Morteza Nikoubazi / REUTERS Iran's national flags are seen on a square in Tehran a day before the anniversary of the Islamic Revolution, February 2012.

The Challenge of Reinstating Sanctions Against Iran

It’s Not as Simple as Withdrawing From the JCPOA

U.S. President Donald Trump appears to be on the brink of withdrawing the United States from the Joint Comprehensive Plan of Action (JCPOA), the landmark 2015 nuclear agreement with Iran. He faces a May 12 deadline to renew waivers of key U.S. sanctions on Iran, and despite pressure from French President Emmanuel Macron and German Chancellor Angela Merkel to do so, Trump seems set to deliver on his January threat to stop waiving sanctions and to kill the deal.

JCPOA critics inside and outside the administration assume that the simple act of letting U.S. sanctions waivers lapse will result in crippling economic pressure on Iran. This pressure, they argue, will give Washington leverage to renegotiate the deal’s limits on Iran’s nuclear program and to press Tehran to curb its support for Syrian Hezbollah and other malign activities throughout the Middle East.

The reality of how sanctions work, however, is far more complicated. It took the combined efforts of Congress and two U.S. presidents—George W. Bush and Barack Obama—nearly a decade to cripple Iran’s economy. Rebuilding economic pressure after Washington pulls out from the JCPOA would be an even greater challenge, given international opposition to the U.S. withdrawal and scant international support for renewed sanctions. The result could be a “win-win” situation for Iran, in which it is both freed from the JCPOA’s constraints on its nuclear activity and able to retain at least part of the sanctions relief for which it bargained.

A RECIPE FOR CHAOS?

Trump would face formidable challenges after withdrawing from the JCPOA. The first would be to establish a legal structure to reinstate sanctions against Iran. Sanctions imposed by the United States on Iran prior to the JCPOA were one of the most complex sets in U.S. history, comprising multiple statutes, roughly a dozen executive orders, and hundreds of pages of federal regulations. In implementing the JCPOA, the Obama administration rewrote federal regulations, removed more than 400 Iranian

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