Iranian sanctions legislation is back on Congress’s menu and Iranian caviar is not. Today the Senate Finance Committee approved a markup of The Iranian Sanctions Act of 2008, a re-tooling (and improvement) of the Iran Counter-Proliferation Act of 2007. The House approved similar legislation earlier this year.

Although the text of the mark-up is not yet available, a mark-up document posted on the Senate Finance Committee site describes the new legislation. Like the previously proposed legislation, the Iranian Sanctions Act of 2008 would forbid all exports from Iran to the United States, including carpets and food products — like caviar — which Iran can currently export to the United States. And it forbids foreign subsidiaries of U.S. companies from violating the sanctions, departing from current law which would permit foreign subsidiaries to trade with Iran if that trade is not controlled by the parent company or other U.S. persons.

The biggest change between the Iranian Counter-Proliferation Act of 2007 and the Iranian Sanctions Act of 2008 is that someone apparently looked at the text of the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”) and made sure that the Iranian Sanctions Act of 2008 is consistent with the language of TSRA. Under the Counter-Proliferation Act exports of “food and medicine” were exempted from the export ban. Now the proposed Iranian Sanctions Act of 2008 exempts “agricultural commodities, medicine and medical devices,” thereby broadening the exemption to track TSRA.

The informational exemptions first past under the Berman Amendment are also preserved in the currently proposed legislation. And although the proposed legislation doesn’t codify the exemption for goods, service and technology to insure air safety, the proposed bill allows the President to make exceptions to the export bans and notes that the President had previously permitted the export of civilian aircraft parts.

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