The Legal Steps and Policy Challenges of Reimposing Sanctions on Iran

September 11, 2017

Weapon Program: 

  • Nuclear
  • Missile


Peter Harrell and Elizabeth Rosenberg


Center for New American Security

Under the Iran Nuclear Agreement Review Act (INARA), a 2015 statute designed to give Congress oversight over the Joint Comprehensive Plan of Action (JCPOA) nuclear agreement with Iran, President Trump is required to periodically certify to Congress whether or not Iran is complying with its obligations under the deal. President Trump has twice certified Iranian compliance with the JCPOA since his inauguration, once in May and once in July. However, since mid-July President Trump himself and other senior administration officials have publicly indicated that Trump is unlikely to certify Iranian compliance with the JCPOA when the administration is next required to do so in mid-October.

A decision not to certify Iranian compliance with the JCPOA would not, legally speaking, automatically reimpose sanctions on Iran. It would, however, begin an executive branch and congressional process of developing ways to reimpose some or all of the sanctions on Iran that the United States suspended as part of the JCPOA, and it would create strong policy and political momentum for reimposing sanctions. Reimposing sanctions would, in turn, create significant uncertainty about the future of the JCPOA and could begin a process of unraveling the nuclear agreement.


Read the full report at Center for New American Security