Requirements of actual verification of lifting sanctions

These indicators include complete normalization of whole banking relationships, complete removal of export barriers, free sale of Iranian oil and oil products, and complete and quick return of [foreign] currency from there. Furthermore, according to Article (7) of the same act, the government (Executive power) must report to the Parliament on sanctions lifting, where the relevant Commissions of the Parliament have to make their evaluation of the government’s report. These two articles together imply that economic benefits must accompany the lifting of sanctions, and these benefits should be verified precisely and measurably.

What matters now is what criteria and indicators should be used to verify whether the Iranian economy benefits from the lifting of sanctions. In another report entitled “Managing the country’s economy in the face of sanctions; the need to plan the national economy with the assumption of the continuation of sanctions” in detail and briefly in the present report, it is explained that the United States – As in the past- will use various economic, political and legal means that even if sanctions are lifted legally, it will still prevent Iran’s economy from benefiting out of sanctions relief.

It is important to note that the use of a mere legal approach to lifting the sanctions from a legal standpoint —the privative approach— is a strategic mistake and will not lead to Iran’s economic benefit when the United States of America, due to its lack of serious will to lift sanctions, is trying to increase the risk of economic cooperation with Iran by employing various means. Compiling extensive lists of US sanctions against Iranian individuals and legal entities and insisting solely on the legal lifting of these sanctions can be regarded as signs of this flawed privative approach. The following are some of the reasons for the lack of success in adopting a mere legal approach to lifting sanctions:

A.legal evasions and placing obstacles in the way of the authentic lifting of sanctions by the united states;

Completion of the legal infrastructures related to sanctions and their permanent nature,

Intertwining nuclear and non-nuclear sanctions and imposing regulation to make the sanctions on Iran inseparable,

Official and bipartisan acknowledgement by US officials of the need to conclude a new comprehensive agreement with Iran;

Based on experiences, even if the US intends to lift sanctions on paper, it will use various tools to prevent Iran’s economy from realizing the real and full economic benefit.

B. Preventing Iran by the United States from benefiting from the lifting of sanctions;

Taking no effort in improving the risk index of interaction and cooperation of other countries with the Iran economy and

trying to maintain the current level of cooperation risk,

Disrupting one of the links in Iran’s chain of foreign Economic cooperation,

Exaggeration in giving the minimum rights (advantages) due to the lifting of sanctions and showing drawbacks as an advantage such as granting specific & general licenses instead of the lifting of sanctions,

Increasing the political and economic risk of cooperation with Iran through formal rhetoric, media attacks, and informal pressures.

In general, using a mere legal approach in the present situation cannot provide the possibility of authentic verification of the lifting of sanctions and benefiting the Iranian economy in practice. Therefore, in addition to insisting on the legal lifting of sanctions, operational and measurable criteria as an affirmative approach should also be designed to verify the benefits of the lifting of sanctions. These indicators should be introduced as conditions of Compliance with the commitments and as preconditions for fulfilling the nuclear Actions of the Islamic Republic of Iran; these include demanding and ensuring the export of a certain minimum level of oil and oil products, conducting transactions easily by using revenues from export, the realization of a certain level (threshold) of monthly transactions and banking operations by targeted foreign banks and operational review of rules related to the international economic activity of Iranian Individuals and legal persons, which is assessed in detail in the present report. The verification of the actual lifting of the sanctions and the realization of the measurable criteria (indicators) determined by Iran is impossible in just a few hours or a few days. The stated process will take at least 3 to 6 months.

Accordingly, based on the definite policy of the Islamic Republic of Iran and the emphasis of the Leader of the Islamic Revolution on the necessity of prioritization of verification over the fulfilment of obligations by Iran, and also Compatible with the aforesaid Iranian Parliament Act, it is factually necessary and also legally mandatory to verify the benefit of the lifting of sanctions by Iran based on quantitative and operational indicators. Furthermore, adopting a mere legal approach—focusing on the apparent lifting of some or even all sanctions, regardless of whether such a lifting also leads the sanctions to be lifted in practice—which may be overcome and followed due to the prioritizing of short-term political interests over national and long-term interests, must be avoided. The parliament’s role in verifying the actual lifting of the sanctions and the realization of the criteria of Iran’s economic benefit from the lifting of the sanctions is vital and unquestionable. Examining the explicit text and spirit of Article (7) of the Law on “Strategic Action for Lifting Sanctions and Protecting the Interests of the Iranian nation” and the detailed proceedings of parliament in the process of passing the mentioned law imply that the Re-commitment of Iran to the nuclear actions according to JCPOA, is possible just after the authorization issued by the Islamic Consultative Assembly. In Turn, This permission in accordance with the mentioned Act will issue by the Parliament only after lifting the sanctions totally and the fulfilment of the measurable criteria.