Biden Sanctions Iran: A Complex Policy Under Scrutiny

Kenyon Legros 18 Jun 2025

The intricate web of US foreign policy often finds its most challenging knots in the Middle East, and few relationships are as fraught with tension and strategic maneuvering as that between the United States and Iran. At the heart of this complex dynamic lies the persistent use of sanctions – a powerful economic tool wielded by successive US administrations to influence the Islamic Republic's behavior. Under President Joe Biden, the approach to Iran has been a nuanced, often contradictory, dance between imposing new restrictions and waiving existing ones, all while aiming to bring Tehran back to the negotiating table for a nuclear deal. This article delves into the various facets of the Biden administration's sanctions policy on Iran, examining its rationale, its impact, and the ongoing debate surrounding its effectiveness.

The Biden administration inherited a highly strained relationship with Iran, largely due to the "maximum pressure" campaign of the previous administration. Navigating this landscape requires a delicate balance, aiming to curb Iran's nuclear ambitions and destabilizing regional activities while avoiding outright conflict. The policy has seen shifts, waivers, new impositions, and considerable debate, reflecting the multifaceted challenges of dealing with a nation described as the world's leading state sponsor of terrorism.

The Shifting Sands of US-Iran Policy: An Overview
- Rescinding Trump-Era UN Sanctions: A Bid for Diplomacy
- The JCPOA's Shadow: Rejoining the Nuclear Deal
The Economic Lever: Sanctions and Their Impact
- Oil Sanctions and American Influence
- Frozen Assets and Waivers: Billions at Play
Balancing Act: Sanctions, Waivers, and Regional Dynamics
- Civil Nuclear Cooperation and Strategic Partnerships
- Iraq's Energy Dependence: A Case Study in Waivers
New Sanctions: Responding to Evolving Threats
- Missile and Drone Programs: Post-Attack Measures
- Election Interference and Broader Geopolitical Concerns
The Effectiveness Debate: Enforcement vs. Circumvention
Trendlines Under Biden: Oil, Military, and Nuclear Advances
Scrutiny and Criticism: Lawmakers and Advocacy Groups
Looking Ahead: The Future of Biden's Iran Policy

The Shifting Sands of US-Iran Policy: An Overview

When President Joe Biden took office in January 2021, the landscape of US-Iran relations was defined by heightened tensions and a complete breakdown of the 2015 nuclear agreement, officially known as the Joint Comprehensive Plan of Action (JCPOA). Former President Donald Trump had unilaterally withdrawn the US from the deal in 2018 and reimposed stringent sanctions, severely impacting Iranian economies. This "maximum pressure" campaign aimed to force Iran to renegotiate a more comprehensive deal, but it instead led to Iran gradually rolling back its commitments under the JCPOA and accelerating its nuclear program.

At the outset of the Biden administration, Iran was led by President Hassan Rouhani, a centrist cleric who had previously championed the 2015 nuclear deal and advocated for improved relations with the West. However, ultimate authority rested with Supreme Leader Ali Khamenei, who held decisive power over Iran’s foreign and security policies. The Biden administration's primary goal was to reverse the course of confrontation and seek a diplomatic path, specifically aiming to bring Iran back to compliance with the JCPOA and eventually rejoining the agreement itself.

Rescinding Trump-Era UN Sanctions: A Bid for Diplomacy

One of the earliest and most significant moves by the Biden administration to signal a shift in policy was the rescinding of former President Donald Trump’s restoration of U.N. sanctions on Iran. This announcement, made by the United Nations (AP) in February 2021, was a clear indication that Washington was moving toward rejoining the 2015 nuclear agreement. The Trump administration had controversially declared in 2020 that it was triggering a "snapback" of all UN sanctions on Iran, arguing that the US was still a participant in the nuclear deal for the purpose of triggering this mechanism, despite having withdrawn from it. This move was widely rejected by most UN Security Council members, who argued the US had no legal standing to do so.

By rescinding this declaration, the Biden administration aimed to remove a major diplomatic obstacle and create an environment more conducive to negotiations. It was a strategic step to rebuild trust, or at least reduce distrust, and demonstrate a commitment to diplomacy over unilateral pressure. This decision was seen as a necessary precursor to any meaningful talks about reviving the JCPOA, as it acknowledged the international consensus that the US was not in a position to unilaterally reimpose UN sanctions.

The JCPOA's Shadow: Rejoining the Nuclear Deal

The ultimate objective behind many of the Biden administration's early policy adjustments regarding Iran was to pave the way for rejoining the JCPOA. The 2015 agreement, which provided sanctions relief in exchange for verifiable restrictions on Iran's nuclear program, was seen by the Biden team as the most effective way to prevent Iran from developing nuclear weapons. President Biden was keen to bring Iran back to the negotiating table, and worried that a crackdown on Iran’s oil trade might fire up hardliners and push Iran further away from diplomacy.

However, the path to rejoining the deal proved far more arduous than anticipated. Iran, having endured years of crippling sanctions and having expanded its nuclear activities in response to the US withdrawal, demanded stronger guarantees and greater sanctions relief. While the Biden administration expressed a willingness to lift sanctions consistent with the original deal, it faced domestic political opposition and Iran's escalating demands. The negotiations, primarily held in Vienna, stalled repeatedly, complicated by shifts in Iranian leadership and persistent disagreements over the scope and sequence of compliance. The challenge for the Biden administration was to find a way to re-engage while demonstrating resolve against Iran's continued nuclear advancements and regional destabilizing activities.

The Economic Lever: Sanctions and Their Impact

Sanctions are a double-edged sword. While they aim to pressure a target regime, they can also have unintended consequences, affecting the civilian population and potentially strengthening hardline elements who blame external forces for economic woes. The Biden administration's use of sanctions on Iran has reflected this complexity, with both impositions and waivers playing a role.

Oil Sanctions and American Influence

One of the most potent forms of sanctions against Iran targets its oil exports, which are a primary source of revenue for the Iranian government. The previous Trump administration's strict financial measures had severely impacted Iranian economies, drastically reducing oil sales. However, the Biden administration's approach has been criticized by some for undermining American influence by lifting certain sanctions on Iranian oil, which in turn, critics argue, gives Iran leverage in the ongoing nuclear talks. While the explicit lifting of oil sanctions in a broad sense has not been a stated policy, the enforcement of existing sanctions has been a point of contention.

President Joe Biden has often waived the enforcement of these sanctions, particularly when keen to bring Iran back to the negotiating table. The rationale behind this selective enforcement is often to provide a degree of economic relief that encourages diplomatic engagement, rather than pushing Iran further into isolation. However, this approach has led to accusations that the administration is inadvertently funding Iran's illicit activities and its nuclear program by allowing it greater access to oil markets, even if unofficially.

Frozen Assets and Waivers: Billions at Play

A recurring theme in the Biden administration's Iran policy has been the issuance of sanctions waivers that allow Iran access to previously frozen assets. In October 2023, and again in January 2024, conservative news outlets reported that the U.S. President Joe Biden's administration had granted Iran $10 billion in sanctions relief, allowing access to frozen funds. These reports fueled significant controversy, particularly after the Democrats’ election losses in November 2023. Critics argue that giving the Islamic Republic of Iran — the world’s leading state sponsor of terrorism — access to billions of dollars of frozen assets, undermines US security interests and emboldens a hostile regime.

For instance, on Wednesday, it was reported that the Biden administration was imposing sanctions on another Israeli while reissuing a sanctions waiver that lets Iran access more than $10 billion in frozen funds. This juxtaposition of sanctioning an ally while providing financial relief to an adversary has drawn sharp criticism. The administration's defense for such waivers often centers on humanitarian grounds or facilitating specific transactions that are deemed beneficial for regional stability or de-escalation, but the optics and strategic implications remain hotly debated.

Balancing Act: Sanctions, Waivers, and Regional Dynamics

The application of sanctions and waivers is not just about the nuclear program; it's also deeply intertwined with regional stability and strategic partnerships. The Biden administration has had to navigate complex relationships, ensuring that its Iran policy doesn't inadvertently destabilize key allies or humanitarian efforts.

Civil Nuclear Cooperation and Strategic Partnerships

In a move aimed at facilitating a return to the JCPOA and ensuring transparency in Iran's nuclear activities, the Biden administration restored a sanctions waiver that allows countries to cooperate with Iran on civil nuclear projects. This decision, announced by two senior US officials, is crucial for several reasons. It permits international partners, such as Russia and China, to continue working with Iran on projects that are designed to make its nuclear program less proliferation-prone, such as converting its Arak heavy water reactor to a light water reactor, which produces less plutonium. These projects were part of the original JCPOA and are seen as vital for preventing Iran from developing nuclear weapons covertly.

By allowing these collaborations, the administration aims to maintain a degree of international oversight and technical assistance that helps keep Iran's nuclear program within civilian bounds, even as broader nuclear talks face challenges. This waiver is a strategic tool, demonstrating a commitment to the technical aspects of non-proliferation while negotiations continue on the political front.

Iraq's Energy Dependence: A Case Study in Waivers

Another significant instance of a sanctions waiver involves Iraq's energy sector. The Biden administration renewed a 2018 sanctions waiver for Iraq on November 7, 2024, allowing Iraq to continue to purchase energy from Iran. This waiver is critical because Iraq is heavily dependent on Iranian natural gas and electricity to meet its energy needs, especially for power generation. Without this energy, Iraq faces severe power shortages, which could lead to widespread unrest and instability.

This waiver highlights a fundamental challenge in applying sanctions: balancing the desire to pressure Iran with the need to avoid destabilizing key regional allies. While the US seeks to curb Iran's influence, it also recognizes that a stable Iraq is vital for regional security. The waiver allows Iraq to pay for Iranian energy through restricted accounts, ensuring that the funds are used for humanitarian goods or other non-sanctionable items, rather than directly funding the Iranian government's illicit activities. This specific waiver demonstrates the pragmatic approach taken by the Biden administration in certain cases, prioritizing regional stability and humanitarian concerns over strict adherence to sanctions enforcement.

New Sanctions: Responding to Evolving Threats

Despite the instances of sanctions waivers and efforts to revive the nuclear deal, the Biden administration has also periodically promulgated new sanctions against Iran and its proxies. This demonstrates a dual-track approach: pursuing diplomacy while simultaneously countering Iran's destabilizing actions and human rights abuses. This is a sound policy, acknowledging that engagement does not preclude accountability.

Missile and Drone Programs: Post-Attack Measures

In response to specific provocative actions by Iran, the Biden administration has swiftly imposed new sanctions. For example, following Iran’s unprecedented attack on Israel in April 2024, President Joe Biden announced new sanctions targeting Iran’s missile and drone program. This immediate response aimed to hold Iran accountable for its aggressive actions and to deter future attacks. The sanctions targeted entities and individuals involved in the production and proliferation of drones and missiles, which Iran uses to arm its proxies across the Middle East and supply to countries like Russia.

These targeted sanctions are distinct from the broader economic sanctions aimed at the nuclear program. They represent a punitive measure designed to degrade Iran's military capabilities and its ability to project power through its proxies. This aspect of the Biden administration's policy underscores a commitment to defending allies and responding decisively to threats, even as the broader diplomatic efforts continue.

Election Interference and Broader Geopolitical Concerns

Beyond the nuclear and regional security issues, the Biden administration has also imposed new sanctions on Russian and Iranian entities, accusing them of attempting to interfere with the 2024 U.S. elections. This highlights the multi-faceted nature of the threats posed by these actors and the comprehensive approach taken by the US government to counter them. Such sanctions aim to protect democratic processes and signal that malign foreign influence operations will not be tolerated.

These measures demonstrate that the Biden administration's use of sanctions extends beyond the nuclear file to encompass a broader range of national security concerns, including cyber warfare, disinformation campaigns, and human rights abuses. The periodic promulgation of these new sanctions reinforces the message that while diplomacy is preferred, the US will not hesitate to use its economic leverage to counter hostile actions.

The Effectiveness Debate: Enforcement vs. Circumvention

A central debate surrounding the Biden administration's sanctions policy on Iran revolves around its effectiveness. While sanctions are intended to deprive Iran of resources and compel behavioral change, critics argue that "sanctions without enforcement are easy to circumvent." This perspective suggests that the administration's perceived leniency or selective enforcement, particularly regarding oil sales and frozen assets, has allowed Iran to mitigate the economic pressure and continue its problematic activities.

The argument is that if Iran can find ways to sell its oil, access its funds, and continue its nuclear and regional programs, then the sanctions lose their coercive power. This concern is amplified by reports that suggest a surge in Iran's oil exports and military expenditures under Biden compared to the stricter enforcement period under Trump. The challenge for the Biden administration is to demonstrate that its sanctions policy is indeed effective in achieving its strategic goals, whether through deterring aggression, compelling negotiations, or limiting Iran's capabilities, rather than merely being a symbolic gesture.

Trendlines Under Biden: Oil, Military, and Nuclear Advances

Data from organizations like the National Union for Democracy in Iran (NUDIR) offers a critical perspective on the outcomes of the Biden administration's approach. According to NUDIR data, during Biden’s term, trendlines for Tehran’s oil exports, military expenditures, and nuclear advances all surged upward compared with relative restraint by the regime during the height of Trump sanctions from 2018 to 2020. This data forms the core of the criticism against the Biden administration's sanctions policy on Iran.

The increase in oil exports suggests that Iran has found ways to circumvent existing sanctions, possibly due to less stringent enforcement or new buyers. Increased oil revenue directly translates to greater funds for military expenditures and nuclear research, potentially undermining the very goals of the sanctions. This perceived surge in Iran's capabilities and resources under the Biden administration has led to significant concern among lawmakers and advocacy groups, who argue that the current policy is not achieving its stated objectives of reining in the Islamic Republic.

Scrutiny and Criticism: Lawmakers and Advocacy Groups

The Biden administration is under increasing scrutiny from lawmakers and advocacy groups for its handling of sanctions on Iran. The Times’s findings, likely referring to investigative reports or analyses, contribute to this growing pressure. Critics from both sides of the political spectrum have voiced concerns, albeit for different reasons.

Some argue that the administration's efforts to revive the JCPOA have been too lenient, providing Iran with economic lifelines without securing sufficient concessions on its nuclear program or regional behavior. Others contend that the continued imposition of sanctions, even with waivers, is counterproductive and only serves to entrench hardliners in Tehran, making diplomatic breakthroughs more difficult. The constant debate over the balance between pressure and diplomacy, and the perceived effectiveness of each, ensures that the Biden administration's Iran policy remains a highly contentious issue in Washington and beyond.

Looking Ahead: The Future of Biden's Iran Policy

The Biden administration's approach to Iran, characterized by a complex interplay of sanctions, waivers, and diplomatic overtures, reflects the enduring challenge of managing a volatile relationship. While the goal of preventing a nuclear-armed Iran remains paramount, the means to achieve it are subject to continuous debate and adjustment. The policy aims to be pragmatic, seeking to de-escalate tensions and provide pathways for diplomacy, even as it responds to Iran's aggressive actions with targeted sanctions.

As the geopolitical landscape continues to evolve, particularly with ongoing conflicts in the Middle East and the upcoming US elections, the Biden administration's sanctions policy on Iran will undoubtedly face further tests. The effectiveness of this policy will ultimately be judged by its ability to curb Iran's nuclear ambitions, limit its regional destabilizing activities, and avoid a wider conflict, all while navigating the intricate dynamics of international diplomacy and domestic political pressures.

What are your thoughts on the Biden administration's approach to Iran? Do you believe the balance between sanctions and waivers is effective, or do you think a different strategy is needed? Share your insights in the comments below, and don't forget to explore our other articles on US foreign policy and international relations.

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