We are disappointed that Congress has decided to renew the Iran Sanctions Act (ISA). We strongly oppose broad unilateral sanctions because they are ineffective, they punish the wrong people, and they pose barriers to far more effective tools to accomplish our interest – namely engagement. This extension is largely symbolic, given the President already has the authority to impose these sanctions and these sanctions are being waived under the nuclear deal. However, the ISA renewal could pose real consequences. 

Some argue renewing ISA is necessary to send a message that the U.S. will impose sanctions if Iran violates the nuclear deal, but this was never up for question. The real uncertainty that threatens the nuclear deal is the open question as to whether the U.S. will fully implement its sanctions relief obligations as required under the deal. It is a question being asked by U.S. partners in Europe and elsewhere, inside Iran, and among commercial interests who have not engaged Iran as anticipated because of political uncertainty and challenges posed by sanctions. Especially considering the current political situation in the US, passing ISA exacerbates that uncertainty. 

Lawmakers and the Obama Administration, as well as the incoming Administration, must now make it clear that – even if ISA is renewed – the U.S. will uphold the terms of the nuclear agreement. This includes lifting all nuclear-related sanctions by October 2023 and taking necessary steps to address lingering obstacles to sanctions relief. 

 

There were concerns that Congress would attach new sanctions to the ISA renewal in violation of the deal, which has been avoided. Unfortunately, we are now still faced with a situation in which Iran is likely to retaliate against what it perceives to be a U.S. violation of the JCPOA. By agreeing to a clean extension of the Iran Sanctions Act, some may have believed Iran could be baited into taking responsive action putting at risk the nuclear accord. They may not be wrong. Iran has long signaled that it would impose counter-measures against the United States should ISA be re-authorized. It wouldn’t be surprising if Iran does take certain measures that could be in violation of the spirit of the nuclear deal. Those interested in protecting the Iran nuclear deal and preventing war and the spread of nuclear weapons must now redouble their efforts to ensure that the deal is fully implemented on all sides, including by avoiding a tit for tat escalation and by taking necessary action to ensure sanctions relief moves forward as required.