Yesterday, the Senate Foreign Relations Committee unanimously passed legislation that would allow Congress to review—and potentially block—any final deal reached with Iran over its nuclear program. The Iran Nuclear Agreement Review Act of 2015 (S.615) would also prevent the Obama Administration from immediately suspending sanctions against Iran during an initial 30-day congressional review period. The legislation still requires approval by the full Senate and the House of Representatives, which is expected soon. The Obama Administration has indicated that it will sign the legislation, unless it is further amended.

As we previously summarized, the United States and its P5+1 negotiating partners, together with Iran, announced the key parameters of the Joint Comprehensive Plan of Action (JCPOA) regarding Iran’s nuclear program on April 2, 2015. The parties have indicated that they will aim to negotiate a full agreement with technical annexes by June 30, 2015.

Congress and the Obama Administration have since engaged in extensive negotiations to determine the extent to which Congress should formally review a final JCPOA after June 30. This bill would provide Congress an opportunity to review a final agreement between the P5+1 and Iran for at least 30 calendar days (or 60 days, if it is transmitted to Congress after July 9), in addition to potential modest extensions of the review period in the event of a joint resolution of disapproval and a presidential veto. During this period, the President would not suspend or otherwise provide any relief from sanctions that have been previously established by statute. The President is also required to certify to Congress every 90 days that Iran is in compliance with the final agreement.

Under the terms of the bill, if Congress does not take any action in response to a final deal before the review period lapses—or if it formally approves the deal—then the President may exercise authority to suspend sanctions. The final JCPOA would be effectively blocked only if Congress formally disapproves it. The bill therefore affirms the powers that Congress already has: even without this legislation, core US sanctions against Iran—including the “nuclear-related” sanctions that are reportedly the subject of the JCPOA—could not be repealed without congressional action. A key impact of the legislation may thus be the limitation on the Obama Administration to suspend certain nuclear-related sanctions against Iran immediately upon agreement of a final JCPOA.