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New Proposal Outlines “Smart Sanctions Architecture”

Foreign Policy’s blog The Cable on Friday published details of a strategy document, co-authored by officials the outlet characterized as carrying “immense political clout” in the de­bate over Iran, outlining a structure for Con­gressional sanctions that would take hold in the aftermath of comprehensive nuclear deal between Tehran and the P5+1 global powers, and which would seek to preserve American leverage both to enforce any agreement and in areas beyond Iran’s atomic program.

The full document—written by Mark Dubowitz and Richard Goldberg, respective­ly the executive director of the Foundation for Defense of Democracies (FDD) and the for­mer deputy chief of staff to Senator Mark Kirk (R-IL)—was subsequently uploaded to FDD’s server.

The report echoes a consensus, which has been emphasized by groups on both sides of the Iran sanctions debate, to the effect that Congress must play a central role in lifting fi­nancial restrictions on the Islamic republic.

It calls for the construction of “a smart sanctions architecture of effective enforce­ment and relief” in the context of any verifia­ble agreement that genuinely puts Iran’s atom­ic program beyond use for weaponization, and outlines six criteria for a “flexible and limited sanctions relief framework”:

This flexible and limited sacntions re­lief framework should be based on: (1) the fi­nal agreement meeting a series of parameters that already has strong bipartisan Congres­sional support; (2) the careful sequencing of sanctions relief tied to Iran meeting its obliga­tions under an agreement; (3) the creation of a permissable financial channel through which trade and financial transactions can occur; (4) temporary suspension of only those sanctions which can quickly be “snapped-back” should Iran fail to comply with the agreement; (5) the maintenance of all conduct-based sanctions until Treasury can certify that the behavious which prompted the designation has ceased; and (6) a series of Presidential certifications that Iran has changed its behavior in critical ar­eas of concern.

Dubowitz and Goldberg also emphasize that “terrorism and human rights sanctions should be strengthened and expanded if the behavior underlying these sanctions contin­ues,” and that—more precisely—conduct-based sanctions should be maintained un­til the Treasury Department and the President have certified that Iran has altered the pro­scribed conduct.

The Cable had quoted Brookings Institu­tion’s Suzanne Maloney predicting that the plan would find backing on Capitol Hill:

“This plan will elicit a lot of support on the Hill,” said Suzanne Maloney, a senior fellow at the Brookings Institution. “They have an enormous amount of sway on the Hill on the issue of sanctions, both because of their expertise and their energetic efforts to advance their case.”

By Omri Ceren/TheTower.org

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