Iranian Parliament Approves Corporate Liability and Mens Rea Rules in Foreign Influence Bill

Iran's Parliament approved Articles 30 and 31 of the draft bill "Countering the Influence of Foreign Intelligence Services, Governments, or Entities" on Wednesday, November 4, 2026, during a virtual open session. The two articles set out the mental element required for individual convictions and introduce corporate criminal liability, including court-ordered dissolution of companies.

What must prosecutors now prove?

Article 31 sets a knowledge threshold. Penalizing an individual requires establishing that the person was aware of contact, support, guidance, or training provided by a foreign agent. Penalties for offenses under the law apply only if the perpetrator's awareness of the crime — or of strategic contact, support, oversight, training, guidance, or control by a foreign entity — is established.

In plain terms, the statute demands mens rea (the legal requirement that a defendant knew what they were doing) before punishment attaches. Mere contact with a foreign-linked actor, without proven awareness, won't support a conviction under this framework. That's the mechanism, and it matters for how Iranian prosecutors build these cases.

The same article doesn't stop at intentional conduct. It also covers crimes committed through negligence or recklessness that harms national security or national interests. In those cases, the perpetrator faces one or two Grade Five or Grade Six punishments — the lower tiers of Iran's graduated sentencing scale, reserved for less serious offenses.

How are companies held liable?

Article 30 addresses legal entities — companies, organizations, and other incorporated bodies. Under its provisions, if a court finds that a crime was committed using the resources or name of a legal entity, or on its behalf or for its benefit, the court may penalize the entity itself, or dissolve it entirely, in addition to punishing the individual perpetrator.

Dissolution is the corporate death penalty here: the entity ceases to exist. But the approved text builds in a protection. Dissolution will not prevent the recovery of workers' claims or the rights of third parties who were not involved in committing the crime. Employees and innocent creditors keep their remedies even after the entity is wound up.

For practitioners advising businesses operating in or with Iran, the practical consequence is straightforward. Corporate structures no longer insulate anyone. If an employee or officer commits a covered offense using company resources, the company itself faces penalties up to dissolution, layered on top of the individual's sentence. Compliance screening for foreign-agent exposure now has direct statutory stakes.

What about conspiracy?

Lawmakers also appended a clause to Article 3 of the bill. If two or more individuals conspire to commit crimes under this law, each person's penalty increases by one to two degrees, proportionate to the offense's societal impact. Group conduct draws harsher punishment than solo acts, and courts get a range to calibrate by.

Where does the bill stand now?

Parliament approved the bill's general framework on August 16, 2025, with 183 votes in favor. The November 4 session continued the article-by-article review. Lawmakers had already passed other provisions, including rules on disclosing unpublished official information to foreign agents, and restrictions on interviews by Iranian citizens with media outlets the regime labels as "hostile."

The knowledge requirement in Article 31 is the notable feature of this batch of amendments. It inserts an intent gate into a bill otherwise built around broad foreign-influence offenses, while negligence liability and corporate dissolution expand the net in the other direction. Whether Iranian courts apply the awareness standard strictly will depend on how implementing jurisprudence develops once the full bill passes and takes effect.