Atlantic Council SOUTH ASIA CENTER

IRAN TASK FORCE BY CORNELIUS ADEBAHR Easing EU Sanctions on Iran JUNE 2014

Progress in the international negotiations with Iran on the country’s nuclear program has increased the Atlantic Council Iran Task Force urgency to think through scenarios deemed highly unlikely only a year ago: How can the international community sensibly lift the sanctions it has imposed on comprehensiveThe Iran Task Force, analysis launched of Iran’s in 2010internal and political chaired Iran? This question is particularly pertinent for both the landscape,by Ambassador as well Stuart as its Eizenstat, role in the performs region and a the United States and the European Union (EU), which have world, to answer the question of whether there are established their own set of sanctions that go beyond elements within the country and region that can the measures agreed to by the United Nations. Those build the basis for an improved relationship with “autonomous” measures target not only the Iranian nuclear program but also Iran’s broader economy. could be utilized by US policymakers. the West and how these elements, if they exist, This paper looks at sanctions imposed by the EU directed at Iran’s nuclear activities and presents a scenario for how sanctions relief could play out should generouslyThe Iran Task by Forcea grant is froma project the Ploughsharesof the Atlantic Fund. a comprehensive agreement be reached. Council’s South Asia Center, and is supported the Treaty on European Union. Over the years they The EU’s Sanctions Architecture have been applied to support democracy and the rule While economic sanctions have a long—and disputed— history in foreign policy, the EU formally acquired transitions, to counter the proliferation of weapons of this tool only in 1993 with the Maastricht Treaty and of law, to enable conflict management and democratic the emergence of a Common Foreign and Security Policy (CFSP). Prior sanctions were based on loose massOnce adestruction, legally binding and Council to fight decisionterrorism. to impose coordination between member states’ foreign policies certain sanctions has been made, it may need further rather than on a common position agreed to after involvement from the European Commission or the deliberations in Brussels. twenty-eight member states. The Commission, as the EU’s main administrative body, is responsible for The legal basis for “restrictive measures,” as sanctions a directly applicable Council regulation. Member states, inimplementing contrast, need economic to implement or financial arms measuresembargos byand way visa of are officially1 called in EU jargon, is a combination However, it has remained established bans, as such restrictions fall within their competence. practiceof Treaty that articles any decisionallowing tofor impose a vote byor lifta “qualified sanctions is majority.” taken unanimously. additional step, there have never been instances where Although this involvement formally constitutes an Sanctions need to aim at the realization of the EU’s a Council decision has not been implemented through Commission or member states mechanisms.

Furthermore, the EU’s sanctions apply only to the EU’s foreign policy objectives as defined by Article 11 of 1 their effect. This is in stark contrast to the United States, Article 29 of the Treaty on European Union (TEU) in conjunction jurisdiction, thus ruling out the extraterritoriality of votingwith Article for such 215 decisions. of the Treaty on the Functioning of the European Union (TFEU). Article 31 Nr. 2 TEU establishes qualified majority where financial sanctions such as those of the 2010 Cornelius Adebahr is an associate in the Europe Program at the Carnegie Endowment for International Peace. His research focuses on European foreign policy. Comprehensive Iran Sanctions, Accountability, and Germany—in 2006 as a consequence of the referral Divestment Act (CISADA) targeted any bank that deals of the Iran case from the International Atomic Energy with designated Iranian financial institutions, regardless solveAgency the (IAEA) question to the of Iran’sUN Security nuclear Council program can per be se,seen of whether it is under US territory or jurisdiction. as another diplomatic success. Although it did not imposition of sanctions and their removal requires Russia, and, crucially, the United States (hence the EU’s merelyAgainst one this ingredient: background, the it politicalis fair to willsay thatof member both the the joining of the three European powers with China, states. With a unanimous Council decision, the EU can approach more weight. preferred acronym E3+3) lent the European diplomatic or lift altogether any of the sanctions it has imposed The “EU way” of continuously pushing for diplomacy sosuspend far. In (indefinitelyother words, orunlike for a the pre-determined US government, period) the with Iran while over time being more willing to accept sanctions as a coercive measure constituted the so- have to deal with a Congress. called dual- or double-track approach. It was motivated Council, as the EU’s foreign policy executive, does not by a desire to avoid another, possibly devastating, Diplomacy and Sanctions: The “Double- Middle East war, to prove the usefulness of diplomacy Track” Approach

Iran in the wake of the Islamic Revolution of 1979 and effective multilateralism and to justify Europe’s 4 andWhile the the hostage US imposed crisis, itsthe first EU andset ofits sanctions member statesagainst Twoown global Waves role, of especially Sanctions in a field against of hard Iran security. maintained normal, if restrained, relations with Iran for more than two decades after those events. Rather than on Iran was Resolution 1737 passed in December sanctioning Iran, the EU aimed at winning the country The first UN Security Council act imposing sanctions over through dialogue2 and cooperation: it began a resolution banned the supply of nuclear technology and2006. related Acting materials under Chapter to Iran VII and of froze the UN the Charter, assets of the individuals and organizations involved in the enrichment years“critical later dialogue” after the with election the Iranian of the reformistregime in President1992, Mohammadwhich turned Khatami. into a “comprehensive3 dialogue” five againstprogram. Iran Security by using Council “targeted” Resolutions sanctions 1747 aimed in 2007 at Iran’s and 1803 in 2008 further increased the restrictive measures EU and its member states translated these regulations After the uncovering of Iran’s hitherto clandestine intonuclear EU sanctions,activities. Asoften bound going by beyond international the scope law, of the gears.nuclear The activities E3—France, in August Germany, 2002 andand thethe USUnited invasion the UN measures. Kingdom—startedof Iraq in March 2003, a diplomatic however, initiativethe Europeans leading shifted to the was accompanied5 by a general policy of increasing discouragement of Thiscompanies first phase to do of business EU sanctions with Iran (though with variance among member states). onlyParis for and delaying Tehran Iran’sDeclarations nuclear of progress 2003 and but 2004. also forThese their broaderagreements approach were hailed to security as a major and regional breakthrough development. not However, they unravelled quickly over the question of whether Iran had a right to the full fuel cycle, including Building on the latest This Iran second resolution phase, 1929 lasting of theuntil UN Security Council of6 June 2010, the EU began to broadly enrichment activities, the EU’s focus shifted toward extend its actions. internationalenrichment. When unity byrather early than 2006 bilateral Iran had talks resumed with Iran. its Especially the latter point also underscores the important “reputational dimension” of the imposition of sanctions. 4 Francesco Giumelli and Paul Ivan, The Effectiveness of EU Sanctions: An Analysis of Iran, Belarus, Syria, and Myanmar permanent members of the UN Security Council plus (Burma) In that sense, the formation of the “P5+1”—the five http://www.epc.eu/ , EPC issue paper no. 76 (Brussels: European Policy effectiveness_of_eu_sanctions.pdfCenter (EPC), November 2013), p. 2,; Dina Esfandiary, Assessing the Europeandocuments/uploads/pub_3928_epc_issue_paper_76_-_the_ Union’s Sanctions Policy: Iran as a Case Study 2 Joakim Kreutz’s comprehensive 2005 publication on the EU’s ht t p:// Yugoslaviasanctions policy and Zimbabwe, from 1981 but to 2004 refers analyzes to Iran only past for and a presentshort www.nonproliferation.eu/documents/nonproliferationpapers/ periodmeasures during against the Iran-Iraqcountries war.from Joakim Argentina Kreutz, and HardAfghanistan Measures to by (Non-Proliferation Consortium, December. 2013), pp. 3-4, a Soft Power? Sanctions Policy of the European Union 1981-2004 dinaesfandiary52b41ff5cbaf6.pdf 5 3 Council Common Position 2007/140/CFSP of February 27, 2007, (Bonn: Bonn International Center for Conversion, 2005). complemented by Council Regulation (EC) No 423/2007 of April The EU officially opened talks on a Trade and Cooperation 19, 2007, were the EU’s first restrictive measures against Iran. Agreement in 2001 and, as late as December 2002, also on a 6 Council Decision 2010/413/CFSP of July 27, 2010, and Council Political Dialogue Agreement. Implementing Regulation (EU) No 668/2010 of July 26, 2010.

2 ATLANTIC COUNCIL These included Iran’s continued intransigence and a further restrictions on Iranian banks and prohibiting mid-2013, came about due to a number of factors. Additional sanctions followed half a year later, putting election;failed fuel and swap the deal discovery in 2009/10; of the theclandestine Iranian prolonged enrichment ship-buildingimports of Iranian equipment gas and or exports technology. to Iran11 of graphite, sitecrackdown at Fordow on protestsnear Qom following as well as the Iran’s 2009 increase presidential of semi-finished metals, such as aluminium and steel, and a renewed and stiffened E3 commitment, with France comprehensive sanctions regime it had ever imposed, andenrichment the UK now to 20 overtaking percent U-235. the United These States trends in sparked pushing aBy veritable 2013, the embargo EU had targetingput in place the the original broadest sectors and ofmost for new tough sanctions. Finally, the EU tied its efforts to nuclear research and missile technology as well as the the credibility of the Non-Proliferation Treaty, which it is determined to preserve. and targeting individuals involved in either the nuclear arms trade, inhibiting trade and financial interactions that year, the EU had frozen the assets of and imposed investing in the Iranian oil and gas sector, including program or closely linked to the regime. At the end of theIn June provision 2010, theof “key” EU banned equipment European and any companies type of from 12 government support for trade with Iran, and put heavy Howtravel bansthe onEU 490 and entities the United and 150 individuals.States Could Lift Sanctions including insurance. Taken together, these measures set offrestrictions a self-reinforcing on most typesmechanism of financial of “over-compliance.” transactions, the election of President Hassan Rouhani in June With naturally risk-averse legal departments keeping After two waves of sanctions over seven years, companies refused even to trade in goods that were suspension2013 ushered following in a period the interimof renewed agreement and serious negotiated an eye on the extra-territoriality of US legislation, many7 negotiations. This led to the first round of sanctions exempted from sanctions such as medicine and food. inWith Geneva a view in toNovember a potential 2013. comprehensive deal in the voicedA major concern round of about sanctions a lack followed of cooperation in January from and Iran need to be made at this point: First, who should lift inMarch clarifying 2012, outstanding after a November issues 20118 and theIAEA US report Congress whichoffing forsanctions the summer and, second, of 2014, in two what basic sequence? considerations imposed new sanctions on Iran’s Central Bank. The EU imposed an oil embargo, prohibited insuring the It is crucial that any sanctions relief be synchronised transport of Iranian oil, and froze the Central Bank of between the EU and the United States. The autonomous Iran’s assets in the EU.9 Crucially, it also banned the reinforced each other: the European oil import ban entities, cutting off Iranian banks from the worldwide wassanctions impactful imposed because, in 2012 at the and same early time, 2013 the mutually United SWIFTprovision network. of financial Once messaging denied access services to the to company listed States pressured Iran’s non-Western clients such as facilitating most international bank transfers, Iranian India, South Korea, Japan, and China to reduce their as non-Western currencies or barter trade, greatly indirect or U-turn dollar transactions became much increasingbusinesspeople their hadtransaction to find alternative costs. channels such moreown crude powerful purchases. once the Similarly, EU had shutthe American off Iranian ban banks on 10 sanctions. 7 On the communicative dimension of the drug shortages issue, see from the international financial system with its SWIFT Tehran Calling: Understanding a New Iranian Not least because of the secondary effects of many US Leadership sanctions, a lifting of EU sanctions alone is not enough. Cornelius Adebahr, . 8 (Brussels: CarnegieImplementation Europe, January of the 2014), NPT Safeguards p. 17, Agreementhttp://carnegieendowment.org/files/tehran_calling.pdf and Relevant Provisions of Security Council Resolutions that would invest in or trade with Iran that does not at in IAEA the IslamicBoard ofRepublic Governors, of Iran , report by the Director General theAs it same happens, time therealso have is hardly an interest any European in the US company market.

http://www.iaea.org/newscenter/ GOV/2011/65 (Vienna: International Atomic Energy Agency focus/iaeairan/iaea_reports.shtml. That is why European firms would not do business with 9 (IAEA), November 8, 2011), 11

Council Decision 2012/35/CFSP of January 23, 2012, and Council Decision 2012/635/CFSP of October 15, 2012, and subsequent Council Regulation (EU) No” Financial 267/2012 Times of March, May 23, 7, CouncilRuairi Patterson, Implementing “EU SanctionsRegulation on (EU) Iran: No The 945/2012 European of OctoberPolitical 2012. http://www.ft.com/intl/ 15, 2012. Middle East Policy 10 “Iran Accepts Renminbi for Crude Oil, 12 2012, . Context,” , spring 2013, vol. 20,. no. 1, p. 136, cms/s/2/63132838-732d-11e1-9014-00144feab49a. http://mepc.org/journal/middle-east-policy-archives/ html#axzz331B2ov8m eu-sanctions-iran-european-political-context

ATLANTIC COUNCIL 3 Iran as long as the specter of liability looms over their activities in the United States. thewant United to have States lifted in first, particular, and what ease is byit willingwhich meansto deliver and Such interdependence rules out any compensatory onfor whichthem? timescale?Conversely, which measures can the P5+1, and additional lifting of EU sanctions for an eventual US failure to live up to its own commitments. Thus, for reasons of political symbolism as much as economic necessity, any lifting of sanctions will have to be The interim agreement or Joint Plan of Action (JPA) coordinated between the transatlantic partners. accordreached established in November a “reciprocal, 2013 and implemented step-by-step process”starting whereJanuary sanctions 2014 can relief be instructive was meant in to that be regard.commensurate This On the second consideration, there could be two with Iranian actions to make its nuclear program more different approaches to the sequencing of sanctions transparent.

Temporary Suspension of EU and US lifting. The first is anti-chronological, going backward deconstructing a house made of bricks, this should allow Sanctions Under the JPA in time to lift the most recent sanctions first. Like for a gradual reversal of the punitive measures in place. In return for Iran’s suspension of certain nuclear The problems with this approach, however, are both activities, the EU lifted a number of restrictive measures, political and technical. They are political because some including the import ban on petrochemical products, of the more recent sanctions are, unsurprisingly, also the prohibition on the transport of Iranian crude oil, the the heaviest ones. They form the core of the sanctions ban on trade in gold and precious metals, and the ban on the supply of certain vessels to Iran. In addition, the EU temporarily increased the thresholds on transfers of architecture that the P5+1 would want to leave intact for funds to and from Iran and unfroze a limited amount of 13 long-terman extended nuclear period agreement. of time, until they are certain that funds and economic resources. Iran has actually complied with the major elements of a The technical side has to do with the interdependence One lesson of this initial suspension of European and of individual measures, both old and new, that has developed over time. Where recent sanctions build on American sanctions is that there seem to have been previous ones, lifting only the newer parts while leaving the effects of the limited sanctions relief. Whereas Iran differing expectations between Iran and the P5+1 about the old regulations in place is unlikely to convince was banking on a positive economic momentum beyond businesses to resume activities. This would be the case of the restrictions lifted and agreed payments made, the removing the embargo on key equipment and technology United States was eager to stress that Iran was still for petrochemicals which was passed after the same ban “not open for business.” Because economic sanctions 14 relating to the oil and natural gas industries. leverage the private sector, their removal can only be effective if the private sector reacts accordingly. The second approach to sanctions lifting revolves around the broad areas of sanctions listed below. In this sense, the strategy could be to start undoing sanctions in companies were hesitant to use the limited freedoms Following the entry into force of the JPA, however, certain areas—e.g., restrictions on trade and transport granted, in the face of both the limited time frame of as well as asset freezes—while retaining them in a comprehensive deal could be achieved. Even a deal approvedsix months by and the the US overallgovernment uncertainty on aircraft over maintenancewhether others—e.g.,This again may financial not achieve and nuclear-related.the goal of actual sanctions did not come about because the time frame to set up the relief for similar reasons. Most importantly, certain was deemed too short. messaging (SWIFT) and on dollar transactions—virtually deal, execute it, and get15 paid before the July 20 deadline cutfinancial off Iran sanctions—such from international as the markets, ones on thus financial rendering impossible even authorized dealings. Conversely, the 13 Council Decision 2014/21/CFSP of January 20, 2014, and front because of their importance in maintaining pressure subsequent Council Regulation (EU) No. 42/2014 of January 20, P5+1 would not want to lift all financial sanctions up Thing,”2014. Global Public Square ht t p:// 14 Cornelius Adebahr, “Why Western Business Eyeing Iran Is a Good duringIn the end, the implementationthe sequencing ofphase sanctions of the relieffinal agreement. will business-eyeing-iran-is-a-good-thing/ (blog), CNN,. February 14, 2014, be decided not based on a particular rationale but globalpublicsquare.blogs.cnn.com/2014/02/14/why-western-Barbara Slavin, “Iran Not Getting Sanctions Relief It Was Promised,” Al-Monitor http://www.al-monitor.com/ depending on the demands, needs, and possibilities of 15 the negotiation partners: Which sanctions does Iran program.html. , April 8, 2014, pulse/originals/2014/04/iran-no-sanctions-relief-nuclear-

4 ATLANTIC COUNCIL What is thus clear is that restrictions waived on a short- • delisting a number of persons and entities from term basis are unlikely to satisfy Iran for both political travel ban lists. and practical reasons. Politically, the Iranian government is bent on reciprocity and proportionality, meaning The need for the EU and the United States to move in that “irreversible” steps on their side would have to be tandem when lifting or suspending their sanctions matched by such steps on the other side. The key word here is the “lifting” rather than mere “suspending” of which has been more inclined to pass additional points to the difficulties posed by a reluctant Congress, dislike such short-term prospects for the very practical the administration can get around this by using lessonssanctions, learned as referenced from the in implementation the JPA. In addition, of the Iran interim will sanctions than to revoke existing ones. To what extent agreement. part of the ongoing debate in Washington. Current analysisexecutive has powers shown such that as the the US presidential president will waiver, be able is to The different interpretations on the two sides of the mentioned areas: a comprehensive deal is reached may create a much use his executive authorities16 in nearly all of the below- biggerAtlantic political of the benefits fall-out ofbetween doing business the EU and with the Iran United once • to allow Iranian access to the oil markets under a States than the subdued disagreements that surfaced comprehensive nuclear settlement, the US president

worldwide purchases of Iranian crude oil.17 He has mayin early lead 2014. their At negotiators the same time,to demand the dissatisfaction more nominal on would have to indefinitely suspend sanctions on the reliefthe Iranian in addition side with to the the setting immediate of an effectsoverall ofpositive the JPA but would have to continue to waive penalties for environment free of uncertainties about doing business done so already for the implementation of the JPA with the country. • consecutiveaccording to periods the same of waiver120 days; provision, he can Sanctions Lifting as Part of Final Deal “unlock” hard currency payments for Iranian crude Given that the ultimate plan on how to lift which held in banks abroad; and sanctions is very much part of the ongoing negotiations, • penalties on foreign banks for transactions with a few general assumptions can be made. sanctioned Iranian banks imposed under Section First, it is the “autonomous” sanctions by the EU and the United States which Iran would like to see lifted sooner secretary of the treasury determines that such a 104 of CISADA can be waived indefinitely if the rather than later. Then, for symbolic reasons, the UN waiver is in the US national interest or otherwise Security Council could reverse some of its sanctions in describes the reasons for a determination in a order to recognize the signing of the comprehensive report to the appropriate congressional committees. deal. For a full lifting of those multilateral sanctions, In addition, some US sanctions legislation contains a naturehowever, of allIran’s open nuclear issues program between needs Iran and to be the restored. IAEA sunset clause such as the Iran Sanctions Act (ISA), which need to be resolved and full confidence in the peaceful applyingexpires at these the end sanctions of 2016 through unless Congressthe use of decides waivers to extend it. Thus, in principle the US president could avoid is likely to be on four areas: Building on the JPA, the focus for an easing of sanctions (or use his or her veto if the members of Congress • allowing for the import of Iranian oil and gas, thus wentwhile aheadworking anyway). with Congress Such a provision to allow thecould Act be to tied expire providing Iran with fresh—and much needed— into a phased implementation of the comprehensive agreement, where the US president commits to technology as well as investments in those sectors; income, and for export to Iran of respective commitments for this period. • suspend sanctions until Iran has verifiably fulfilled its revenues held abroad; Given that sustainable sanctions relief ultimately unfreezing an estimated $100 billion in Iranian oil needs congressional action, one possibility would be • to introduce new legislation, e.g., an Iran Sanctions insurance and lifting sanctions broadly in the area of theeasing civilian the restrictions economy, e.g., on tradefinancial in precious transactions metals, and bank notes, bond trades and loans, the automotive and Nuclear Safeguards and Verification Act (ISNSVA). and shipbuilding industry, as well as specialized 16 training; and 17 Kenneth Katzman, “Easing US Sanctions Against Iran,” Atlantic Council, June 2014. As contained in Section 1245 of the FY2012 National Defense Authorization Act (NDAA).

ATLANTIC COUNCIL 5 sanctions legislation vis-à-vis Iran, minus those regulationsThis law would that consolidate are to be lifted. all existing Not only nuclear-related would this provide substantial sanctions relief in the areas agreed upon at the negotiation table, it might also be more acceptable to a Congress bent on appearing to remain tough on Iran.

presupposes a level of cooperation between Congress andAlthough the White fairly House attractive that inhas theory, not been this onoption display recently on the Iran sanctions issue. It is much more likely that Congress will acquiesce to President Barack Obama’s issuance of waivers to uphold his negotiation commitments while refusing to provide the certainty of permanent sanctions relief through legislation.

The described possible lifting of a number of measures notwithstanding, some elements of the EU sanctions architecture probably will also remain in place for quite

comprehensive agreement, including: some time, until or closer to the expiration date of the • sanctions on sales to Iran of any technology that could be used in Iran’s nuclear, other WMD, or conventional weapons programs;

• inspections of cargo and restrictions on airport access;

•

• certainthe arms financial embargo; restrictions; and • restrictions on businesses relating to the Iranian Revolutionary Guard Corps.

Conclusion While a successful lifting of sanctions in the face of overall compliance represents a “good” outcome, an unravelling of the deal due to Iran’s noncompliance would certainly be a “bad” result. The truly “ugly”— however, not at all unlikely—outcome would be failure over an inability by the United States to deliver meaningful sanctions relief.

Ultimately, it may be an irony of history that, after years of US pressure on its European partners to do their part in imposing sanctions, it would now be up to

to eventually lift sanctions. What could in the future possiblythe EU to be push regarded Washington as proof to offulfill the itsoft-denounced commitments usefulness of harsh economic sanctions should not crumble over the failure of one party to undo its powerfully restrictive measures.

6 ATLANTIC COUNCIL EU Sanctions on Iran

Nuclear and missile technology The EU embargoes certain goods and technology which could contribute to enrichment-related, reprocessing, or heavy water-related activities, to the development of nuclear weapons delivery systems, or to the pursuit of

Arms activities related to other topics about which the IAEA has expressed concerns (“dual-use goods”). The EU embargoes all sales of arms and related materiel (including certain chemicals, electronics, sensors and lasers, navigation and avionics), including a ban on the provision of related services and investments. Financial transfers and international assistance The EU has generally restricted the transfers of funds to and from Iran, with limited easing provided during the

implementationPayments may be of authorized the JPA. It hasif related imposed to foodstuffs, control of healthcare,transactions medical of (and equipment, vigilance requirements agricultural orfor) humanitarian EU financial institutions with banks domiciled in Iran and their subsidiaries, branches and other financial entities outside Iran.

purposes, personal remittances, a specific trade contract, a diplomatic or consular mission or an international organizationThe EU imposed enjoying a ban immunities,on the provision claims of specializedagainst Iran, financial or to certain messaging specified services exemptions. of funds and economic resources (cutting Iranian banks from the SWIFT network) and prohibited to satisfy claims made by listed persons, entities or bodies. It further restricts the establishment ofto branches those subjected and subsidiaries to the freezing

insurance), and the issuance of and trade in certain bonds. of and cooperation with Iranian banks, the provision of insurance and re-insurance (except health and travel The EU bans any new commitments for grants, financial assistance, and concessional loans to the government of Iran as well as the provision of new Iranian banknotes and coins. Energy The EU bans the import, purchase, and transport of oil, petroleum, and natural gas products as well as related finance, insurance and services or technical assistance. It also embargoes key equipment and technology for the oil and natural gas industries. The EU prohibits the construction of new oil tankers for Iran and bans the provision of

flagging and classification services to certain vessels. A ban on the supply of certain vessels to Iran has been lifted for the duration of the implementation of the JPA. Trade and investment The import ban on petrochemical products has been lifted for the duration of the implementation of the JPA. The EU prescribes “vigilance” over any business with Iran, especially with business entities of the IRGC and of the export controls for sensitive goods and technology, including related services and investment. Islamic Republic of Iran Shipping Lines. It has imposed The EU has banned trade in gold, precious metals, and diamonds with the Government of Iran, which has been

lifted for the duration of the implementation of the JPA.Transport Still in place are measures to prevent certain specialized teaching or training, as well as a ban on member states’ commitments for financial support for trade with Iran. The EU requires prior information about and inspection of all cargoes to and from Iran, further restricting access to

EUIt bans airports the provision for certain of certaincargo flights. services (such as flagging and classification) to certain vessels and aircraft, and embargoes key naval equipment and shipbuilding technology, including related services. Asset freezes The EU has frozen the funds and economic resources of listed persons, entities, and bodies

. Specific exceptions have been made for the Central Bank of Iran, Bank Tejarat,Travel and thebans accounts of diplomatic missions and international organizations. In addition, some individuals have been delisted for the duration of the implementation of the JPA. The EU has issued a number of travel bans against individuals restricting the admission to the EU of listed natural persons.

ATLANTIC COUNCIL 7 Atlantic Council Board of Directors

CHAIRMAN Conrado Dornier Franklin C. Miller Mary C. Yates *Jon M. Huntsman, Jr. Patrick J. Durkin James N. Miller Dov S. Zakheim PRESIDENT AND CEO Thomas J. Edelman HONORARY *Frederick Kempe Thomas J. Egan, Jr. DIRECTORS *Stuart E. Eizenstat *Judith A. Miller VICE CHAIRS Thomas R. Eldridge *George*Alexander E. Moose V. Mirtchev Julie Finley GeorgetteObie L. Moore Mosbacher David C. Acheson *Richard Edelman Bruce Mosler Madeleine K. Albright *C.*Robert Boyden J. Abernethy Gray Harold Brown Thomas R. Nides FrankJames C.A. Carlucci,Baker, III III Lawrence P. Fisher, II Michèle Flournoy Franco Nuschese Robert M. Gates Alan H. Fleischmann *Ronald M. Freeman Sean O’Keefe Michael G. Mullen *Richard L. Lawson *Robert S. Gelbard Hilda Ochoa-Brillembourg *John*Virginia Studzinski A. Mulberger *Sherri W. Goodman *W. DeVier Pierson William J. Perry TREASURER *Stephen J. Hadley Leon E. Panetta Ahmet Oren *Brian C. McK. Henderson Mikael Hagström Thomas R. Pickering Condoleezza Rice Ian Hague Ana Palacio SECRETARY Colin L. Powell John D. Harris II George P. Shultz *Walter B. Slocombe *Andrew Prozes Frank Haun JohnEdward W. WarnerL. Rowny DIRECTORS Arnold L. Punaro Rita E. Hauser Joseph W. Ralston William H. Webster TeresaKirk A. M.Radke Ressel LIFETIME DIRECTORS Stephane Abrial Michael V. Hayden Charles O. Rossotti Odeh Aburdene Annette Heuser StanleyJeffrey A. O. Rosen Roth Peter Ackerman KarlMarten Hopkins H.A. van Heuven Robert Rowland DanielCarol C. J. Adelman Callahan, III Timothy D. Adams RobertJonas Hjelm Hormats Harry Sachinis BrianLucy Wilson Dailey Benson John Allen William O. Schmieder Kenneth W. Dam *Michael Ansari Robert E. Hunter John P. Schmitz Richard L. Armitage Wolfgang*Mary L. Howell Ischinger Stanley Ebner Elizabeth*Adrienne F. Arsht Bagley Reuben Jeffery, III ChasLacey W. Neuhaus Freeman Dorn SheilaDavid D.Bair Aufhauser Robert Jeffrey JohnAnne-Marie M. Spratt, Slaughter Jr. Carlton W. Fulford, Jr. JamesAlan J. StavridisSpence Edmund P. Giambastiani, Jr.

Julia*Rafic Chang Bizri Bloch Stephen*James L. R. Jones, Kappes Jr. James B. Steinberg Barbara Hackman Francis*Thomas Bouchard L. Blair MariaGeorge Pica A. Joulwan Karp *PaulaRichard Stern J.A. Steele FranklinJohn A. Gordon Myron Brilliant Francis J. Kelly, Jr. Robert J. Stevens *R. Nicholas Burns Zalmay M. Khalilzad John S. Tanner Roger Kirk *Richard R. Burt Robert M. Kimmitt Peter J. Tanous GeraldineRobert L. Hutchings S. Kunstadter Michael Calvey *Ellen O. Tauscher James P. Mccarthy Peter Kovarcik Karen Tramontano Jack N. Merritt James E. Cartwright FranklinHenry A. D.Kissinger Kramer Clyde C. Tuggle Ashton B. Carter Paul Twomey William Y. Smith Wesley K. Clark Philip A. Odeen JohnAhmed Craddock Charai Philip Lader David W. Craig Henrik Liljegren CharlesMelanne F. Verveer Wald Marjorie Scardino Tom Craren *Jan M. Lodal JayEnzo Walker Viscusi William H. Taft, IV *Ralph D. Crosby, Jr. *John*George D. MacomberLund Michael F. Walsh TogoRonald D. P.West, Verdicchio Jr. Nelson Cunningham Jane Holl Lute Mark R. Warner R.Carl James E. Vuono Woolsey Ivo H. Daalder Wendy W. Makins J. Robinson West Gregory R. Dahlberg MianIzzat MajeedM. Mansha John C. Whitehead Committee *Paula J. Dobriansky William E. Mayer Members*Members of the Executive Christopher J. Dodd Eric D.K. Melby ^ International Advisory Board David A. Wilson Maciej Witucki List as of May 21, 2014 Thetoday’s Atlantic global Council ­challenges. is a nonpartisan organization that ­promotes constructive US leadership and engagement in ­international ­affairs based on the central role of the Atlantic community in ­meeting be reproduced or transmitted in any form or by any means without permission in writing from the © 2014 The Atlantic Council of the United States. All rights reserved. No part of this publication may Please direct inquiries to: Atlantic Council, except in the case of brief quotations in news articles, critical articles, or reviews. 1030 15th Street, NW, 12th Floor, Washington, DC 20005 (202) 778-4952, AtlanticCouncil.org