HR6528-119

In Committee

Tracking and Restricting Adversarial Circumvention of Embargoes Act of 2025

119th Congress Introduced Dec 9, 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

Sanctions Foreign Affairs Energy National Security

Substantive provisions

Identified Gains
  • Congressional oversight committees
  • Treasury sanctions officials
  • OFAC investigators
  • United States national-security policymakers
  • Sanctions-compliance professionals
Model: codex-gpt-5 | Version: bill_summary_v2 | Source: ih
OFAC investigators: ,
Treasury sanctions officials: ,
Congressional oversight committees: ,
Sanctions-compliance professionals: ,
United States national-security policymakers: ,
Identified Costs
  • Director of National Intelligence
  • Treasury Secretary
  • China-based oil purchasers
  • China-based precursor suppliers
  • Shell-company intermediaries
  • Iranian oil exporters
Model: codex-gpt-5 | Version: bill_summary_v2 | Source: ih
Treasury Secretary: ,
Iranian oil exporters: ,
China-based oil purchasers: ,
Shell-company intermediaries: ,
China-based precursor suppliers: ,
Director of National Intelligence: ,

Legislative Progress

In Committee
Introduced Committee Passed
Dec 9, 2025

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

Dec 9, 2025

Referred to the Committee on Foreign Affairs, and in addition …

Dec 9, 2025

Introduced in House

Stakeholder Effects

cui bono?

How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.

Government
6 mentions across 2 clauses
+4 positive -2 negative

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

Foreign Entities
3 mentions across 2 clauses
-3 negative

China-based companies trading with Iran, China-based oil purchasers, China-based precursor suppliers

Financial Services
2 mentions across 2 clauses
-2 negative

China-based financial institutions, Shell-company intermediaries

Oil & Gas
1 mention across 1 clause
-1 negative

Iranian oil exporters

2/3
sections analyzed
Full impact breakdown

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Sanctions Foreign Affairs Energy National Security
Actor Mappings
"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