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JCPOA Implemented, Rolling Back Several U.S. Sanctions on Iran

The U.S. and Iran reached “Implementation Day” for the Joint Comprehensive Plan of Action on Jan. 16, after the International Atomic Energy Agency verified that Tehran implemented nuclear-related prerequisites dictated by the JCPOA, Secretary of State John Kerry said during a speech announcing the deal’s official initiation (here). The U.S. has lifted certain nuclear sanctions on the country, as OFAC released related guidance and documents, which can be found (here). OFAC has also submitted for implementation a final rule (here) that would add a general license under Iran sanctions regulations, 31 C.F.R. part 560, relating to importation of Iranian-origin carpets and foodstuffs, to become effective when published in the Federal Register. Furthermore, the office has also published information regarding actions to implement other JCPOA commitments, including removals from the Specially Designated Nationals and Blocked Persons List, the Foreign Sanctions Evaders List, and the Non-SDN Iran Sanctions Act List (here).

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“In return for the steps that Iran has taken, the United States and the EU will immediately lift nuclear-related sanctions, expanding the horizon of opportunity for the Iranian people,” Kerry said in published remarks. “Today marks the moment that the Iran nuclear agreement transitions from an ambitious set of promises on paper to measurable action in progress. Today, as a result of the actions taken since last July, the United States, our friends and allies in the Middle East, and the entire world are safer because the threat of a nuclear weapon has been reduced.”

Additionally, President Barack Obama on Jan. 16 revoked Executive Orders 13574, “Concerning Further Sanctions on Iran” (here); 13590, “Authorizing the Imposition of Certain Sanctions with Respect to the Provision of Goods, Services, Technology, or Support for Iran's Energy and Petrochemical Sectors (here); 13622, “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Freedom and Counter-Proliferation Act (IFCA) of 2012 and Additional Sanctions with Respect to Iran (here); and 13645, “Implementing the Iran Freedom and Counter-Proliferation Act of 2012 and Authorizing New Iran Sanctions” (here).

However, Obama announced the start of new authority to impose on Iran sanctions pursuant to the IFCA and unrelated to the JCPOA, under Executive Order 12957 of 1995 (here). News of “Implementation Day” roused criticism from Congressional Republicans who previously expressed skepticism of the agreement. “In selling this agreement, President Obama pledged to keep the pressure on Iran for its destructive behavior,” Foreign Affairs Chairman Ed Royce, R-Calif., said in a statement (here). “Yet it is Iran that has pressured the administration to drop new sanctions against its missile program and then announced its acceleration. This flawed deal is only entrenching Iran’s military and security forces that run the country. Now more than ever, we need a policy of backbone, not backing down.”

Implementation drew a more mixed response from Congressional Democrats, with some such as Foreign Affairs Ranking Member Eliot Engel, D-N.Y. sharing praise (here), and others like Foreign Relations Ranking Member Ben Cardin, D-Md., appearing more tepid about the JCPOA and skeptical of other Iranian ambitions. “With Implementation Day of the Iran nuclear agreement now here, it is critical that all parties uphold their commitments agreed to in the Joint Comprehensive Plan of Action,” Cardin said in a statement. “While Congress was not a party to the nuclear negotiations, we do have a productive role to play in conducting rigorous oversight of Iranian compliance with the agreement. As issues arise outside the scope of the JCPOA, from Iran’s continued ballistic missile development, sponsorship of terrorism and violent proxies, and ongoing human rights violations, Congress should respond vigorously and without delay.”

Email ITTNews@warren-news.com for a copy of Cardin’s statement.