With Implementation Day approaching for the Iran nuclear agreement, the Treasury Department is readying new financial sanctions on some Iranian businesses and individuals.  The sanctions are in response to Iranian ballistic missile tests in October banned by U.N. resolutions.

In truth, the new sanctions are a drop in the bucket compared to the more than $100 billion in sanctions relief Iran is expecting next month, when the IAEA is supposed to give the Iranian nuclear program a clean bill of health.  But beyond the dollar amount of the sanctions is the real possibility that Iran might pull out of the nuclear deal altogether.

Wall Street Journal:

The planned action by the Treasury Department, U.S. officials told The Wall Street Journal, is directed at nearly a dozen companies and individuals in Iran, Hong Kong and the United Arab Emirates for their alleged role in developing Iran’s ballistic-missile program.

Iranian officials have warned the White House in recent months that any such financial penalties would be viewed by Supreme Leader Ayatollah Ali Khamenei as a violation of the nuclear accord.

Senior U.S. officials have said the Treasury retained a right under the agreement to blacklist Iranian entities allegedly involved in missile development, as well as those that support international terrorism and human-rights abuses. Officials view those activities as separate from the nuclear deal.

Critics of the administration said Wednesday that the impending sanctions are paltry compared with the amount of sanctions relief Iran is set to get next year under the nuclear deal.

But they also acknowledged that the measures could feed into Iranian politics and national elections scheduled for late February. Hard-line politicians in Tehran have attacked President Hassan Rouhani and his allies for the terms of the nuclear deal.

The Iranian government on Wednesday didn’t immediately respond to a request for comment on the possible new sanctions, which are expected to be formally announced this week.

Iranian diplomats recently accused the U.S. of violating the nuclear agreement after Congress passed legislation requiring that any foreign national who visits Iran or Syria obtain a visa before entering the U.S., a change made in response to the San Bernardino shootings. Iranian officials called the visa requirement, in effect, a tax or sanction on international businessmen seeking to invest in the Iranian market.

A note of caution: These are proposed sanctions.  Nothing is set in stone.  It's a possibility that the announcement is window dressing, designed to appease critics in Congress who have been after the administration to sanction Iran not only for the missile test, but for promoting terrorism and human rights violations.  They could yet be watered down or canceled.

President Rouhani has his own political headaches, and any new sanctions will play right into the hands of his political enemies.  But it's also true that Iran is so committed to the deal that pulling out now could cause more political damage than the flack he will take from any new sanctions.  They've already begun to transfer their enriched uranium to Russia and taken other steps to implement the agreement. 

Congress is planning its own set of sanction, support for which is bipartisan.  But administration flunkies like Harry Reid have been blocking the measure, assuring that the bill will remain in limbo for the time being.