With the objective of reducing Iran’s oil exports to zero and diminishing Russia’s oil revenues, the United States has imposed extensive primary and secondary economic sanctions on the international oil trade of both countries. Adopting a comparative approach and employing a descriptive–analytical method, this article examines the legal regime governing U.S. sanctions on the sale of Iranian and Russian oil in order to identify their similarities and differences within the framework of international trade law. The main research question addresses whether unilateral U.S. sanctions produce identical effects on the international oil trade of Iran and Russia.

The final analysis demonstrates that the nature, objectives, and legal frameworks of these sanctions differ significantly. While sanctions against Iran are designed to entirely eliminate oil export revenues—resulting in an absolute prohibition on the purchase of Iranian oil by U.S. natural and legal persons—and while secondary sanctions with extraterritorial character substantially expand the scope and severity of their impact, sanctions against Russia are primarily focused on long-term and high-risk projects. Moreover, the purchase of Russian oil remains permissible under certain restrictions, such as the imposition of a price cap mechanism. These differences indicate that unilateral sanctions do not exert uniform effects on the two countries and are consistently accompanied by substantial conflicts with fundamental principles of international trade law, including the principles of non-discrimination, most-favored-nation treatment, and the prohibition of quantitative restrictions.