Mitigating Humanitarian Impact in a Complex Sanctions Environment: The European Union and the Sanctions Regimes against Iran

Iran is one of the most heavily sanctioned countries in the world. The combination of sanctions on Iran imposed by the United States, the United Nations and the European Union (EU) in response to, among others, nuclear and ballistic missile activities and human rights violations provides for a sanctions environment that is highly complex and difficult to navigate for exporters, financial institutions and humanitarian actors. Particularly in the context of the Covid-19 pandemic, there is renewed attention to the humanitarian impact of sanctions, especially in the case of Iran which became one of the flashpoints of the pandemic. The focus of this paper is on the array of overlapping sanctions and the mitigation of humanitarian impact, with a particular focus on EU sanctions policy and instruments.

The paper outlines key milestones and phases in the imposition of sanctions on Iran by the three main sanctioning actors, the USA, the UN and the EU, thus demonstrating the complexity and the at times coordinated or contradictory nature of the different sanctions. It then explores the humanitarian impact of sanctions on Iran by discussing several illustrative indicators and the impact of sanctions on the provision of international humanitarian aid. The paper reviews existing mechanisms to mitigate the humanitarian impact of sanctions and how they could be improved. In the context of the sanctions of Iran, but also beyond, the paper finds that there is a clear need to further strengthen compliance, enforcement and coordination of EU sanctions, including in the context of the Joint Comprehensive Plan of Action. It concludes by providing specific recommendations for the EU and its member states on improving the effective use of sanctions and reducing their humanitarian impact, including through strengthening key instruments and assessment processes, better coordination with the USA and more engagement with humanitarian actors.