A report by Islamic Parliament Research Center
Verification of Sanctions Removal; Main Topics and Executive Aspect

Tehran (IP) - Article 7 of the Law on "Strategic Action to remove Sanctions and Protect Iranian Nation's interests," stress that the removal of Iran sanctions should provide tangible benefits for Iran's economy, a report by the Department of Economic Studies of Islamic Parliament Research Center (IPRC) analyzed, main topics and executive aspect of verification of sanctions removal.

Iran PressIran news:  A report prepared by the Department of Economic Studies of Islamic Parliament Research Center (IPRC) says that "Realization of the legal aspects of removing sanctions, should provide tangible benefits for Iran's economy due to the removed sanctions."

According to the provisions of Article (7) of the Law on "Strategic Action to remove Sanctions and Protect Iranian Nation's interests," as well as the definite policy of the Islamic Republic of Iran, the Verification of the removal of sanctions and its subsequent benefits for Iran's economy should be the inevitable demand of the foreign policy apparatus in any negotiation process. In other words, the removal of Iran sanctions, regardless of the realization of the legal aspects of removing sanctions (removal of sanctions on paper), should provide tangible benefits for Iran's economy due to the removed sanctions.

Read in Iran Press: Iranian MPs on 01 December 2020 approved Outline of strategic plan action to lift sanctions approved by MPs

 

Islamic Parliament Research Center (IPRC), in a report, prepared a comprehensive guideline for advancing Verification of sanction removal.

Verification has two main factors:

"monitoring guideline" and"monitoring organization."

Verification is a continuous activity in which a monitoring organization evaluates the other participant's compliance to the agreement's provisions based on objective indicators and criteria related to the type of obligations.

Therefore, three essential requirements must be considered in determining the verification process:

First, developing a comprehensive, operational, and measurable guideline.

Second, determining the unique features for the first stage of Verification.

Third, determining the quality and aspects of periodic Verification.

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In this report, the three main topics are proposed to meet the mentioned three requirements, which will be presented as follows:

A) The verification authority can be beyond the organization of the parliament-approved power such as the Supreme National SecurityCouncil or the Iranian Supervisory Committee on Joint Comprehensive Plan of Action (JCPOA) or even a newly established body with a professional expertise structure and a permanent secretariat.

This authority has the responsibility to compose periodic reports on the Verification of the removal of sanctions to decide whether Iran should continue to comply with the agreement or take countermeasure in the form of reducing or suspending its commitments. This authority has three crucial tasks:

1. Monitoring and analyzing the benefits of Iran'seconomy due to removed sanctions,

2. Receiving complaint letter from an Iranian citizen or institution (especially those individuals and entities that have been removed from the sanctions list) about the "Violation ofJCPOA or the impossibility of deriving benefit from the removedsanctions";

3. Develop a regulation for countermeasures. This includes but is not limited to implementing its provisions in proportion to the other participants' non-compliance by introducing a regulation that mandates suspending, stopping, or reducing nuclear activity limitations as countermeasures.

B) Providing a verification checklist of removing sanctions and permission to resume nuclear-related measures based on JCPOA.

For the first stage of Verification:

The provisions of the proposed checklist of Verification of removing sanctions are presented in two parts

Factors of the actual removal of sanctions:

It includes realizing the minimum thresholds for oil sales and transactions with the German EIHand Bank Tejarat branch of Paris, revoking US President's executive orders, reviewing the related FAQ's of the OFAC website, avoiding issuing warning notices, and issuing specific and general Licences for foreign individuals and legal entities who want to cooperate with Iran'seconomy.

Factors of reducing the risk of economic cooperation with Iran:

The criteria of this topic are the acceptance of legal commitment and the adoption of practical measures by the leaders of the other participant countries on the normalization of trade and economic relationships with Iran, that include:

Revoking executive orders and other regulations, continuing the issuance of the certification of Iran compliance to JCPOA, eliminating instructions and advisories introducing the Iranian economy as a jurisdiction with a high risk of money laundering, and issuing orders or approving regulations that are necessary measures for normalizing trade relationships with Iran.

Avoiding any negative comments or actions discouraging nations from cooperating with Iran and acknowledging the possibility of establishing medium and long-term cooperation with Iran's economy.

Altering the approach of Financial Crimes Executive Network(FinCEN) of United States Department of the Treasury from Risk-Based to Rule-Based.

Removing Iranian Individuals, entities, vessels, and aircraft from the sanctions lists and fundamentally revising the SDN and non-SDNlists.

Eliminating warning instructions and advisories from OFAC and other US agencies on humanitarian goods trade and maritime trade with Iran.

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C) Checklist of Continuity of benefits from removed sanctions and issuance of periodic licenses to allow Iran to continue the implementation of JCPOA (Periodic Verification):

On the issue of continuity of Verification, it is recommended that the process of deriving benefits should be verified continuously and to publish the reports of this Verification every three months.

The threshold for the first part of continuous Verification is 2.5 million barrels per day export of oil and condensate, monthly transactions of Iranian individuals and entities with the EIH Bank in Germany and the Paris branch of Tejaratbank worth at least $ 4.2 and $ 1.5 billion, respectively.

In addition, the normalization of trade and international cooperation with the sanctioned sectors of Iran's economy is considered the basis for continuing the Verification.

The proposed mechanism for examining the normalization of relationships with each economic sector can be described as follows:

The verification authority receives quarterly feedback from prominent governmental and non-governmental actors in each sector based on the dimensions introduced.

Then based on those feedbacks, the verification authority will recommend whether to comply with the commitments or to reduce, suspend or cease Iran'sactions as countermeasures.

In fact, the verification authority should report to the main decision-making organization about JCPOA (which is currently the Supreme National Security Council and the Iranian Supervisory Committee on JCPOA).

According to paragraph 36 of the JCPOA, Iran has the right to reconsider compliance to its commitments based on the domestic approved arrangements in the case of a violation of the JCPOA by other participants.

However, taking these countermeasures does not prevent Iran from sending verification reports to the Joint Commission of the JCPOA as an international organization to convince foreign participants.

This report is prepared by the Department of Economic Studies of Islamic Parliament Research Center (IPRC) and has been published in Iran Press News Agency.

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