September 16, 2016

12 Organizations Write Congress on Potential Iran Sanctions Act Debate


Contact: Jamal Abdi
Phone: 202-386-6408
Email: [email protected]

Washington, DC – A dozen national organizations that have supported the Joint Comprehensive Plan of Action (JCPOA) delivered a letter to Congress today outlining key considerations for any potential debate over legislation to extend the Iran Sanctions Act of 1996 (ISA), which is set to expire at the end of the year. 
The battle over extending ISA may be exploited by opponents of the JCPOA, who have been stymied in their attempts to pass deal-killing measures over the past year. The letter urges Congress to only consider renewing ISA as a clean reauthorization. As the administration will retain full authority to snap back sanctions with or without the extension of ISA, the letter states that ISA should be allowed to expire in lieu of passing legislation that could unravel the JCPOA. Finally, it urges Congress to reaffirm that the U.S. is fully committed to uphold its sanctions relief obligations and that lawmakers should defend and support further action to ensure that relief under the JCPOA moves forward. 
The full text of the letter, including a list of signers, is available below.

View in PDF.
September 16, 2016
To: Majority Leader Mitch McConnell, Minority Leader Harry Reid, Speaker of the House Paul Ryan and Minority Leader Nancy Pelosi
CC: Members of the U.S. Senate and House of Representatives
We, the undersigned organizations, write to urge the 114th Congress to continue to maintain the United States’ commitment to upholding the Joint Comprehensive Plan of Action (JCPOA), which has succeeded in blocking Iran’s potential pathways to a nuclear weapon while averting a disastrous war. We understand that Congress may soon focus its attention on a potential renewal of the Iran Sanctions Act of 1996 (ISA), which is set to expire on December 31, 2016. In deciding whether and how to extend this legislation, we urge Congress to observe several important considerations.
First, Congress should only consider renewing ISA as a clean reauthorization. Many, but not all, of the legislative proposals to extend ISA introduced thus far include poison-pill provisions and measures that would seek to re-impose sanctions lifted under the JCPOA, albeit under a different justification. Shifting the goalposts midway through implementation would be viewed as an outright violation by our international partners in the P5+1 and by Iran, and must be rejected.
Second, it is important to note that the administration will retain full authority to snap back sanctions in order to respond to a potential Iranian breach of the accord with or without the extension of ISA under the authorities established by the International Emergency Economic Powers Act (IEEPA). While some have asserted that ISA should be extended in order to ensure snapback authorities, the President retains virtually unlimited authority to impose or re-impose sanctions under IEEPA, rendering an extension of ISA largely duplicative of existing authorities. Therefore, if opponents of the JCPOA are unwilling to allow for a clean renewal of ISA, it should be allowed to expire rather than moving forward with legislation that could unravel the JCPOA and free Iran from its nuclear constraints under the accord.
Third, if ISA is extended beyond the date of the JCPOA’s “Transition Day,” Congress should reaffirm that the U.S. is fully committed to upholding its commitments to terminate nuclear-related sanctions on that date so long as Iran upholds its own obligations. The latest potential date for “Transition Day” under the JCPOA is October 18, 2023. Many of the current proposals to renew ISA go well beyond that time frame, departing from past ISA renewals that have extended the authorization by just five years. An act of Congress will therefore be necessary to terminate nuclear-related sanctions, including ISA sanctions, and Congress should make clear that this remains its intent. Further, lawmakers who support the JCPOA must also defend and push for further action by the U.S. government to ensure that businesses receive due assurance that they will not face U.S. legal repercussions for engaging in transactions allowable under the JCPOA.
There have been numerous efforts to undermine confidence in the JCPOA, both from Congressional opponents of the JCPOA and hardliners in Iran.  Any consideration of an ISA extension must not become an opportunity for opponents of the JCPOA on either side to re-litigate or renege on the accord. We urge you to take these important considerations into account to preserve the important national security achievements of the JCPOA. We will be monitoring this debate closely as it moves forward and look forward to working with you.

Americans for Peace Now
Council for a Livable World
Friends Committee on National Legislation
J Street
Just Foreign Policy
NIAC Action
Peace Action
United Methodist Church, General Board of Church and Society
Women’s Action for New Directions
Win Without War


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