The EU Needs an Iran Strategy, Not Just “More Sanctions”

The past couple of years have seen Europe’s Iran strategy run into one roadblock after another. It was as toothless against the US withdrawal from the 2015 nuclear deal as it was against the regime’s brutal repression of its citizens. If the former pushed Tehran to ramp up its nuclear activities, the latter has left the population largely impoverished, imprisoned, or in exile. All the while, Tehran has doubled down on destabilizing the region through allied militias in third countries, most viciously through its long-running support for Hamas against Israel.

Given this track record, European policymakers need to rethink their approach to Iran and formulate a new policy that puts people, not just states, and human security, not just the military type, at its core. The guiding question both for defining an immediate response and to develop a long-term strategy should be: How can the EU’s actions help the safety and security of people in Iran and the region, while advancing European interests and values? Answering it begins with the realization that the current approach offers neither the right instruments nor an applicable strategic framework.

How can the EU’s actions help the safety and security of people in Iran and the region?

We will therefore, first, assess the EU’s current Iran policy, focusing in particular on the use of sanctions as a standard response to Iran’s damaging actions. We then point out how this one-sided approach fails to take into account the effective promotion of human rights, adequate support for civil society, and the consideration of a broader regional security concerns. Finally, we propose a set of guiding principles for a new European approach vis-à-vis Iran. It centers on the prioritization of a comprehensive and consistent human rights perspective, the critical reflection on the use of sanctions, and the sustained support for, and consultation with, civil society.

Europe’s Iran policy is increasingly disconnected

For years now, the Islamic Republic has violently suppressed its people, created instability in the region, and threatened European security, including the safety of individual citizens by targeting diaspora activists or engaging in hostage diplomacy. In the past, it was possible to see the country as a challenge for specialists to deal with – either security wonks, especially nuclear experts, or human rights activists, but seldom the two together. Yet, already in September 2022, the EU was unable to reconcile those perspectives in the face of the regime’s brutal repression of the “woman, life, freedom” movement sparked by the death in custody of the young Kurdish woman Jina Mahsa Amini. Today, the most recent set of regional escalation in the wake of the October 7 attack by Hamas and the ensuing war in Gaza has brought the long-running Iranian-Israeli shadow war into the open – with possibly devastating consequences for the whole region, but without a recipe by Europe for how to deal with it.

Europe’s lack of response is not lost on the Iranian leadership, which has further increased its harsh crackdown on civil liberties at home as international attention focuses on the regional turmoil. On the day of Iran’s attack on Israel on April 13, morality police resumed its patrols in a campaign to round up and imprison women for allegedly violating the state’s stringent dress code. Just last month, the UN Fact Finding Mission on Iran formally confirmed that the Islamic Republic committed crimes against humanity, including gender persecution, in the squelching of the protests. And even this followed a years-long increased crackdown on civil society and an escalation of repressive measures against women, all within an economic situation that is harsh for the majority of Iranians, but harder still for women, marginalized and vulnerable groups.

All the while, the EU’s approach focused on trying to reinstate a nuclear deal, leading to a one-sided policy giving little priority to the dire human rights situation in the country or to address other elements of regional destabilization. Once these issues came to dominate the headlines, the EU responded with its go-to policy tool of the past 20 or so years: sanctions. Even the European Parliament, which used to be fairly critical of the EU’s sanctions policy in support of the nuclear negotiations in the early 2010s, only had more sanctions to propose in response to Iran’s unprecedented attack against Israel: against the Islamic Revolutionary Guards’ Corps (IRGC), against the entirety of the Lebanese Hezbollah (not just its military arm), and via the UN sanctions snapback if Iran continues to obstruct the inspection work of the International Atomic Energy Agency (IAEA).

The question, however, is this: Can the proposed measures achieve the stated aims of changing Iran’s behaviour?

Sanctions are a double-edged sword in need of direction

Looking at their purpose, design, implementation, and eventual effect of sanctions, serious doubts about their usefulness arise.

• Purpose: If sanctions intend to change the behaviour of the targeted party, they arguably worked on Iran in the context of the negotiations leading to the nuclear deal of 2015. This is in line with research suggesting that sanctions can be successful in support of clearly formulated, specific demands. In contrast, the unilateral sanctioning of Iran by the United States under its “maximum pressure” campaign beginning in 2018 appears rather detached from actual outcomes: It is a case of signalling, whether towards the adversary, other actors, or one’s public, a readiness to act (sort of) but without progress towards the declared policy goals, and instead a willingness to accept detrimental effects on the Iranian people.
  
   
• Design: Targeted human rights sanctions are broadly accepted to be less harmful than sectoral ones and indeed remain among the few accountability instruments at hand. Even so, they can still do more damage than good if badly designed. So far, the EU’s listing of entities or individuals is largely done by national foreign ministries, with little to no input from those who could assess the measures’ potential effects on the ground, whether on civil society, people’s lives, or specific human rights projects and mechanisms. Worse, the strong signalling effect of sanctions – the ‘punishing’ of an antagonist – usually overrides other priorities like human rights or regional cooperation.
  
   
• Implementation: With evidence of recurring trips by listed Iranian officials to Europe, the need to assess the actual reach of sanctions has been recognized in academic and policy communities – however, without practical consequences. As member states are responsible for the implementation of visa bans and asset freezes, it falls on them to establish coordinating or controlling mechanisms, or guidelines for more effective sanctions implementation. However, reinforcing existing measures does not have the same communicative value as slapping new ones on a ‘bad actor’, which is why the latter if often chosen over the former.
  
   
• Effect: The outcomes of sanctions are notoriously hard to measure, given the vast number of intervening factors. That said, it has become evident that strangling financial and economic sanctions have hurt the Iranian population more than the regime. While the latter has developed intricate ways to evade and circumvent sanctions, regular citizens struggle with higher import prices and the increased cost of receiving remittances which are barely accessible to them. Already suffering from repression, corruption, and mismanagement, they now also see their capacities for political agency weakened: If people are trying to make ends meet, the time, mental capacity and resources for political activism fade.

Under these circumstances, the prominent call for a terror designation of the IRGC looks particularly misguided. For one, it would not go beyond the existing sanctions against IRGC members based on the EU’s measures under its countering weapons of mass destruction (WMD) policy. It would therefore be a rather symbolic measure that may have its merits as such but does not provide the EU with leverage to make Iran budge. The foremost example is Washington’s terror listing of the guards under the previous administration, which evaporated in the plethora of existing US sanctions. To the contrary, banning all entities, institutions, and organizations only loosely associated with the IRGC will make any diplomatic or civil society contacts into the country much more difficult, if not impossible, given how thoroughly this organisation has permeated the country after decades of sanctions. Therefore, the potential repercussions both on the socio-economic situation of Iranians in general and on civil society and human rights work more specifically are important criteria for any listing of the IRGC, in addition to an actual assessment of how much such a listing would prod the regime to refrain from its most egregious policies.

This creates a double paradox: The EU ultimately wants to alter Iran’s behaviour, yet it pursues policies leading to a weakening of the most important change agents, namely people and civil society. In addition, an overly isolationist approach takes away any remaining leverage Europe might have while increasing Iran’s exposure to supporters like China and Russia. Solely applying more pressure without an overarching strategic framework and complementing actions will not produce the desired results; instead, it will lead to a worsening of human security in Iran and the region.

A human rights and regional security framework

Any strategic approach aiming to weaken the Iranian regime without further harming the citizens while strengthening Iranian civil society would have to include further internal and external factors. Key elements include human rights promotion and civil society support as well as regional security.

For years, European policy prioritized the nuclear negotiations over confronting the regime’s gross human rights violations.

The women’s and human rights situation as well as the existence of a civic space are the proverbial canary in the coal mine for the internal and external peacefulness of a given state. Research suggests that a state that is violent and oppressive towards marginalized groups on the inside is more likely to act aggressively towards the outside as well. And indeed, human rights are one pillar of EU policy towards Iran, but more on paper than in practice. For years, European policy prioritized the nuclear negotiations over confronting the regime’s gross human rights violations. That was an arguable stance as long as diplomacy progressed, but the lack thereof following the US withdrawal from the deal and the violent repression of recurring protests since then lay bare its weaknesses.

The European response to the regime’s crackdown of the “woman, life, freedom” uprising serves as an example of this lack of a comprehensive approach. The measures taken, ranging from sanctioning certain individuals and institutions to promoting accountability mechanisms at UN level, remained rather isolated steps. What has been missing is the momentum to build a more strategic setting in which a human rights perspective is considered equal in importance to security considerations and complemented by actual support for those who keep demanding their rights from within. The fact that there has not been a strong EU response to the March 2024 report by the UN Fact-Finding Mission on Iran, which established that Tehran committed crimes against humanity, is a stark illustration of this incoherent approach. Nor has little systematic programming taken place to support human rights or to strengthen civil society actors in Iran, even though the disconnect from independent voices in the country is a major challenge for EU policymaking on Iran.

Lastly, the regional dimension has come into renewed public focus since the autumn, yet without prompting attempts to craft a comprehensive European approach. Instead, the political context of a region with interwoven conflicts has been put aside. This may have been plausible for the specific non-proliferation issues around Iran’s nuclear program dealt with in a multilateral setting. It becomes less so given the renewed eruption of the Israeli-Palestinian conflict, in which all neighbouring and Gulf states, including Iran, are invested to different degrees. That said, while the EU was, rightly so, quick to respond to Iran’s drones and missiles attack against Israel, it failed to condemn the latter’s preceding attack against an Iranian diplomatic installation in Damascus. Neither does it bring its full weight to bear by tying its immediate response to the ongoing war in Gaza, the moribund Arab-Israeli normalization process, or past attempts to work towards an eventual system of collective security in the region. Criticized of double standards, the EU evidently struggles to live up to its ambition to uphold international norms and human rights globally.

Guiding principles for a new approach towards Iran

No doubt, it is primarily on Iran to fundamentally change the situation, whether internally or in the region. Time and again, though, the regime has demonstrated its stern resistance to reform, which is why substantial change would have to come from within society. The West’s Iran policy, in turn, especially the United States’ broad economic sanctions, have led to a strengthening of the hardliners and a weakening of the population. In this context, for the EU to administer “more of the same” when present policies have failed to move the needle for the better, simply is not smart.

Instead, the comprehensive human security-centred approach suggested here provides a viable alternative. Devising such a policy builds on the realization that simply pursuing power politics risks contributing to further military escalation. Instead, a power critical analysis of regional dynamics and a focus on political solutions – whether for the conflict between Iran and Israel, the war in Gaza, or regional non-proliferation concerns – is needed. Those EU member states pursuing a feminist foreign policy will recognize these principles as feminist in their core, while its essential elements remain accessible to all others – including the EU as a whole – that do not adhere to a feminist framework.

Three such principles stand out: to look at comprehensive human rights perspectives, to revise the use of sanctions, and to include civil society expertise into policymaking, whether the issue is Iran’s domestic situation, regional security affairs, or international concerns regarding its nuclear program.

1. Prioritize a comprehensive human rights perspective

The EU needs to walk its talk on human rights and establish their protection as a goal in itself, equal to the other interests it pursues. This means to develop a strategic framework including political action as well as programmatic support, backed by political will and leveraged through financial means. Such a framework requires the mainstreaming of human rights in all dimensions of the EU’s Iran policy, ranging from security policy and economic and social aspects to environmental issues and the digital sphere.

Such a framework requires the mainstreaming of human rights in all dimensions of the EU’s Iran policy.

It specifically includes the strengthening of human rights in Iran and the protection of women and human rights defenders wherever they may choose (or be forced) to work. It also implies to credibly follow through and strengthen accountability mechanisms, including but not limited to acting upon the UN fact finding mission’s recent recommendations and supporting its renewed mandate. Concretely, neither the EU nor its member states should retract on the language and content of the mission’s report, whose documented crimes against humanity and gender persecution provide the grounds for international criminal persecution.

To be consistent and credible, the EU needs to consider human security, gender equality, and women’s and human rights across the board, especially in a region where states jealously watch for any perceived double standards. This means that the yardstick used to judge Iran’s gross human rights violations and regional destabilization tactics should be equally applied to the actions of neighbouring countries such as Saudi Arabia, the other Gulf countries, or Egypt. And it would, self-critically, extend to an assessment of the damage done to the EU’s credibility as a serious human rights actor given its wavering stance on Israel’s war in Gaza.

Rather than addressing – or not – these various crises and conflicts in isolation, the EU should strive to turn the current calamity into an opportunity to help devise a regional security mechanism. Steered by the countries concerned and shepherded by the UN, initial talks should on concrete and attainable issues such as maritime security and nuclear safety, before working towards broader de-escalation and confidence-building measures.

2. Critically assess the use of sanctions as a policy instrument

Sanctions do have a place in any international actor’s toolbox; the problem is their overuse without considering eventual outcomes or possible alternatives. Rather than to blindly believe in sanctions as a sinecure, the EU should integrate existing and new sanctions into a broader strategic framework with complementary action to reach its goals.

The EU should integrate existing and new sanctions into a broader strategic framework.

Given the relative value and high symbolism of targeted human rights sanctions, the EU should continue to apply these as means of ensuring accountability. Also, symbolic signalling has its own usefulness if accompanied by supporting policy measures designed to achieve the same goal. To increase the reach and effectiveness of targeted sanctions, the EU should coordinate its new listings and the efforts to close loopholes of existing ones not just with important partners (namely Canada, the United Kingdom, and the United States), but also in multilateral settings, wherever possible. As nuclear diplomacy with Iran showed, it was the – relative – unity of the negotiation partners that gave the stringent measures applied, whether in the UN context or autonomously by the EU and the United States, their teeth.

Obviously, there is much less agreement between the Western allies and China or Russia now. This however, makes a rigorous assessment of the expected impact of restrictive measures only more necessary, both regarding their intended goals and their potentially harmful consequences. To that end, member states should collaborate with the EEAS to establish mechanisms for civil society-inclusive harm assessments and due diligence. This will also help the EU to avoid having to lift sanctions against some individuals or institutions in response to a court ruling.

3. Strengthen and consult with civil society

Working with civil society both when designing sanctions (such as through an inclusive ex ante harm assessment) and measuring their impact is key for turning such often-symbolic measures into a more impactful and less harmful policy instrument. Moreover, civil society professionals and human rights defenders can contribute with their expertise to expand the EU’s policy options, so that imposing sanctions does not become a knee-jerk reaction to a festering crisis. Moreover, an intersectional perspective will help recognize the diversity of civil society actors, be it in their field of work, ethnic identity, or social background.

In any policy area towards Iran, the EU should include effective instruments for civil society consultation at eye-level.

This contribution to policymaking comes in addition to civil society’s ‘traditional’ role on the ground, which the EU should strengthen more systematically. In any policy area towards Iran, the EU should include effective instruments for civil society consultation at eye-level. The goal should be to enable civil society actors to voice their priorities rather than just responding to external demands. Also, the EU should aim to decrease the barriers to representation and participation, trying to reach a variety of actors representing diverse voices and actors, including under-represented and marginalized groups. Importantly, it needs to evaluate the impact its actions have on civil society organisations’ ability to keep up their work (“do no harm” being an age-old principle of human security).

Finally, given the regional dynamics at play, the EU should strive to learn from examples provided in the wider context, such as the “Supporting the Future of Syria and the Region” conference and the “Days of dialogue component”. Based on such efforts and their lessons learned, it should assess the potential establishment and continued support, including via financial means, of a coordination platform for Iranian civil society, especially outside Iran. This platform should have a clear strategy, mandate, and goals to coordinate human rights interventions and informing decisions at the governmental and European level. Once set up, the platform can help the EU develop the more strategic and regional approach it so urgently needs.

With the human rights situation in Iran hitting a new rock-bottom, no tangible mechanism for nuclear non-proliferation in sight, European-Iranian relations deteriorating, the security situation in the region worsening, and the EU preparing for a new leadership by the fall, the time is ripe for new approach to Iran.

This paper has outlined the guiding principles for such a strategic framework that builds on the values of feminist principles, such as human security, women’s and human rights, focuses on civil society as a major source of change, and prioritises regional security over unilateral sanctions. EU institutions will find ready partners – in member states, in the region, and at EU and international level but above all in an active and professional civil society and human rights community – to begin fleshing out the details and developing concrete instruments to bring such a policy to bear.