What the EU and U.K. Should Do Now to Hold Iran Accountable

Click here to view what the US should do to hold Iran Accountable.

There are many tools that the European Union (EU) and United Kingdom (U.K.) should use to hold Iran’s regime accountable for its human rights abuses, engagement in and support for terrorism, and missile and drone proliferation.

The governments of EU member states and the U.K. should take the following actions to hold Iran accountable:

• Publicly acknowledge and support the Iranian people’s goals: the end of the Islamic Republic and the establishment of a democratic, accountable government that upholds human rights in its place.
• Declare the termination of the Joint Comprehensive Plan of Action (JCPOA). Reviving this 2015 deal will only bankroll the Iranian regime’s oppression in exchange for expiring nuclear restrictions.
• Support invoking the snapback sanctions mechanism under U.N. Security Council Resolution 2231, which endorsed the JCPOA. Snapback will reinstate international restrictions on Iran—like the arms embargo, which lapsed in 2020—and extend the limitations on its missile program, which expire in October 2023. Iran’s security forces must not acquire international assistance to make their arsenals more lethal.
• Insist on the unconditional release of all hostages, given Iran’s longstanding and increasing detention of European nationals.
• Work with the U.S. to develop creative, innovative approaches to ensure internet freedom for Iranians, including government partnerships with the private sector for satellite-based services. Additional support should include funding such efforts.
• Support efforts to jam the Iranian regime’s ability to shut down internet access in Iran and use creative intelligence disclosures to assist Iranian revolutionaries in their movement. This includes the use of offensive cyberoperations hampering the ability of Iran’s Communications Regulatory Authority and internet service providers in shutting down the internet.
• Work with and encourage social media platforms such as Instagram and Twitter to hinder Iran’s cyber army’s efforts to suppress the voices of Iranian activists through tactics like shadow banning.
• Call on all social media platforms to ban the accounts of Iran’s Supreme Leader, Ayatollah Ali Khamenei, and other senior regime officials, who spread their propaganda to millions while denying Iranians access to the same platforms.
• Expel agents of the Iranian regime who work against European interests. This includes shuttering entities, like the Hamburg Islamic Center in Germany, which provide a permissive environment for terror recruitment for Iran’s regime, and the Islamic Center of England, which houses Iran’s Supreme Leader’s representative office in the U.K.
• Isolate Tehran diplomatically by reducing Iran’s diplomatic presence in Western capitals, recalling European ambassadors, suspending official visits, and mounting campaigns to strip Iran of its membership in international organizations.
• Use Malta’s February 2023 presidency of the U.N. Security Council to hold multiple Council meetings on Iran’s human rights abuses, hostage taking, engagement in and sponsorship of terrorism, weapons proliferation, and other malign activities, and to vote on a resolution imposing further sanctions on Iran for those activities (going beyond snapback).
• Support multilateral sanctions against Iran’s senior leadership for human rights abuses, using European Magnitsky Act authorities and harmonizing their respective human rights sanctions with the U.S. and other G7 countries. For example, almost 150 individuals and entities are sanctioned for human rights abuses by the U.S. but not by the EU. Key sanctions targets should include Iran’s Supreme Leader Ayatollah Ali Khamenei; President Ebrahim Raisi; the supreme leader’s son, Mojtaba Khamenei; and other top Iranian decision-makers and shapers.
• Conduct an immediate survey of all Iranian regime officials’ relatives who live in Europe and are profiting off the Iranian establishment’s corruption, with a view to revoking their visas and confiscating their assets. One Iranian study suggests there may be 3,000-4,000 children of Islamic Republic officials living abroad. British MPs have recently expressed concern that London is becoming a “safe place of refuge” for regime elites. Similar efforts have targeted Russian oligarchs in the aftermath of Moscow’s invasion of Ukraine. 
• Sanction Iran’s Islamic Revolutionary Guard Corps (IRGC) in its entirety as a terrorist organization, as the U.S. has done. The IRGC has been responsible for multiple terror plots on European soil, is working with Russian forces in Ukraine, and is engaged in transnational repression against Iranian dissidents living in Europe. 
• Sanction the Iranian proxy Hezbollah in its entirety as a terrorist organization, a step that would be particularly significant now given the group’s reported role in suppressing protests in Iran. Hezbollah itself has confirmed on multiple occasions that it does not differentiate between “political” and “military” wings.
• Sanction the Iranian proxy group the Houthis (a.k.a. Ansar Allah) as a terrorist organization. The Houthis use Iranian drones and missiles to regularly target cities and critical infrastructure in Europe’s Gulf partners’ territory, home to many thousands of European citizens.
• Prohibit European companies from insuring or reinsuring ships carrying Iranian oil anywhere in the world, as is the case with Russia, and from providing insurance or reinsurance for the National Iranian Oil Company, the National Iranian Tanker Company, or any of its associated vessels.
• Help the U.S. to enforce all sanctions on Iranian oil through information exchange and interdictions of Iranian oil shipments, which sustains regime finances with billions of dollars of revenue—particularly from China.
• Ban all Iranian terrorist-linked airlines—including Mahan Air and Iran Air—from landing in European airports. Mahan Air has long been the IRGC’s airline of choice, while Iran Air has been used to convey lethal drones and IRGC personnel to Russian forces to be used against EU candidate country Ukraine. These airlines continue to service some European countries, like the U.K. and Austria. 
• Terminate all banking licenses for Iranian banks still operating on European soil. Bank Sepah, Bank Melli, Bank Saderat, Middle East Bank, and the European Iranian Handelsbank all operate in Germany. France and Italy also permit multiple U.S.-sanction-designated Iranian banks to do business there. Bank Sepah, for instance, has provided “direct and extensive financial services” to Iran’s Aerospace Industries Organization (AIO), which is responsible for managing the Iranian missiles and satellites program. These banks also resource the very repressive security institutions which abuse the Iranian people.
• End any so-called ‘trade envoy’ roles specifically designed to facilitate business with the Islamic Republic. The U.K., in particular, continues to employ a trade envoy, whose comments are regularly cited in the Iranian press for propaganda purposes. Terminating these positions would clearly signal to domestic firms that doing business with Iran is unacceptable and explicitly discouraged.
• Work with the U.S. to develop a forum to provide the Iranian diaspora a platform to organize around a common agenda to represent the Iranian people before the international community. A first step should include hosting an international conference for the Iranian people. Funding for this initiative could come from part of the Iranian regime’s frozen assets which are held abroad.