EU3: De-Facto Enforcer of U.S. Sanctions against Iran?

Heiko Maas (Alexandros Michailidis via Shutterstock)

by Eldar Mamedov

The situation around Iran, which only seemed to be moving inexorably toward a crisis, recently took a slightly more hopeful turn. Multiple international efforts to facilitate de-escalation between the United States and Iran, in addition to both sides’ unwillingness to sleepwalk into war, helped to lower the tensions. The proposal of Russian Deputy Foreign Minister Sergey Ryabkov to convene an emergency meeting of the remaining signatures of the Joint Comprehensive Plan of Action (JCPOA) along with Swiss, Iraqi, and Omani attempts to re-establish backchannels between Washington and Tehran and the announced visit of the Japanese Prime-Minister Shinzo Abe to Tehran after meeting with Donald Trump all highlight the many players seriously committed to avoiding a war.

German Foreign Minister Heiko Maas was the latest major figure to announce a visit to Tehran with the goal of saving the JCPOA. He is expected to meet with his Iranian counterpart Javad Zarif on Monday June 10. This is a well advised, albeit much delayed and insufficient step. Announced immediately after the news of Abe’s planned visit to Tehran, it almost looks like Japan, who is not a signatory of the JCPOA, shamed the EU3 of France, Germany, and United Kingdom into action.

Better late than never. The EU has a special responsibility in preserving the JCPOA, as it invested 12 years of diplomatic negotiations in securing it, and sees it as a success of effective multilateralism. But what messages will Maas deliver, presumably on behalf of the EU3, to his Iranian counterparts in order to convince them to stay within the agreement?

Political declarations of support for the JCPOA, of which the EU produced many, are useful in the immediate aftermath of U.S. escalation, but now need to be backed up by real, tangible action. Appeals to Iranian strategic patience and sense of moral high ground—as well as an insistence that all the alternatives to staying in the JCPOA are far worse and hopes that after 2020 a new, less hawkish administration will come to power in Washington—may sound perfectly reasonable from a European point of view, but fail to impress the Iranians. The lack of concrete delivery from the JCPOA left its defenders in Iran without arguments. This may embolden their hardline opponents with new parliamentary elections approaching in 2020 and presidential ones in 2021.

The EU3 performance so far does not invite much optimism. On May 31, at the press conference with Secretary of State Mike Pompeo in Berlin, Maas essentially endorsed Pompeo’s line that as long as INSTEX was limited to humanitarian trade (food and medicines) “it does not create a problem”—even as the U.S. Treasury was openly threatening the EU3 with sanctions over INSTEX. This is perilously close to imposing a “food for oil”-style system on Iran, to which Iraq was subjected after its defeat in the first Gulf War. Unlike Saddam Hussein’s Iraq, however, Iran was not defeated in a war and was not subjected to UN-mandated nuclear sanctions after the JCPOA. To the contrary, it fulfilled its obligations, even as the United States did not.

Respecting the American sanctions also runs against the declared purpose of the INSTEX to facilitate all legitimate European trade with Iran. Indeed, the founding statement of the EU3 made it clear that humanitarian trade was meant to be only the first step in making this mechanism operational. Thus, limiting it only to food and medicines makes the EU3 a de-facto enforcer of US sanctions, with no basis in international and European law.

French President Emmanuel Macron further muddied the waters regarding the EU3 intentions during his meeting with Trump at the D-Day celebrations. Macron said that the Europeans and Americans shared the same objectives on Iran and only differed on how to achieve them. Does this include the acceptance of Pompeo’s 12 demands, tantamount to a de-facto regime change in Iran, the disagreement being merely about the tactics?  Or is this statement limited only to the nuclear issue?

True, the United States and EU share the objective of not allowing Iran to acquire nuclear weapons. But then the best way to secure that outcome would be to encourage Washington to rejoin the JCPOA rather than putting more pressure on the side that was fulfilling its obligations under the deal. As to the other issues on which the EU3 leaders find themselves on the same page as Americans, such as Iran’s regional policies and ballistic missiles program, negotiations are only realistic if all sides implement the existing agreement, the JCPOA. Iranian President Hassan Rouhani said as much. This, and not the escalation of the “maximum pressure” campaign, is the condition to negotiate over other issues.

Perhaps the idea that the E3 would stand up to its long-standing transatlantic ally was always far-fetched. It is also true that Iranians did not use all the opportunities to engage the EU. Europe was conspicuously absent from diplomatic itineraries of top Iranian officials in recent weeks. The EU delegation in Tehran was never allowed to operate, due to factional infighting in Iran. The continued imprisonment of a number of EU-Iranian dual nationals and the alleged activities of Iranian intelligence services in Europe targeting dissidents do not add trust to bilateral relations.

That said, the EU has to approach the JCPOA not in terms of its relations with Iran but its own role in the international system. Unlike the United States, the EU is primarily a soft power. Its influence and relevance is maximized through a rules-based international order. It is ill-suited to operate in a world dominated by bullies engaged in zero-sum games. This is why it should stand up for the JCPOA, even if that means paying a price in relations with the current U.S. administration.

Otherwise, if Washington and Tehran finally find themselves sitting at the same table, Europeans risk not being invited to join them. This would deal a crushing blow to EU credibility, as it will throw in doubt its ability to defend the international agreements it champions. Heiko Maas should bear this in mind as he heads to Tehran.

This article reflects the personal views of the author and not necessarily the opinions of the S&D Group and the European Parliament.

Eldar Mamedov

Eldar Mamedov has degrees from the University of Latvia and the Diplomatic School in Madrid, Spain. He has worked in the Ministry of Foreign Affairs of Latvia and as a diplomat in Latvian embassies in Washington D.C. and Madrid. Since 2007, Mamedov has served as a political adviser for the social-democrats in the Foreign Affairs Committee of the European Parliament (EP) and is in charge of the EP delegations for inter-parliamentary relations with Iran, Iraq, the Arabian Peninsula, and Mashreq.



  1. The title reflect the truth in a concise way! EU is practically losing its leverage on international issues when the world realize that they are only an extension of US bullying of course covered a soft coating!

  2. The Ayatollahs benefit from keeping everyone guessing, and making the Americans and Europeans go around in circles. Ultimately they have only one objective, and that is to carry out their religious jihad to bring back their Mahdi.

    Meanwhile their war against Iran, keeps on going, with serious sanctions against the Iranian population. And of course all the commentators blame the Americans. Authors never mention the Ayatollah sanctions on the Iranian people. Presumably they think that the Ayatollahs are very kind of the Iranian people.

    So you have to think who is worse, the authors or the Ayatollahs. Or am I just completely wrong in blaming the Ayatollahs for all the misery in Iran?

  3. Thank you Eldar Mamedov for the piece. In the international affairs the European are no longer relevant. In addition to the UK with an unknown future the entire EU is in deep internal political challenges.
    All the recent activities and traveling of the emissaries to Tehran have to do with Iran’s 60 days ultimatum and the fact that Iran will move on to the next phase of its activities starting after the 60+1 day should Iran doesn’t receive positive responses from the EU.
    The US threats haven’t accomplished anything and the Russians have begun to influencing the US-Iran tension by having one of their Navy ships intimidating one of the US Navy ships today!
    Japan, China and Russia may find a way to convince the US that the bullying approach will not work with Iran and the parties minus EU would have to sit around the table and begin to air their views unconditionally.

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