For the second time in a half-decade, U.S. policy toward Iran is undergoing a profound redefinition, as the Biden administration abandons the "maximum pressure" of the Trump era in favor of a broad effort to reengage the Islamic Republic.
Even before he was elected in November 2020, it was clear that, as president, Joe Biden would pursue a substantially more accommodating approach toward Tehran than his predecessor. For instance, in the spring of 2020, at the start of the global coronavirus outbreak, Biden himself argued that the U.S. government needed to ease sanctions pressure on Iran[1] – even though the Iranian regime had by then repeatedly turned down offers of humanitarian assistance from the Trump administration.[2] In much the same vein, top foreign policy advisor (now Secretary of State) Antony Blinken indicated that a Biden White House would be willing to resuscitate the 2015 deal over Iran's nuclear program known as the Joint Comprehensive Plan of Action, or JCPOA – including, presumably, reactivating the massive sanctions relief that accompanied the original agreement.[3] Meanwhile, the broad contours of this reengagement was being defined by aligned experts and think tanks, such as the left-leaning Center for a New American Security, which in August of 2020 published what was effectively a blueprint for future talks with Iran.[4]
In turn, once it took office in January 2021, reengagement with Iran became a top priority of the Biden administration's foreign policy. Almost immediately, Administration principals (including Secretary of State Blinken, Deputy Secretary of State Wendy Sherman, National Security Advisor Jake Sullivan and State Department Special Envoy Rob Malley) embarked upon extensive outreach toward the Iranian government designed to cajole the country's clerical regime into reentering the 2015 nuclear deal and returning to the diplomatic table. As of this writing, that effort has entailed, among other things: renewed proximity talks between Washington and Tehran, a rollback of key sanctions deemed not to be consistent with the spirit of the 2015 nuclear deal, and a relaxation of American enforcement of those punitive economic measures still in place. Administration officials have waxed optimistic that such steps will, over time, pave the way for a "longer and stronger" deal with Tehran.[5]
Yet it is also an effort that is fraught with peril. The Biden administration's Iran policy risks undoing the significant leverage that the United States has accumulated vis-à-vis the Iranian regime over the past two years as a result of "maximum pressure." It likewise risks missing a crucial opening within Iran itself, where an increasingly disaffected populace is coalescing around an anti-regime consensus that offers a tantalizing glimpse at a post-theocratic future for one of America's most vexing strategic adversaries.
THE LEVERAGE THAT TRUMP BUILT
The advent of the Trump administration in early 2017 brought with it an earlier sea change in the prevailing U.S. approach to Iran. President Trump's predecessor, Barack Obama, pivoted away from the broad sanctions pressure of the George W. Bush era toward a more accommodating policy of sustained engagement with Tehran. That policy, launched while Obama was still a candidate for America's highest office,[6] culminated in mid-2015 in the JCPOA. Under the terms of the agreement negotiated with Iran by the U.S. and the other P5+1 powers (the United Kingdom, France, Russia, China and Germany), the Islamic Republic accepted significant – albeit temporary – restrictions on its nuclear development in exchange for massive sanctions relief and a rehabilitation of the Iranian regime's international standing.[7]
Significantly, these steps were pursued by the Obama administration in the face of significant domestic opposition in the U.S.[8] It was predictable, therefore, that Iran policy would emerge as a major point of contention in the 2016 presidential race, with Republican candidate Donald Trump pledging to repudiate the deal and roll back its benefits for the Iranian regime if elected.[9] Once in office, however, it took more than a year for Trump's administration to enact this about-face. It was not until May of 2018 that President Trump formally announced he was withdrawing the United States from the confines and commitments of the 2015 deal.[10] That action, in turn, set the stage for the Administration's "maximum pressure" policy toward the Islamic Republic – an approach which was geared toward curbing the Iranian regime's malign regional behavior and forcing it back to the international negotiating table to conclude a more comprehensive accord that (in the view of the Trump administration) better served American strategic interests.[11]
However, "maximum pressure" met with significant skepticism from the mainstream media and policy elites. Assorted commentators and foreign policy experts argued at the time (and have argued since) that the Trump administration's approach to Iran failed in its objectives, contributed to a deterioration of humanitarian conditions within the Islamic Republic, and intensified the potential for instability in the Middle East.[12] These criticisms were perhaps not surprising, coming as they did against the backdrop of a heated U.S. domestic political cycle – one in which matters of foreign affairs played a more prominent role than in years past.[13] Yet they were and remain inaccurate, because empirical data suggests that "maximum pressure" had a pronounced effect on the Islamic Republic's internal dynamics, regime stability, and its ability to sponsor and foment regional radicalism.
Most directly, the Trump administration's campaign of escalating economic and political pressure succeeded in profoundly impacting the Iranian regime's financial situation. In mid-2020, Iranian officials disclosed that, since the start of 2019, the country's once-robust oil revenues had declined by more than 90 percent, from around $100 billion annually to just $8 billion a year.[14] This declining income reflected a massive cooling of Iran's oil sector, as skittish clients fearful of the potential consequences of U.S. sanctions increasingly disengaged from the Islamic Republic. Similarly, Iranian officials disclosed at the time that a growing number of the regime's foreign partners – fearful of running afoul of the United States – were declining to sign new energy deals with Tehran.[15]
Foreign investment in Iran dried up as well, as more and more countries and businesses opted to steer clear of the Islamic Republic rather than risk becoming the target of U.S. sanctions. According to the UN Conference on Trade and Development, for instance, foreign direct investment in Iran declined by 26.5 percent in 2019, and in mid-2020 stood at its lowest level in nearly two decades.[16]
These factors, in turn, precipitated a full-on collapse of Iran's national currency. Last summer, the Iranian rial – which traded at 79 to the U.S. dollar at the time of the 1979 Revolution – plummeted to its lowest rate in the Islamic Republic's 41-year history (260,000 to $1).[17] So steep was this decline that, despite the regime's ongoing economic crisis, the country's Central Bank had been forced by August 2020 to spend some $2.5 billion to stabilize the failing currency.[18]
As a result, the Iranian regime had no choice but to eat into its savings to stay solvent. Even prior to the coronavirus, the prestigious Institute for International Finance had projected that Iran's foreign exchange reserves – which had been estimated at more than $100 billion in 2019 – would dip to some $73 billion in the first half of 2020, and at the regime's then-current rate of consumption total just $20 billion by March 2023.[19] With the outbreak of the global pandemic, that trajectory became steeper still, as Iran's regime was forced to further deplete already-scant funds in order to address a national health crisis of truly immense proportions.[20]
Thus, upon its inauguration, the Biden administration inherited an Iran policy that had already succeeded in significantly weakening the Iranian regime – and which could have been ratcheted up still further if the new White House had chosen to do so. Instead, the new Administration set about dismantling the elaborate architecture of sanctions and economic pressure that had been painstakingly erected against the Islamic Republic over the preceding quarter-century by successive administrations. Despite its initial pledges to delay sanctions relief until Iran's reentry into the JCPOA,[21] the Administration has provided sanctions relief "in effect" by relaxing its enforcement of existing economic restrictions – a move that has spurred foreign companies and countries to begin to reengage with the Islamic Republic.[22] It has also signaled that it is prepared to offer Tehran sanctions relief far beyond that related to just its nuclear program, potentially waiving any punitive measures it deems "inconsistent" with the spirit of the JCPOA.[23]
For its part, the Iranian regime has worked assiduously to rebuild its leverage over the United States. It has done so via a series of steps – from further enrichment of uranium above permitted levels to aggressive military maneuvers by its forces and regional proxies throughout the Persian Gulf.[24] These and other steps are designed to signal in no uncertain terms to the United States and its partners that the consequences of not striking a new diplomatic bargain between Tehran and the West potentially will be dire.
AN INCREASINGLY DISAFFECTED POPULACE
Since December of 2017, the Iranian regime has faced the longest sustained period of grassroots opposition to its legitimacy since the Islamic Revolution of 1979. While more modest in scope than the summer 2009 protests that accompanied the fraudulent reelection of Mahmoud Ahmadinejad (an opposition wave that came to be known at the "Green Movement"), they have proven both more durable and more broad-based. Strikes, marches and other forms of opposition activism involving practically every stratum of Iranian society sporadically take place in Tehran and other major cities in spite of extensive regime repression.[25]
The Iranian leadership was provided a temporary reprieve by the onset of the global coronavirus crisis, which limited gatherings and allowed the regime to take greater control of the Iranian "street." However, popular ferment reemerged with a vengeance in recent months. Ordinary Iranians rallied throughout the country against the social malaise, economic decline and official corruption that has come to typify life under the Islamic Republic. Increasingly, moreover, these protests reflect a more fundamental rejection of the regime itself. For instance, a February 2021 poll of over 20,000 Iranians in 31 provinces carried out by the Netherlands-based by GAMAAN institute found that some 53 percent of respondents self-identified as outright proponents of regime change, while an additional 26 percent supported "structural transformation and transition away from the Islamic Republic." By contrast, merely a fifth (21 percent) of those polled expressed support for the principles undergirding the Ayatollah Ruhollah Khomeini's Islamic Revolution, or said they preferred to work within the current system in order to amend it.[26]
Those results are striking. They underscore that – contrary to the prevailing wisdom in Washington and Western capitals – there is in fact no existential contest between "hardliners" and "reformists" that can be influenced in favor of the latter through sustained diplomatic engagement. Rather, the true fault line in contemporary Iran lies between the regime and those who are ruled by it. The former seeks to preserve the Khomeini's repressive ideological system of velayat e-faqih (Guardianship of the Jurisprudent). The latter is increasingly prepared to repudiate it outright.
It is a reality that Iran's leaders understand well. In the most recent Iranian elections, which took place in June of 2021, the regime took great pains to stage manage the ascension of a regime stalwart: former judiciary head Ebrahim Raisi.[27] Notably, the election saw the lowest turnout of any political contest in the Islamic Republic's more-than-four-decade history, with Iranian voters expressing their opposition to the system by staying home or by casting irregular or blank ballots.[28] Raisi's inevitable selection thus represented a consolidation of power by Iran's clerical elite around a figure in line with the regime's ideological precepts – and who is now positioned to take over the mantle of Supreme Leader once the Ayatollah Ali Khamenei leaves the scene. As Karim Sadjadpour of the Carnegie Endowment for International Peace has put it, the Iranian regime has simply "stopped pretending" that it is anything other than what it is: a repressive, consolidated theocracy.[29]
Iran's disparate opposition forces, meanwhile, have begun to coalesce around a shared rejection of the regime. Beginning this spring, a new civic campaign, known as "No to the Islamic Republic," emerged among opposition elements both inside and outside the country.[30] The effort is notable in that it has unified Iran's ordinarily fractious opposition groups and ideological currents behind a common vision: one that fundamentally rejects the country's current, clerical system of government and the unaccountable ayatollahs who administer it.
To its credit, the Trump administration recognized the dynamic nature of Iran's internal political scene during its time in office. Admittedly, human rights did not figure specifically in the "twelve points" laid out by Secretary of State Mike Pompeo in May 2018 as prerequisites for a normalization of relations between Washington and Tehran.[31] In practice, however, the Trump administration made internal conditions within Iran a major focus of its policy, with the State Department placing significant emphasis on engagement with Iranian opposition elements and shining sustained attention on the Iranian regime's internal abuses.[32]
The Biden administration, by contrast, has de-emphasized engagement these initiatives in favor of renewed dialogue with the country's clerical regime. Like the Obama administration before it, the Biden White House has systematically deprioritized the plight of the Iranian people in its pursuit of some sort of official diplomatic bargain with Tehran. In doing so, however, the Administration has chosen the country's aging clerical regime over its young and westward-looking population. That, in turn, could end up being a fateful decision – one that robs the United States of meaningful ability to shape the future of one of the world's most important nations in the years ahead.
AN ENDURING TRANSATLANTIC DIVIDE
Despite its positive track record, "maximum pressure" was widely seen as a unilateral, rather than a collaborative, strategy. While in the Middle East, the Trump administration's escalating campaign of political and economic pressure on the Islamic Republic garnered support from regional states concerned over Iran's regional activism and its increasingly mature nuclear capabilities,[33] the European reaction to it was uniformly negative. European leaders decried President Trump's withdrawal from the JCPOA as an abandonment of America's international commitments and a blow to international stability. They also actively worked to preserve the terms of the agreement and to dilute the effectiveness of American policy, including by erecting a barter trade mechanism (known as INSTEX) that would permit them to continue doing business with the Islamic Republic despite U.S. pressure.[34]
This divergence was, without a doubt, exacerbated by the broader political distance between the U.S. and Europe. During his time in office, President Trump's more confrontational stance toward the NATO alliance, political tensions with continental luminaries (like German chancellor Angela Merkel), and his Administration's broader penchant for international disengagement significantly frayed U.S.-European ties. In turn, these disagreements played a role in limiting cooperation between the United States and Europe on the subject of Iran. Thus, the Trump administration's August 2020 effort to extend the United Nations arms embargo on Iran – a position broadly consistent in principle with European attitudes – proved unsuccessful, undermined not only by Russia and China (both of which serve as major Iranian strategic partners) but also by European nations increasingly unwilling to abide by or comply with U.S. policy.
By contrast, the Biden administration's approach has garnered plaudits from European officials, who have tried to goad the White House into accelerating its existing reengagement with the Islamic Republic still further.[35] Their eagerness is understandable, given that European officials are far more invested in preserving the JCPOA as a matter of both diplomacy and international credibility.[36] Economic considerations also play a significant role; while the United States engages in only minimal trade with the Islamic Republic, Europe does far more. Even though the advent of "maximum pressure" led to an appreciable decline in the overall volume of trade between the EU and Iran, at the end of the Trump administration the EU still accounted for close to 20 percent of the Islamic Republic's external trade.[37] Over time, continuing business with Iran (and the potential for more commerce in the future) has helped to make the continent's companies – and even its governments – stakeholders of sorts in the Iranian regime's continued solvency.
Europe, then, remains enduringly committed to engagement with Iran. In contrast to the Trump era, that is now a view also shared by the United States. This tactical convergence, however, masks more fundamental differences in the American and European approaches toward the Islamic Republic.
The longstanding (and bipartisan) American perception of Iran is that of a revisionist power, one whose destabilizing regional activities need to be limited, its support of radical non-state proxies curtailed, and its persistent pursuit of weapons of mass destruction blunted. Simply put, irrespective of administration, the United States views Iran under its current, clerical government as a source of instability in the Middle East, and a threat to its allies in the region and American interests there. Where various administrations have differed is in their preferred approach to dealing with that problem, with some (like George W. Bush and Donald Trump) preferring broad sanctions pressure and others (Obama and now Biden) opting to proffer inducements to Tehran for a change in behavior.
Europe, by contrast, by and large sees Iran as a long-term problem to be managed. There is little discernable appetite on the continent for discussions of regime change within Iran, and significant desire – at least at the corporate and governmental levels – to return to normal political and trade relations with Tehran. While the "grand bargain" with Iran envisioned a over a decade ago by the E3 nations has not come to pass, the premise that undergirded those discussions continues to animate Europe's approach to Iran. That approach has minimized critical attention to the Iranian regime's radical ideology, repressive domestic behavior, and regional troublemaking in favor of broad diplomatic and political engagement.
While it may have temporarily receded as a result of the Biden administration's current reconfiguration of U.S. Iran policy, this fundamental disconnect will endure, and remain an irritant in relations between the United States and Europe for the foreseeable future. And, in time, the advent of a new administration in Washington and the ascent of substantially different views of Iran will invariably lead the American policy pendulum to swing back once more.
ENDNOTES
[1] Bryant Harris, "Intel: Joe Biden uses coronavirus crisis to push for Iran sanctions relief," Al-Monitor, April 2, 2020, https://www.al-monitor.com/pulse/originals/2020/04/intel-biden-sanctions-relief-iran-coronavirus.html.
[2] Somayeh Malekian, "Iran rejects coronavirus aid amid conspiracy theories and sanctions," ABC News, March 24, 2020, https://abcnews.go.com/International/iran-rejects-coronavirus-aid-amid-conspiracy-theories-sanctions/story?id=69775776.
[3] Matthew Petti, "Will Joe Biden Go Back to the Iran Deal?" The National Interest, May 20, 2020, https://nationalinterest.org/blog/skeptics/will-joe-biden-go-back-iran-deal-156186.
[4] Ilan Goldenberg, Elisa Catalano Ewers, and Kaleigh Thomas, Reengaging Iran, Center for a New American Security, August 2020, https://s3.amazonaws.com/files.cnas.org/documents/Iran_Report-FINAL-v5.pdf?mtime=20200804090707.
[5] See, for instance, "Blinken says US to seek 'longer and stronger' deal with Iran," i24 News, January 19, 2021, https://www.i24news.tv/en/news/international/1611087752-blinken-says-us-to-seek-longer-and-stronger-deal-with-iran.
[6] Michael R. Gordon and Jeff Zeleny, "Obama Envisions New Iran Approach," New York Times, November 2, 2007, https://www.nytimes.com/2007/11/02/us/politics/02obama.html.
[7] This included hundreds of billions of dollars in direct and indirect economic relief for the Iranian regime, as well as a lessening of multilateral restrictions on foreign commercial business with Iranian companies and entities. See David Rothkopf, "Iran's $300 Billion Shakedown," Foreign Policy, April 16, 2015, https://foreignpolicy.com/2015/04/16/irans-300-billion-shakedown-sanctions-nuclear-deal/.
[8] A poll conducted by Quinnipiac University in the summer of 2015 found that American voters opposed the agreement by a 2 to 1 margin. "Press release: American Voters Oppose Iran Deal 2-1, Quinnipiac University National Poll Finds; Pope's Climate Change Message Gets Huge Support," Quinnipiac University, August 3, 2015, https://poll.qu.edu/national/release-detail?ReleaseID=2265.
[9] "2016 presidential candidates on the Iran nuclear deal," Ballotpedia, n.d., https://ballotpedia.org/2016_presidential_candidates_on_the_Iran_nuclear_deal.
[10] White House, "Remarks by President Trump on the Joint Comprehensive Plan of Action," May 8, 2018, https://www.whitehouse.gov/briefings-statements/remarks-president-trump-joint-comprehensive-plan-action/.
[11] Richard Goldberg, "Trump has an Iran Strategy. This Is It," New York Times, January 24, 2020, https://www.nytimes.com/2020/01/24/opinion/trump-iran.html.
[12] See, for instance, Colin H. Kahl, "This is how easily the U.S. and Iran could blunder into war," Washington Post, May 23, 2019, https://www.washingtonpost.com/outlook/this-is-how-easily-the-us-and-iran-could-blunder-into-war/2019/05/23/40dbbcae-7c07-11e9-8ede-f4abf521ef17_story.html; See also Phillip H. Gordon and Ariane M. Tabatabai, "Trump must ease sanctions against Iran or face a humanitarian catastrophe," Washington Post, March 25, 2020, https://www.washingtonpost.com/opinions/2020/03/25/trump-must-ease-sanctions-against-iran-or-face-humanitarian-catastrophe/.
[13] See, for example, Walter Russell Mead, "Trump's Best Re-Election Bet: Run Against China," Wall Street Journal, April 22, 2020, https://www.wsj.com/articles/trumps-best-re-election-bet-run-against-china-11587573159.
[14] Yaghoub Fazeli, "Iran's oil revenues fell steeply from $100 bln to $8 bln in 2019: First VP Jahangiri," Al-Arabiya (Riyadh), June 14, 2020, https://english.alarabiya.net/en/business/energy/2020/06/14/Iran-s-oil-revenues-fell-steeply-from-100-bln-to-8-bln-in-2019-says-First-VP-Jahan.html.
[15] "Oil Minister Says Foreign Countries Refusing To Sign Agreements With Iran," Radio Farda, July 20, 2020, https://en.radiofarda.com/a/oil-minister-says-foreign-countries-refusing-to-sign-agreements-with-iran/30737553.html.
[16] "Foreign Investment In Iran In 2019 Dropped To Lowest Level In 17 Years," Radio Farda, June 17, 2020, https://en.radiofarda.com/a/foreign-investment-in-iran-in-2019-dropped-to-lowest-level-in-17-years/30675461.html.
[17] "Devaluation of Iran's Currency Accelerates With Dollar Hitting 260,000 Rials," Radio Farda, July 19, 2020, https://en.radiofarda.com/a/devaluation-of-iran-s-currency-accelerates-with-dollar-hitting-260-000-rials/30735734.html.
[18] "Iran's Rial Regaining Value As Central Bank Injects $2.5 Billion Into Market," Radio Farda, August 10, 2020, https://en.radiofarda.com/a/iran-s-rial-regaining-value-as-central-bank-injects-2-5-billion-into-market/30775559.html.
[19] Davide Barbuscia, "Iran recession to deepen, reserves to fall to $73 billion by March: IIF," Reuters, January 15, 2020, https://www.reuters.com/article/us-iran-economy-iif/iran-recession-to-deepen-reserves-to-fall-to-73-billion-by-march-iif-idUSKBN1ZE139.
[20] In mid-July 2020, Iranian president Hassan Rouhani gave a public address in which he disclosed publicly that, according to internal Iranian government tallies, as many as 25 million people – or close to one-third of the nation's population of nearly 85 million – had by then been infected with COVID-19, with some 70,000 dying of the disease. Zachary Halaschak, "Iran's president says 25M caught coronavirus in nearly hundredfold jump from official numbers," Washington Examiner, July 18, 2020, https://www.washingtonexaminer.com/news/irans-president-says-25m-caught-coronavirus-in-nearly-hundredfold-jump-from-official-numbers.
[21] See, for instance, Michael Lipin, "US Sanctions on Iran to Remain, Blinken Says," Voice of America, January 27, 2021, https://www.voanews.com/middle-east/voa-news-iran/us-sanctions-iran-remain-blinken-says.
[22] See, for instance, "IntelBrief: Maximum Pressure on Iran Begins to Relax," Soufan Center Intelbrief, March 23, 2021, https://thesoufancenter.org/intelbrief-2021-march-23/.
[23] U.S. Department of State, Office of the Spokesperson, "Briefing with Senior State Department Official on Ongoing U.S. Engagement in Vienna Regarding the JCPOA," May 6, 2021, https://www.state.gov/briefing-with-senior-state-department-official-on-ongoing-u-s-engagement-in-vienna-regarding-the-jcpoa/.
[24] Ilan Berman, "How Iran Is Building Leverage Over Biden," Al-Hurra Digital, January 9, 2021, http://www.ilanberman.com/24992/how-iran-is-building-leverage-over-biden.
[25] See, for instance, "Special Report: Iran's leader ordered crackdown on unrest – 'Do whatever it takes to end it,'" Reuters, December 23, 2019, https://www.reuters.com/article/us-iran-protests-specialreport-idUSKBN1YR0QR.
[26] Ammar Maleki, "Iranians' Attitudes Toward Media: A 2021Survey Report," GAMAAN, March 2021, 12, https://gamaan.org/wp-content/uploads/2021/04/GAMAAN-Iran-Media-Survey-2021-English-Final.pdf.
[27] Ahead of the election, nearly 600 hopefuls filed papers to formally run for the Iranian presidency. However, all but seven were disqualified by the Guardian Council, the Islamic Republic's constitutional vetting body. By election day, another three had dropped out of the race, making Raisi's election a virtual certainty even before Iranians cast their ballots. See "Iranian presidential race narrows as more candidates drop out at last minute," TRT World, June 16, 2021, https://www.trtworld.com/middle-east/iran-presidential-race-narrows-as-more-candidates-drop-out-last-minute-47578.
[28] "As Raisi Wins Iran Vote, 'Void And Blank Ballots' Come In Second Place," Iran International, June 19, 2021, https://iranintl.com/en/iran/raisi-wins-iran-vote-void-and-blank-ballots-come-second-place.
[29] Karim Sadjadpour, "Iran Stops Pretending," The Atlantic, June 20, 2021, https://www.theatlantic.com/ideas/archive/2021/06/iran-president-raisi-biden/619252/.
[30] "'No to the Islamic Republic': Opposition Inside, Outside Iran Rally Together To Oust Regime," The Foreign Desk, March 11, 2021, https://www.foreigndesknews.com/middle-east/iran/no-to-the-islamic-republic-iranian-opposition-inside-outside-iran-rally-together-to-oust-regime/.
[31] Mike Pompeo, "After the Deal: A New Iran Strategy," Remarks before the Heritage Foundation, May 21, 2018, https://www.heritage.org/defense/event/after-the-deal-new-iran-strategy.
[32] Mora Namdar, "The Human Rights Element of Iran Policy," The National Interest, March 22, 2021, https://nationalinterest.org/blog/buzz/human-rights-element-iran-policy-180860.
[33] See, for instance, "Saudi minister says maximum pressure only way to get Iran to negotiate," Reuters, October 24, 2019, https://www.reuters.com/article/us-usa-iran-saudi/saudi-minister-says-maximum-pressure-only-way-to-get-iran-to-negotiate-idUSKBN1X30XM.
[34] See, for instance, Laurence Norman, "EU Ramps Up Trade System With Iran Despite U.S. Threats," Wall Street Journal, March 31, 2020, https://www.wsj.com/articles/eu-ramps-up-trade-system-with-iran-despite-u-s-threats-11585661594.
[35] Colum Lynch, "Europeans Fear Iran Nuclear Window Closing," Foreign Policy, March 26, 2021, https://foreignpolicy.com/2021/03/26/europe-us-biden-iran-nuclear-deal-lift-sanctions/.
[36] Council of the European Union, "Declaration of the High Representative on behalf of the EU following US President Trump's announcement on the Iran nuclear deal (JCPOA)," May 9, 2018, https://www.consilium.europa.eu/en/press/press-releases/2018/05/09/declaration-by-the-high-representative-on-behalf-of-the-eu-following-us-president-trump-s-announcement-on-the-iran-nuclear-deal-jcpoa/.
[37] European Commission, "Iran," n.d., https://ec.europa.eu/trade/policy/countries-and-regions/countries/iran/.
