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The European Union, through the countries of the E3 – the UK, France and Germany – as well as the European High Representative for External Affairs, played a critical and central role in negotiating the Joint Comprehensive Plan of Action (JCPOA), commonly referred to as the Iran nuclear deal. This was a major achievement for a European community of states whose external policy and actorness on the international stage as a bloc is still a matter of debate whose foreign policy institutions are deemed by many to still be a work in progress.

After the withdrawal of the United States from the JCPOA under President Trump, the E3/EU took the lead in trying to reassure Iran of the deal’s viability in an effort to avoid the deal’s implosion. While Iran did not leave the agreement, it did reduce its compliance with the agreement in a series of steps. While the E3/EU’s political position in support of the agreement was important to the structure of the JCPOA remaining intact, they were unable to sway European economic actors away from heeding Washington’s extraterritorial writ.

The EU/E3 unsuccessfully erected two major initiatives to blunt US sanctions: A bartering facilitator mechanism known as INSTEX was created to facilitate financial flows and the activation of the so-called blocking statutes in order to stem the tide of European firms leaving Iran. The mechanism ultimately failed to provide financial transactions and the credibility of the blocking statutes was never meaningfully established[1].

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[1] Werner, M. J., Kampouridi, J., & Ryzgelyte, L. (2019). Undertakings caught in the crossfire: US sanctions on Iran vs. the EU Blocking Regulation and possible compensation as State aid. ERA Forum, 20(1), 63–79. doi.org/10.1007/s12027-019-00564-y. See also ​​O’Tool, B. (2019). Facing Reality: Europe’s Special Purpose Vehicle Will Not Challenge US Sanctions. , August 26. Atlantic Council. https://www.atlanticcouncil.org/blogs/iransource/facing-reality-europe-s-special-purpose-vehicle-will-not-challenge-us-sanctions/