By Edward Carney
Since the beginning of April, the White House has taken highly significant, incremental steps toward the realization of its goal for “maximum pressure” on the Iranian regime. In the first place, the Trump administration announced that it was designating the Islamic Revolutionary Guard Corps as a foreign terrorist organization and imposing sanctions on most individuals and entities that provide it with material support. And about two weeks later, the administration announced that waivers for eight foreign importers of Iranian oil would not be renewed after their expiration on May 2nd.
But amidst the international dialogue over this measures, Al Monitor published an article on Wednesday which suggested that the Islamic Republic might be affected even more seriously by an action that may still be forthcoming. The article explained: “US national security adviser John Bolton and a group of hawkish lawmakers in Congress are agitating for the Trump administration to cancel three key waivers issued in November 2018, when the United States re-imposed secondary sanctions on Iran.” The waivers allow signatories to the 2015 nuclear deal to engage in technical work at three key sites in Iran’s nuclear program.
Such foreign collaboration ostensibly serves to help the Islamic Republic undertake actions that will make it better able to comply with the terms of the Joint Comprehensive Plan of Action while still advancing the development of a civilian nuclear program. But from the perspective of Bolton and others, perhaps including President Donald Trump himself, the waivers no doubt represent an undesirable safeguard on the implementation of an agreement that the US pulled out of in May of last year.
The Al Monitor article further explained that because the relevant technical work is left up to commercial enterprises, the waivers represent a blind spot in the provisions for multilateral enforcement of the Joint Comprehensive Plan of Action. Following the American withdrawal, the remaining signatories have been working to keep the agreement in force, with the E3 – France, Germany, and the United Kingdom – even going so far as to establish a “special purpose vehicle” for avoiding US sanctions on transactions with Iran. But this mechanism has yet to become truly functional, and many observers doubt both the willingness and the ability of the European nations to openly defy US sanctions.
If the White House elects to withdraw the relevant waivers, it could precipitate the complete collapse of the JCPOA. As evidenced by the widespread compliance with sanctions on Iran’s oil economy, it is extremely unlikely that any commercial enterprise with interests in the US would accept the risk of doing business with Iran in the nuclear sphere. And in absence of existing supports for Iran’s permissible nuclear work, the nation’s leadership may finally abandon an agreement that it has already been complaining bitterly about.
To date, those complaints refer primarily to the Islamic Republic’s supposed inability to take full advantage of the initial sanctions relief and subsequent explorations of trade partnerships in the West. And naturally those complaints have accelerated over the past year. Even without support from the E3, China, and Russia, the pressure emanating from Washington has helped to drive Iran into its worst recession since 2012.
Even so, the White House remains reasonably far away from achieving its goal of maximum pressure, for which the participation of European allies would surely be necessary. The removal of waivers on nuclear collaboration could leave those allies with little other choice in the matter. And furthermore, the Trump administration’s argument for maximum pressure may be strengthened by ongoing reports about the effect of sanctions upon the regime’s various malign activities, including its support of terrorism.
On Wednesday, Bloomberg reported that Hassan Nasrallah, the head of the Iran-backed Lebanese paramilitary Hezbollah, had begun appealing to the local population to donate money for the group’s budget, in anticipation of crucial Iranian support being lost as new sanctions take hold. The same report noted that Iran’s Oil Minister Bijan Zanganeh had echoed the regime’s defiant talking points by saying Tehran would “act wholeheartedly to break U.S. sanctions” and continue the flow of capital to Iranian partners and allies. But this may be all the more difficult to achieve if the US first breaks the already tenuous ties between the Islamic Republic and vital Western markets.