35 2015 The agreement reached in Vienna over the Joint Comprehensive Plan of Action (JCPA) between Iran and the E3+3 (France, Germany, the UK, China, Russia and the US) lays the ground for the gradual lifting of restrictive measures imposed against the Islamic Republic. Having already activated a first round of limited (and reversible) sanctions relief alongside the US in January 2014, the EU is now set to adopt an ‘exit strategy’: a procedural road- map to ease punitive measures in accordance with Iranian compliance. With a track record of effectively rewarding acqui- escent targets, the EU stands out as a responsive ‘sanctioner’. In contrast to the US, the EU has re- peatedly adopted a strategy aimed at incentivising progressive compliance with economic and diplo- matic pay-offs. Lifting sanctions The lifting of sanctions is technically less difficult than often presumed. Following a heated debate at the United Nations Security Council (UNSC) on the embargo against Iraq in the late 1990s, the UN moved from enacting open-ended sanctions to adopting so-called ‘sunset clauses’ which foresee a date for the expiration of restrictive measures. The EU was quick to start inserting such clauses in its CFSP sanctions acts, which are envisaged to be reviewed once a year. However, they also stipulate that they ‘shall be kept under constant review’, and foresee the possibility that they ‘may be renewed, or amended as appropriate’ (as was the case of Syria). While open-ended sanctions regimes make con- tinuation ostensibly easier than termination, sun- set clauses reverse this situation. In theory, each EU member state can veto the renewal of sanc- tions on account of the unanimity requirement, thereby precipitating an abrupt end to the meas- ures. However, to date, no single member state has ever vetoed the renewal of a sanctions regime. While the process of building consensus within the Council can be time-consuming, it testifies to member states’ commitment to a common foreign policy. Terminating a sanctions regime is easier for the EU than for the US. In the EU, a unanimous deci- sion by the Council suffices to lift sanctions, as no parliamentary approval – either by the European Parliament or by national assemblies – is required. In the complex US system, certain sanctions can be lifted by the president, while others – typically the most severe – can only be removed by Congress. Although the loosening of sanctions regimes is of- ten initiated by the president, congressional ap- proval is necessary for their complete termination. The case of Burma/Myanmar illustrates this well: the Oval Office removed all restrictions within its power, while Congressional measures remain in place. Similarly, the current rapprochement with Cuba consists exclusively of steps taken by the Obama administration, while the trade embargo EU sanctions: exit strategies by José Luengo-Cabrera and Clara Portela YUKI MATSUEDA / REX FEA/REX/SIPA European Union Institute for Security Studies July 2015 1