◢ This month, the European Commission approved an initial tranche of EUR 18 million in development funding from an larger package of EUR 50 million that has been allocated to support projects in Iran. This represents a highly significant, “first-of-its-kind,” intervention to support Europe-Iran trade and investment. However, the funding is not primarily intended as an attempt to mitigate the effect of returning U.S. secondary sanctions. As made clear in the “action document” which details how the development funding will be distributed, the European Commission has allocated the funding “in line with the European Consensus on Development” to provide “targeted support in the areas of Prosperity, Planet and People.”