An Investigation into Role of Secondary Sanctions in the European Union’s Approach to JCPOA (2015-2021)

Important international players, including the US, have always used sanctions as one of their crisis management tools, particularly secondary sanctions that target third parties and are extraterritorial in nature rather than being official like primary sanctions. The US had increased secondary sanctions against Iran since 2012 to halt Iran's nuclear program. These sanctions persisted until the JCPOA when most secondary sanctions were lifted and many foreign companies resumed their businesses in Iran. However, after Trump was elected president and unilaterally withdrew from the JCPOA in 2018, the secondary sanctions were re-imposed in an intensified manner. Despite its opposition to the US approach, the European Union (EU) has recalled its companies from Iran following the US withdrawal from the JCPOA. Therefore, the main question of this study is as follows: How did the US secondary sanctions against Iran affect the EU’s approach to the JCPOA? The hypothesis was evaluated through a descriptive-analytical method in response to this question within the framework of secondary sanctions. Accordingly, the US hinders the EU’s independent approach by imposing secondary sanctions against European companies, banks, and private sector in general. The results indicate that the EU cannot act independently of the US to resolve major international issues (e.g., the JCPOA) due to the structure of secondary sanctions. In fact, if the EU contradicts the general policies of the US toward Iran, the US will impose different sanctions on European entities. It will also place the EU’s private sector under pressure.