Washington, DC – Yesterday the Trump Administration announced an “Economic D-Day” that would target “the Islamic Republic of Iran and its enablers.” Yet the first actions they have taken under this campaign are aimed squarely at ordinary Iranians and at severing personal, familial, academic, and cultural relationships between Americans and Iranians.
The Administration has suspended key humanitarian exemptions from existing sanctions on Iran designed to allow Iranian Americans to send personal remittances to family in Iran, to allow universities to enroll or offer scholarships to Iranian students, and to allow for sports exchanges involving American and Iranian athletes.
These include:
- 31 CFR § 560.544: Allowing universities to recruit, enroll, and educate students who are ordinarily resident in Iran, and offer them scholarships;
- 31 CFR § 560.550: Allowing Americans to send personal, non-commercial remittances to non-sanctioned persons in Iran.
- 31 CFR § 560.554 and Iran General License G: Allowing academic and educational exchanges between the U.S. and Iran.
- Iran General License F: Allowing for friendly matches and other sports exchanges involving the U.S. and Iran.
For years, as U.S. sanctions on Iran have escalated, policymakers have claimed they are aimed at the Iranian government rather than ordinary people. These carveouts that are now being suspended by the Trump Administration were put in place in response to clear areas where sanctions were hurting ordinary Iranians and undermining U.S. interests. The exemptions were far from perfect and have often run into severe complications due to the myriad of overlapping sanctions on Iran and an enforcement environment that fosters overcompliance. Yet rather than devote U.S. resources to strengthening sanctions exemptions for ordinary people and making the sanctions “smarter” by targeting them against decisionmakers and bad actors, the Administration is making our sanctions dumber and even more blunt.
The Trump Administration is spinning this latest sanctions focus as a novel escalation that is somehow distinct from the decades of comprehensive sanctions imposed by the U.S. and Iran, including Trump’s own “maximum pressure” sanctions. But the fact that there is little left to sanction in Iran may explain why the Administration is instead undoing protections from sanctions that have long been in place because they were universally viewed as benefiting U.S. interests and the Iranian people alike.
NIAC President Jamal Abdi makes clear: “We have had decades of sanctions underscore that collective punishment is strategically and morally wrong. Iranian civilians have grown poorer while the government elite has been unscathed.”
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