based on Article (6) of the "Strategic Action for Lifting SANCTIONS and Protecting the Interests of the Iranian Nation" act passed by the Islamic Consultative Assembly (Parliament of the Islamic Republic of Iran) in December 2020, several indicators have been set on the issue of Lifting the SANCTIONS and benefiting Iran's economy thereof. These indicators include complete normalization of whole banking relationships, complete removal of export barriers, free sale of Iranian oil and oil products, and complete and quick return of [foreign] currency from there. Furthermore, according to Article (7) of the same act, the government (Executive power) must report to the Parliament on SANCTIONS lifting, where the relevant Commissions of the Parliament have to make their evaluation of the government’s report. These two articles together imply that economic benefits must accompany the lifting of SANCTIONS, and these benefits should be verified precisely and measurably. What matters now is what criteria and indicators should be used to verify whether the Iranian economy benefits from the lifting of SANCTIONS. In another report entitled "Managing the country's economy in the face of SANCTIONS; the need to plan the national economy with the assumption of the continuation of SANCTIONS" in detail and briefly in the present report, it is explained that the United States - As in the past- will use various economic, political and legal means that even if SANCTIONS are lifted legally , it will still prevent Iran’s economy from benefiting out of SANCTIONS relief. It is important to note that the use of a mere legal approach to lift the SANCTIONS from a legal standpoint —the privative approach— is a strategic mistake and will not lead to Iran’s economic benefit when the United States of America, due to its lack of serious will to lift SANCTIONS, is trying to increase the risk of economic cooperation with Iran by employing various means. Compiling extensive lists of US SANCTIONS against Iranian individuals and legal entities and insisting solely on the legal lifting of these SANCTIONS can be regarded as signs of this flawed privative approach. The following are some of the reasons for the lack of success in adopting a mere legal approach to lifting SANCTIONS: a. legal evasions and placing obstacles in the way of the authentic lifting of SANCTIONS by the united states; • Completion of the legal infrastructures related to SANCTIONS and their permanent nature, • Intertwining nuclear and non-nuclear SANCTIONS and imposing regulation to make the SANCTIONS on Iran inseparable, • Official and bipartisan acknowledgment by US officials of the need to conclude a new comprehensive agreement with Iran; Based on experiences, even if the US intends to lift SANCTIONS on paper, it will use various tools to prevent Iran’s economy from realizing the real and full economic benefit. b. Preventing Iran by the United States from benefiting from the lifting of SANCTIONS; • Taking no effort in improving the risk index of interaction and cooperation of other countries with the Iran economy and • trying to maintain the current level of cooperation risk, • Disrupting one of the links in Iran’s chain of foreign Economic cooperation, • Exaggeration in giving the minimum rights (advantages) due to the lifting of SANCTIONS and showing drawbacks as an advantage such as granting specific & general licenses instead of the lifting of SANCTIONS, • Increasing the political and economic risk of cooperation with Iran through formal rhetoric, media attacks, and informal pressures. In general, using a mere legal approach in the present situation cannot provide the possibility of authentic verification of the lifting of SANCTIONS and benefiting the Iranian economy in practice. Therefore, in addition to insisting on the legal lifting of SANCTIONS, operational and measurable criteria as an affirmative approach should also be designed to verify the benefits of the lifting of SANCTIONS. These indicators should be introduced as conditions of Compliance with the commitments and as preconditions for fulfilling the nuclear Actions of the Islamic Republic of Iran; these include demanding and ensuring the export of a certain minimum level of oil and oil products, conducting transactions easily by using revenues from export, the realization of a certain level (threshold) of monthly transactions and banking operations by targeted foreign banks and operational review of rules related to the international economic activity of Iranian Individuals and legal persons, which is assessed in detail in the present report. The verification of the actual lifting of the SANCTIONS and the realization of the measurable criteria (indicators) determined by Iran is impossible in just a few hours or a few days. The stated process will take at least 3 to 6 months. Accordingly, based on the definite policy of the Islamic Republic of Iran and the emphasis of the Leader of the Islamic Revolution on the necessity of prioritization of verification over the fulfillment of obligations by Iran, and also Compatible with the aforesaid Iranian Parliament Act, it is factually necessary and also legally mandatory to verify the benefit of the lifting of SANCTIONS by Iran based on quantitative and operational indicators. Furthermore, adopting a mere legal approach—focusing on the apparent lifting of some or even all SANCTIONS, regardless of whether such a lifting also leads the SANCTIONS to be lifted in practice—which may be overcome and followed due to the prioritizing of short-term political interests over national and long-term interests, must be avoided. The parliament's role in verifying the actual lifting of the SANCTIONS and the realization of the criteria of Iran's economic benefit from the lifting of the SANCTIONS is vital and unquestionable. Examining the explicit text and spirit of Article (7) of the Law on "Strategic Action for Lifting SANCTIONS and Protecting the Interests of the Iranian nation" and the detailed proceedings of parliament in the process of passing the mentioned law implies that the Re-commitment of Iran to the nuclear actions according to JCPOA, is possible just after the authorization issued by the Islamic Consultative Assembly. In Turn, This permission in accordance with the mentioned Act will issue by the Parliament only after lifting the SANCTIONS totally and the fulfillment of the measurable criteria.

According to the provisions of Article (7) of the Law on "Strategic Action to remove SANCTIONS and Protect Iranian Nation's interests," as well as the definite policy of the Islamic Republic of Iran, the verification of the removal of SANCTIONS and its subsequent benefits for Iran's economy should be the inevitable demand of the foreign policy apparatus in any negotiation process. In other words, the removal of Iran SANCTIONS, regardless of the realization of the legal aspects of removing SANCTIONS (removal of SANCTIONS on paper), should provide tangible benefits for Iran's economy due to the removed SANCTIONS. Regarding the thirteenth government coming to power, the following report as a comprehensive guideline can play an essential role in advancing verification if the new government seriously considers the issue of Verification. Verification has two main factors: "monitoring guideline" and "monitoring organization." Verification is a continuous activity in which a monitoring organization evaluates the other participant's compliance to the agreement's provisions based on objective indicators and criteria related to the type of obligations. Therefore, three essential requirements must be considered in determining the verification process: first, developing a comprehensive, operational, and measurable guideline. Second, determining the unique features for the first stage of verification. Third, determining the quality and aspects of periodic verification. In this report, the three main topics are proposed to meet the mentioned three requirements, which will be presented as follows: A) The verification authority can be a beyond the parliament-approved powers organization such as the Supreme National Security Council or the Iranian Supervisory Committee on Joint Comprehensive Plan of Action (JCPOA) or even a newly established body with a professional expertise structure and a permanent secretariat. This authority has the responsibility to compose periodic reports on the verification of the removal of SANCTIONS to decide whether Iran should continue to comply with the agreement or take countermeasure in the form of reducing or suspending its commitments. This authority has three crucial tasks: 1. Monitoring and analyzing the benefits of Iran's economy due to removed SANCTIONS, 2. Receiving complaint letter from an Iranian citizen or institution (especially those individuals and entities that have been removed from the SANCTIONS list) about the "Violation of JCPOA or the impossibility of deriving benefit from the removed SANCTIONS"; 3. Develop a regulation for countermeasures. This includes but is not limited to implementing its provisions in proportion to the other participants' non-compliance by introducing a regulation that mandates suspending, stopping, or reducing nuclear activity limitations as countermeasures. B) Providing a verification checklist of removing SANCTIONS and permission to resume nuclear-related measures based on JCPOA for the first stage of verification: The provisions of the proposed checklist of verification of removing SANCTIONS are presented in two parts: • Factors of the actual removal of SANCTIONS: it includes realizing the minimum thresholds for oil sales and transactions with German EIH and Bank Tejarat branch of Paris, revoking US President's executive orders, reviewing the related FAQ's of the OFAC website, avoiding issuing warning notices, and issuing specific and general Licences for foreign individuals and legal entities who want to cooperate with Iran's economy. • factors of reducing the risk of economic cooperation with Iran: The criteria of this topic are the acceptance of legal commitment and the adoption of practical measures by the leaders of the other participant countries on the normalization of trade and economic relationships with Iran, that include: - Revoking executive orders and other regulations, continuing the issuance of the certification of Iran compliance to JCPOA, eliminating instructions and advisories introducing the Iranian economy as a jurisdiction with a high risk of money laundering, and issuing orders or approving regulations that are necessary measures for normalizing trade relationships with Iran. - Avoiding any negative comments or actions discouraging nations from cooperating with Iran and acknowledging the possibility of establishing medium and long-term cooperation with Iran's economy. - Altering the approach of Financial Crimes Executive Network (FinCEN) of United States Department of the Treasury from Risk-Based to Rule-Based. - Removing Iranian Individuals, entities, vessels, and aircraft from the SANCTIONS lists and fundamentally revising the SDN and non-SDN lists. - Eliminating warning instructions and advisories from OFAC and other US agencies on humanitarian goods trade and maritime trade with Iran. C) Checklist of Continuity of benefits from removed SANCTIONS and issuance of periodic licenses to allow Iran to continue the implementation of JCPOA (Periodic Verification): on the issue of Continuity of Verification, it is recommended that the process of deriving benefit should be verified continuously and to publish the reports of this verification every three months. The threshold for the first part of continuous verification is 2.5 million barrels per day export of oil and condensate, monthly transactions of Iranian individuals and entities with the EIH Bank in Germany and the Paris branch of Tejarat bank worth at least $ 4.2 and $ 1.5 billion respectively. In addition, the normalization of trade and international cooperation with the sanctioned sectors of Iran's economy is considered the basis for continuing the verification. The proposed mechanism for examining the normalization of relationships with each economic sector can be described as follows: the verification authority receives quarterly feedback from prominent governmental and non-governmental actors in each sector based on the dimensions introduced. Then based on those feedbacks, the verification authority will recommend whether to comply with the commitments or to reduce, suspend or cease Iran's actions as countermeasures. In fact, the verification authority should report to the main decision-making organization about JCPOA (which is currently the Supreme National Security Council and the Iranian Supervisory Committee on JCPOA). According to paragraph 36 of the JCPOA, Iran has the right to reconsider compliance to its commitments based on the domestic approved arrangements in the case of a violation of the JCPOA by other participants. However, taking these countermeasures does not prevent Iran from sending verification reports to the Joint Commission of the JCPOA as an international organization to convince foreign participants.