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B.   Legal Framework of the Iran Sanctions Regime 874

2.   International Sanctions: Multilateral Resolutions 891

in sanctioning Iran, spawning a rich unilateral sanctions regime that

existed in some form for the majority of four decades.

294

However,

unilateral sanctions—even controversial extraterritorial unilateral

sanctions—packed little punch in comparison to comprehensive

multilateral sanctions.

295

While even some of Washington’s closest

allies were hesitant to sanction Iran through much of the US sanctions

regime, European attitudes soured over the course of the

Ahmadinejad presidency, especially following the reignition of the

nation’s nuclear program and the deterioration of Iranian human

rights in the aftermath of Ahmadinejad’s contested reelection.

296

The first truly multilateral resolution concerning Iran occurred as

a response to its resumption of uranium enrichment in 2005, related to

the government’s nuclear development program.

297

UN Security

Council Resolution 1696 provided a basis for future rounds of

multilateral sanctions, promising that the Security Council would

adopt “appropriate measures” if Iran failed to cease its uranium

enrichment operations.

298

Although Resolution 1696 included no

sanctions itself, it set a one-month deadline for Iran to comply or be

subject to further action.

299

Such further action came in the form

Security Council Resolution 1737, passing unanimously in the

Security Council in late 2006.

300

Resolution 1737 advised all UN

Member States to raise sanctions targeting the transfer of nuclear-

related materials to Iran, including ballistic missile technologies.

301

Additionally, Resolution 1737 demanded Member States freeze the

294. See supra Part I.B.1 (discussing US sanctions against Iran).

295. See generally Egle, supra note 145 (arguing the inefficacy of unilateral sanctions); Clawson, supra note 27, at 116 (questioning whether unilateral sanctions were successful).

296. See Clawson, supra note 27, at 117; MALONEY, IRAN’S POLITICAL ECONOMY

SINCE THE REVOLUTION, supra note 28, at 349 (asserting the global sanctions consensus by

late 2010).

297. See Jason Starr, The U.N. Resolutions, in THE IRAN PRIMER, supra note 12, at 119;

MALONEY, IRAN’S POLITICAL ECONOMY SINCE THE REVOLUTION, supra note 28, at 463

(identifying the origins of multilateral sanctions against Iran).

298. See S.C. Res. 1696 (July 31, 2006); Starr, supra note 297, at 119 (overviewing Resolution 1696).

299. See S.C. Res. 1696; Starr, supra note 297, at 119 (noting Resolution 1696’s one- month compliance deadline).

300. See S.C. Res. 1737 (Dec. 23, 2006); Starr, supra note 297, at 120 (observing the adoption of Resolution 1737).

assets of 22 entities involved in the Iranian nuclear program or the

IRGC, and urged Member States to limit the travel of anybody

connected to Iran’s nuclear program.

302

Three months later, the

Security Council followed up with Resolution 1747, another

unanimous proposal that placed multilateral limitations upon Iran’s

access to military equipment and purchases.

303

In addition to this

military angle, Security Council Resolution 1747 also targeted Iran’s

access to international financial institutions, suggesting that States

limit financial commitments involving Iran to mere humanitarian-

related transactions.

304

Additional names and businesses with ties to

Iran’s nuclear program and/or the IRGC were included on Resolution

1747’s list of sanctionable entities, and the Resolution further

stipulated international reporting requirements when any individual

with ties to Iran’s nuclear program traveled or entered Member State

territory.

305

Following this first round of multilateral sanctions, there were

some positive signs that Iran was beginning to comply with its

International Atomic Energy Agency (“IAEA”) obligations.

306

Still,

encouraged by the United States and some European allies, the UN

Security Council further adopted Resolution 1803 in March 2008.

307

While Resolution 1803 was comprised primarily of non-binding

recommendations, it strongly urged UN Member States to cease any

involvement with Iranian financial institutions suspected of serving

Iran’s nuclear program and/or overseas terrorism.

308

Fifteen additional

302. See S.C. Res. 1737; Starr, supra note 297, at 120 (identifying Resolution 1737’s sanction provisions).

303. See S.C. Res. 1747 (Mar. 24, 2007); Starr, supra note 297, at 120 (introducing Resolution 1747).

304. See S.C. Res. 1747; Starr, supra note 297, at 120 (highlighting the financial sanctions within Resolution 1747).

305. See S.C. Res. 1747; Starr, supra note 297, at 120 (pointing out Resolution 1747’s expanded list of sanctioned Iranian entities).

306. See Starr, supra note 297, at 120 (“ . . . several council members initially questions the need for further sanctions against Iran. Libya, South Africa, Indonesia, and Vietnam were especially hesitant to pursue new punitive measures, arguing that Iran had begun to cooperate with IAEA inspections.”); Walter Isaacson, A Way Out for Iran’s Nuclear Impassse?, TIME, Mar. 14, 2007, http://content.time.com/time/magazine/article/0,9171,1599725,00.html (acknowledging initial hopes for Iranian nuclear compliance).

307. See S.C. Res. 1803 (Mar. 3, 2008); Starr, supra note 297, at 120-21 (presenting Resolution 1803).

308. See S.C. Res. 1803; Starr, supra note 297, at 120-21; William Maclean & Andrew Quinn, Analysis: Iran Sanctions Push is Test for West Diplomacy, REUTERS (Jan. 5, 2012), http://www.reuters.com/article/us-iran-sanctions-analysis-idUSTRE80415Q20120105 (articulating the financial measures of Resolution 1803).

entities were subjected to asset freezes, and Member States were

authorized to seize and inspect any cargo traveling to or from Iran if

there were “reasonable grounds” to believe that the cargo contained

previously-banned materials.

309

Later that year, the Security Council

also adopted Resolution 1835, which simply reaffirmed the existing

multilateral sanctions in light of new evidence related to Iran’s

ongoing nuclear noncompliance.

310

Although the Security Council

unanimously passed Resolution 1835, growing tensions between

Washington and Moscow related to further sanctions began to show

the limitations of the multilateral sanctions regime.

311

At the same

time, however, Iran’s stark noncompliance in the face of both IAEA

and UN demands helped bring individual European States toward

adopting their own unilateral measures to target Iran.

312

In response to another major negotiating impasse as well as the

discovery of Iran’s secret uranium enrichment site at Qom, the UN

Security Council passed Resolution 1929 in June 2010.

313

The

Resolution demanded that States adopt measures to keep sensitive

technologies from reaching Iran.

314

Likewise, it blocked all Iranian

commercial access to uranium mining operations and other nuclear

material production operations outside Iran.

315

Further targeted

309. See S.C. Res. 1803. Importantly, the language of Resolution 1803 provided no definition or guidance as to what constituted “reasonable grounds,” thereby leaving enforcement to the discretion of individual member states. See id.; see also Starr, supra note 297, at 121 (further expounding on the suggestions under Resolution 1803).

310. See S.C. Res. 1835 (Sept. 27, 2008); Starr, supra note 297, at 121 (explaining Resolution 1835).

311. See Starr, supra note 297, at 121 (“[i]n its final U.N. measure on Iran before leaving office, the Bush administration was forced to accept a compromise resolution after Russia balked at more sanctions.”); Egle, supra note 145, at 45 (noting Russian and other nations’ resistance to Washington’s call for intensified sanctions).

312. See MALONEY, IRAN’S POLITICAL ECONOMY SINCE THE REVOLUTION, supra note 28, at 463 (“the Bush administration began to reap the rewards of a new coordination with Europe on Iran, in the form of incipient European and multilateral actions to penalize Tehran.”); DINA ESFANDIARY, ASSESSING THE EUROPEAN UNION’S SANCTIONS POLICY:

IRAN AS A CASE STUDY,34 EUNON-PROLIFERATION CONSORTIUM,7-10 (December 2013),

http://www.nonproliferation.eu/web/documents/nonprolif

erationpapers/dinaesfandiary52b41ff5cbaf6.pdf (identifying European unilateral sanctions against Iran).

313. See S.C. Res. 1929 (June 9, 2010); Starr, supra note 297, at 121 (introducing Resolution 1929); see also Meshkat, supra note 200, at 44 (detailing Iran’s NPT noncompliance on the eve of Resolution 1929).

314. See S.C. Res. 1929; Starr, supra note 297, at 121 (explaining Resolution 1929). 315. See S.C. Res. 1929; Starr, supra note 297, at 121 (detailing the further restrictions of Resolution 1929).

sanctions were aimed at the IRGC, as well as the Islamic Republic of

Iran Shipping Lines (“IRISL”), which was suspected of importing

goods related to Iran’s nuclear program.

316

Perhaps most importantly,

in light of the simultaneous US efforts under CISADA, Security

Council Resolution 1929 adopted new sanctions on Iran’s finance

sector, calling on Member States to block the expansion of Iranian

banks into their jurisdiction and to require that a State’s domestic

banks cut all ties to Iran.

317

The passage of Resolution 1929 along

with the United States’ diplomatic resurgence following the election

of President Obama allowed for even greater proliferation of

commonly focused unilateral sanctions, which had a major impact on

Iran’s international image and its domestic economy.

318

In combination with US and other unilateral sanctioning efforts,

these UN Security Council measures contributed to the most complex

and aggressive international sanctions regime that the world has ever

witnessed.

319

By the election of President Rouhani in 2013, the

Islamic Republic was drowning in international coercive pressures.

320

The next Part of this Note will focus on what these pressures actually

looked like.