakeholder Effects
cui bono?How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.
Congressional oversight committees, Director of National Intelligence, OFAC sanctions investigators
Positive-direction: Congressional oversight committees, OFAC sanctions investigators, Treasury sanctions officials
Negative-direction: Director of National Intelligence, Treasury Secretary
China-based companies trading with Iran, China-based oil purchasers, China-based precursor suppliers
China-based financial institutions, Shell-company intermediaries
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "agencies"
- → ['Director of National Intelligence', 'Department of the Treasury', 'OFAC']
- "foreign_entities"
- → ['China-based oil purchasers', 'Iranian oil exporters', 'Shell-company intermediaries']
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