Michael Greenwald writes "The E3 countries (Germany, France, and the UK) intended to seed the Institution in Support of Trade Exchanges (INSTEX) as a means of supporting trade with Iran after the reimposition of sanctions. Though humanitarian goods, like food and medicine, are technically exempt from Washington’s sanctions, many private sector players are deterred by the combination of a more activist sanctions policy and continuing AML/CFT problems in the Iranian jurisdiction."
Michael Greenwald, a former senior diplomat at the U.S. Treasury Department who is now a fellow at Harvard Kennedy School's Belfer Center, said, “A multilateral framework, while an ideal solution to this problem, would suffer major vulnerabilities.” China and Russia are likely to take actions to “oppose it outright or water down enforcement mechanisms given their interests in continuing to evade sanctions,” Greenwald said.
