United States Institute of Peace

The Iran Primer

Iran Slams US Sanctions Enforcement

            On December 13, Iran’s foreign ministry slammed Washington for blacklisting more than a dozen companies and individuals for sanctions evasion. “The U.S. administration is fully responsible for the consequences of these indiscrete measures,” said Foreign Spokesperson Marziyeh Afkham. She acknowledged the Obama administration’s attempt to persuade Congress to hold off on new sanctions. But Afkham argued that sanctioning companies and individuals under existing sanctions is a “questionable move” that demonstrates “serious confusion” in U.S. policy. The chairman of parliament’s National Security and Foreign Policy Committee, Alaeddin Boroujerdi, called the blacklisting a “flagrant violation of the Geneva nuclear accord.”
            In Vienna, expert-level talks between Iran and the world’s six major powers halted just hours after Washington imposed the sanctions. “America's move is against the spirit of the Geneva deal,” said Deputy Foreign Minister Abbas Araqchi on the way back to Tehran. The team decided to return for consultations before continuing discussions on implementing the November 24 nuclear agreement.  “After four days of lengthy and detailed talks, reflecting the complexity of the technical issues discussed, it became clear that further work is needed,” said Michael Mann, a spokesman for E.U. foreign policy chief Catherine Ashton. He clarified that officials would return to their capitals with the “expectation that technical talks will continue soon.”
            When asked about the halted talks, U.S. Spokesperson Jen Psaki said pausing to consult a “normal part of the process in developing the implementation plan.” The following are excerpted remarks by Iranian and American officials.

Foreign Ministry Spokesperson Marziyeh Afkham
      “On the one hand, U.S. administration officials are seemingly persuading Congress to refrain from passing fresh sanctions against the Islamic Republic of Iran within the framework of furtherance of the Joint Plan of Action between the Islamic Republic of Iran and the P5+1. On the other hand, in a questionable move, the U.S. Treasury and State Department... have blacklisted firms from Iran and a number of foreign countries in an unconstructive measure.”
      “The U.S. administration is fully responsible for the consequences of these indiscrete measures.”
      “Unfortunately, we are witnessing serious confusion in U.S. officials’ attitudes, decisions and remarks.”
           Dec. 13, 2013 to the press
Deputy Foreign Minister for Legal Affairs Abbas Araqchi
      “This is a game of double standards — it is not in accord with the talks we have had and it is against the spirit of the Geneva agreement… We are evaluating the situation and will make the appropriate response.”
      “On the one hand they tried to halt sanctions in Congress, and on the other hand they made a new move and the Treasury added new companies to the list.”

      Dec. 13, 2013 to the press

      “Such a measure is by no means constructive and we are seriously critical of it.”
      Dec. 13, 2013 on state television


Parliament's National Security and Foreign Policy Committee Chairman Alaeddin Boroujerdi
      “Undoubtedly, the latest U.S. move to blacklist a number of Iranian companies and institutions is the flagrant violation of the Geneva nuclear accord, and the US officials revealed that they are not trustworthy.
      “The recent U.S. action showed that this country, despite its claim of being a world superpower, is in practice a follower of Zionist lobbies and is incapable of acting independently concerning its affairs and policies.
      “Given the hostile approach of this country [the United States] and the violation of the Geneva agreement, one cannot be optimistic about the future of the nuclear talks. We should in fact take necessary measures to expedite our peaceful [nuclear] activities.”
            Dec. 13, 2013 to the press


State Department Spokesperson Jen Psaki
      “We’ve been hard at it in Vienna, a lot of discussions taking place. I've talked with Cathy Ashton the last days. We’re making progress, but I think we’re at a point in those talks where folks feel a need to consult, take a moment. There is every expectation that talks are going to continue in the next few days, and that we will proceed to the full implementation of that plan. This is sort of the normal part of the process in developing the implementation plan.”
      Dec. 13, 2013 to the press during a visit to Israel




Photo credits: www.mfa.gov.ir, http://rc.majlis.ir, www.state.gov


US Sanctions Networks Linked to Nuclear Program

      On December 12, the U.S. Treasury and State Department targeted 17 companies and individuals for evading international sanctions on Iran or supporting its nuclear program. Four companies and one person allegedly violated oil sanctions. The other twelve companies and individuals operated front companies supporting the nuclear program. “Today’s actions should be a stark reminder to businesses, banks and brokers everywhere that we will continue relentlessly to enforce our sanctions, even as we explore the possibility of a long-term, comprehensive resolution of our concerns with Iran’s nuclear program,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen. He clarified that the Geneva nuclear agreement does not impact current U.S. sanctions. Under Secretary of State for Political Affairs and lead Iran negotiator Wendy Sherman reiterated that point in a Senate Committee on Banking, Housing and Urban Affairs hearing. The following are excerpts from her opening remarks and the State Department press release on sanctions.      

Designations Related to Sanctions Evasion

            A central part of the United States’ strategy in enforcing sanctions against Iran is a sustained effort to target those who deceptively engage in transactions on behalf of Iran or other sanctioned entities. These actors take advantage of unwitting foreign businesses by concealing the true beneficiaries of their activities and have become a key part of Iran’s international sanctions evasion efforts. Treasury possesses a number of far-reaching authorities to counter and disrupt these actors, including various Executive Orders (E.O.s) that target those who provide support to the Government of Iran or previously sanctioned entities or those who engage in deception to assist the Government of Iran or others to circumvent sanctions.
            Today’s actions target several companies and individuals who engaged in transactions on behalf of previously-designated National Iranian Tanker Company, Iran’s primary shipper of crude oil, and previously identified KASB International, and also target the General Manager of Ferland Company Limited, which was identified earlier this year as a sanctions evader. They also identify a number of NITC vessels that have changed their flagging jurisdiction or names.

Mid Oil Asia

            Mid Oil Asia was designated today pursuant to E.O. 13645 for providing material support to the National Iranian Tanker Company (NITC). E.O. 13645 broadens existing sanctions with respect to Iran, including imposing sanctions on persons that materially assist certain other persons whose property and interests in property are already blocked. NITC was identified as part of the Government of Iran in July 2012. Singapore-based Mid Oil Asia is used by NITC to make NITC’s urgent payments in violation of international sanctions. For example, Mid Oil Asia was used by NITC to transfer funds to an Egypt-based company and to ensure the payment documents did not mention the name of the vessels or Iran, the country which owned them.

Singa Tankers

            Singapore-based Singa Tankers was designated today pursuant to E.O. 13645 for providing material support to NITC. Singa Tankers is also used by NITC to make urgent payments. For instance, NITC provided funds to Singa Tankers for a tanker transport-related expense in September 2013. Separately, Singa Tankers transferred funds to a non-Iranian foreign bank on behalf of NITC. Care was taken so that transfer details were not mentioned, specifically the name of the vessel or the Iranian nationality of the vessel’s owners.

Siqiriya Maritime

            Siqiriya Maritime Corporation was designated today pursuant to E.O. 13645 for providing material support to NITC. The following vessels have been identified as property in which Siqiriya Maritime Corporation has an interest: Anthem, Jaffna, and Olysa.

Ferland Company Limited

            Ferland Company Limited was designated today pursuant to E.O. 13645 for providing material support to NITC. Representatives from Ferland Company Limited and NITC were involved in the ship-to-ship transfer of Iranian crude oil in March 2013. Ferland Company Limited facilitated deceptive transactions for or on behalf of NITC. Treasury previously imposed sanctions on Ferland Company Limited pursuant to E.O. 13608, which targets foreign sanctions evaders, for facilitating deceptive transactions for or on behalf of NITC. The Department of State also imposed sanctions on Ferland Company Limited pursuant to the Iran Sanctions Act, as amended.

Vitaly Sokolenko

            Vitaly Sokolenko, the General Manager of Ferland Company Limited, who is based in Odessa, Ukraine, and involved in brokering the sale of Iranian crude oil, was designated today pursuant to E.O. 13645 for providing material support to NITC and was targeted for sanctions under E.O. 13608 for acting for or on behalf of Ferland Company Limited.

Designations Related to Front Companies, Officials or Agents of Designated Nuclear and Weapons Proliferation Companies

            Pursuant to E.O. 13382, the United States has imposed a series of targeted, conduct-based sanctions on individuals, firms, and financial institutions involved in or linked to Iran’s nuclear and ballistic missile programs. This sustained sanctions effort has both disrupted the progress of Iran’s nuclear and ballistic missile program and imposed significant pressure on the Iranian government.

            The Department of State today targeted five Iranian entities directly engaged in providing the Iranian government goods, technology, and services that materially contribute to or pose a risk of materially contributing to Iran's ability to enrich uranium, construct a heavy water-moderated research reactor, and develop its ballistic missile capabilities, all of which are prohibited by United Nations Security Council Resolutions. These designations represent State’s continuing effort to target for sanctions private Iranian entities contributing to Iran’s nuclear and ballistic missile programs.

Eyvaz Technic Manufacturing Company

            Eyvaz Technic Manufacturing Company (Eyvaz) is an Iranian entity involved in the procurement of sensitive items for use in Iran’s centrifuge program. Since at least 2008, Eyvaz has procured components useful in centrifuge cascades, specifically expansion joints, for Kalaye Electric Company (KEC), an Iranian entity designated in United Nations Security Council Resolution 1737 for its work on Iran’s proscribed uranium enrichment program. Eyvaz has procured other components useful in centrifuge cascades, including valve bellows and vacuum pumps, also for KEC, and for other entities involved in the Iranian nuclear program.

The Exploration and Nuclear Raw Materials Production Company

            The Exploration and Nuclear Raw Materials Production Company (EMKA) is a subsidiary organization of the Atomic Energy Organization of Iran (AEOI). EMKA oversees uranium discovery, mining, and mineral processing operations in Iran. EMKA provided support and funding for continued mining operations for uranium ore at the Gachin mine as recently as November 2012. As of July 2013, EMKA was using a front company to procure items intended for the AEOI.

Maro Sanat Company

            Since 2011, the Iranian firm Maro Sanat Company (Maro Sanat) has worked for Iran’s Nuclear Reactors Fuel Company (SUREH) to acquire necessary items for the organization’s facilities. SUREH is responsible for Iran’s Uranium Conversion Facility, the Fuel Manufacturing Plant, and the Zirconium Production Plant. SUREH contracted with Maro Sanat to acquire large amounts of zirconium silicate, which Iran could use as feedstock to produce nuclear-grade zirconium for IR-40 fuel cladding and other internal components, and non-nuclear-grade zirconium that could contribute to Iran’s missile program as solid rocket propellant. Maro Sanat’s efforts to acquire large amounts of zirconium silicate could make a major contribution to Iran’s ability to advance construction of its IR-40 reactor. Maro Sanat also worked for SUREH to acquire anhydrous hydrofluoric acid (AHF), which is used to form one of the precursors needed to create uranium hexafluoride (UF6), used at Iran’s Uranium Conversion Facility.

Navid Composite Material Company

            Navid Composite Material Company (Navid Composite) is an Iran-based subsidiary of U.S.- and UN-designated Sanam Industrial Group, which was designated for its involvement in Iran’s ballistic missile program. Navid Composite is currently building a carbon fiber production plant in Iran. Since at least 2012, Navid Composite has contracted with Asia-based entities to procure a carbon fiber production line capable of producing 150 tons per year of carbon fiber probably suitable for use in ballistic missile components.

Negin Parto Khavar

            Negin Parto Khavar (Negin Parto) is a key participant in a nuclear procurement network that brokers items for Iran’s proscribed nuclear program, including for UN-designated entities such as the Atomic Energy Organization of Iran (AEOI), Modern Industrial Technique Company (MITEC), and Kalaye Electric Company (KEC), all of which have also been designated by the United States pursuant to E.O. 13382. Negin Parto also has procured items for Iran’s Nuclear Reactors Fuel Company (SUREH), which was designated by the United States pursuant to E.O. 13382 on November 11, 2011. Since at least mid-2009, Negin Parto has brokered or attempted to broker several deals to provide sensitive components for Iran’s 40-megawatt heavy water research reactor (the IR-40) at Arak, Iran, often using false end-user statements to deceive manufacturers and to obscure Iranian involvement in the transactions.

            Continuing the effort to target Iran’s nuclear proliferation activities, Treasury today targeted a network of proliferators headed by Iran’s Ministry of Defense for Armed Forces Logistics (MODAFL), which oversees Iran’s ballistic missile program. MODAFL was designated by the United States pursuant to E.O. 13382 in 2007, and has brokered a number of transactions involving materials and technologies with ballistic missile applications. Treasury also designated officials from and aliases for the Iranian nuclear procurement firm Neka Novin. Neka Novin was designated in November 2011 for its involvement in the procurement of specialized equipment and materials that have direct application to Iran’s nuclear program.

Neka Novin Officials Iradj Mohammadi Kahvarin and Mahmoud Mohammadi Dayeni

            Iradj Mohammadi Kahvarin and Mahmoud Mohammadi Dayeni are key officials working for Neka Novin. Iradj Mohammadi Kahvarin holds the roles of Managing Director, Project Manager, and Sales and Marketing Manager for Neka Novin. He participated in negotiations related to the procurement of automation equipment for Iran’s nuclear program in 2009. Mahmoud Mohammadi Dayeni is the Chief Executive Officer of Neka Novin and also holds the titles of Managing Director and Project Manager of Neka Novin.

Neka Novin Aliases

            Neka Novin has used the names Kia Nirou, Block Nirou Sun Co., BNSA Co., and Neku Nirou Tavan Co. when procuring equipment from foreign suppliers.

Qods Aviation Industries

            Iran’s Islamic Revolutionary Guards Corps (IRGC) operates Qods Aviation Industries and uses it to fund projects. MODAFL contracts with Qods Aviation Industries for aviation and air defense projects. Qods Aviation is involved in the production of UAVs, parachutes, paragliders, and para-motors, which the IRGC has claimed to use as part of its asymmetric warfare doctrine.

            In addition, Qods Aviation Industries has also been identified as an IRGC entity in an annex to U.N. Security Council Resolution 1747 of March 24, 2007. It was also listed by the European Union on March 23, 2012 as an entity linked to Iran’s proliferation-sensitive nuclear activities or Iran’s development of nuclear weapon delivery systems.

Iran Aviation Industries Organization

            Iran Aviation Industries Organization is part of the Iranian Ministry of Defense and is responsible for managing Iran’s military aviation industry. Among other things, it is involved in developing long range unmanned aerial vehicles (UAVs). It has also been sanctioned by the European Union as an entity linked to Iran’s proliferation-sensitive nuclear activities or Iran’s development of nuclear weapon delivery systems.

Reza Amidi, Fan Pardazan, and Ertebat Gostar Novin

            Reza Amidi, who was a commercial manager of Qods Aviation Industries, has been tied to procurement work undertaken by Fan Pardazan. Fan Pardazan is a Qods Aviation Industries cover company. Reza Amidi is also tied to Ertebat Gostar Novin, a suspected Qods Aviation front company involved in procurement activities.

Updated Information About Previously Identified Persons

KASB International Update – First Furat Trading LLC

            KASB International LLC is a UAE-based company previously identified on September 6, 2013 pursuant to E.O. 13599 – which targets the Iranian government’s property and its financial institutions – as part of the Seyed Seyyedi network of front companies used to evade sanctions. The company is now known as First Furat Trading LLC. Additionally, KASB International LLC’s address and phone number have been updated.

Seifollah Jashnsaz Update

            The biographical and passport information of Seifollah Jashnsaz, Managing Director of the Switzerland-based Naftiran Intertrade Company and of numerous Iranian front companies involved in evading international sanctions on Iranian oil, have been updated, including to note his role as the Chairman of the Board of Directors of the previously-identified Iranian Oil Company U.K.

Click here for more details.


Under Secretary of State for Political Affairs and lead Iran negotiator Wendy Sherman

Continued Enforcement of Sanctions
            It is important to understand that the overwhelming majority of our sanctions remain in place and we will continue to vigorously enforce those sanctions to ensure that Iran receives only the limited relief that we agreed to. This will include aggressive enforcement of sanctions under the Comprehensive Iran Sanctions Accountability and Divestment Act of 2010 (CISADA), the Iran Sanctions Act, the Iran Threat Reduction and Syria Human Rights Actof 2012, and the Iran Freedom and Counter-Proliferation Act of 2012. This means that sanctions will continue to apply to broad swaths of Iran’s economy including its energy, financial, shipping, and shipbuilding sectors. By rigorous monitoring we will also prevent abuse of the relief that is part of the JPA. Were we to see increased purchases of oil or sanctions evasion, we are prepared to act swiftly to sanction the offenders.
           Moreover, the U.S. trade embargo remains in place and U.N. Security Council’s sanctions remain in place. All sanctions related to Iran’smilitary program, state sponsorship of terrorism, and human rights abuses and censorship remain in place. Our vigilance will continue.
           What is also important to understand is that we remain in control. If Iran fails to live up to its commitments as agreed to in Geneva, we would be prepared to work with Congress to ramp up sanctions. In that situation, we would be well-positioned to maximize the impact of any new sanctions because we would likely have the support of the international community, which is essential for any increased pressure to work.
           In comparison, moving forward on new sanctions now would derail the promising and yet-to-be-tested first step outlined above, alienate us from our allies, and risk unraveling the international cohesion that has proven so essential to ensuring our sanctions have the intended effect.


Click here for Sherman's opening remarks.


Treasury: Sanctions Relief Limited, Temporary and Reversible

            On December 12, Under Secretary for Terrorism and Financial Intelligence David S. Cohen outlined Iran’s relief package from the Geneva nuclear deal. Tehran committed to roll back its nuclear program and allow increased monitoring “in exchange for limited, temporary, and reversible relief,” he told the Senate Committee on Banking, Housing and Urban Affairs. Cohen also assured the members that Washington will vigorously enforce existing sanctions and keep the core banking, financial and oil sanctions in place. The following are excerpts from Cohen’s testimony at the Senate hearing on the interim agreement.    

            The relief offered Iran is limited in several important respects. First, under the JPA, we will allow Iran access to a set amount of its own money – $4.2 billion in installments over the six- month course of the JPA – in a carefully controlled manner. Second, we will suspend some sanctions to allow Iran to engage in specified additional commercial activity – petrochemical exports, imports for its automobile industry, and gold trade – that altogether have at best marginal economic value to Iran. And third, the vast bulk of our sanctions, including the core oil, financial, and banking sanctions that have had such a dramatic impact on Iran's economy, remain in place and will continue to exert pressure on Iran's decision makers over the next six months.
            The relief offered Iran in the JPA is also temporary in that it expires at the end of six months. At the end of six months, no additional funds will be made available to the Iranians, and the suspended sanctions will snap back into place. Because the JPA is renewable only "by mutual consent," at the six-month mark we could then consider whether, and to what extent, to provide additional relief to the Iranians in light of the circumstances. But if we decide not to provide additional relief, the relief described in the JPA expires at the end of six months.
And the relief in the JPA is reversible. If Iran fails to fulfill its commitments under the JPA, or refuses to enter into a comprehensive, long-term solution, we can stop the gradual release of funds, reimpose the suspended sanctions and impose new and enhanced types of sanctions.
The Relief Package
            The relief package described in the JPA is composed of several discreet elements, as follows:
Access to Restricted Funds
            The majority of the relief will come from granting Iran access, in installments over the six-month tenure of the JPA, to $4.2 billion of its own funds currently held in bank accounts outside of Iran – funds to which Iran has limited access and which right now can only be used for bilateral trade or humanitarian purchases. Let me underscore this point. These funds already belong to Iran, but under the international sanctions framework cannot be moved to third countries (except to facilitate humanitarian trade) nor repatriated to Iran. Not a single dollar of U.S. taxpayer money will be provided to Iran.
Temporary Pause in Reduction of Iran's Crude Oil Sales
            We have agreed to hold Iran's exports of crude oil flat for a period of six months rather than requiring further significant reductions in the amount of Iranian oil purchased by oil-importing countries. To be clear, this will not allow Iran to increase its oil exports. To the contrary, Iran will be held to its currently depressed levels, down 60 percent from what it was selling in early 2012. This provision, moreover, will apply only to Iran's six current crude oil purchasers – Japan, Republic of Korea, China, Taiwan, India and Turkey. They will not be allowed to increase their purchases and no other country will be allowed to begin importing Iranian oil.
Temporary Suspension of Petrochemical Sanctions
            U.S. sanctions on Iran's petrochemical exports will be temporarily suspended as part of this first step deal. We estimate that this will allow Iran to generate a maximum of $1 billion in new revenue over the next six months, but only if Iran is able to produce additional petrochemicals for export (some of its petrochemical plants have been retrofitted to boost gasoline production capacity for the domestic market) and only if Iran is able to find additional petrochemical customers – who typically prefer stable, long-term supply contracts – willing to sign contracts with Iranian exporters knowing that the sanctions are suspended under the JPA for only six months.
Temporary Suspension of Sanctions on Iran's Auto Industry
            We will also temporarily suspend U.S. sanctions on exports by third countries to Iran's automobile industry. We estimate that this could provide Iran some $500 million in revenue, assuming Iran can resume prior levels of production and revitalize its car exports. Iran's automobile industry, however, is riddled with structural problems and was in steep decline even before our auto sanctions were put in place. Moreover, if Iran hopes to revive its auto sector, it would need to spend some of its limited foreign currency to pay for car kits from abroad.
Temporary Suspension of Gold Sanctions
            Sanctions on Iran's ability to buy and sell gold will also be temporarily suspended. However, we expect that this provision will be of limited value to Iran because the only funds Iran can use to buy gold are its limited unrestricted hard-currency reserves. Because of the sanctions architecture that remains in place, Iran will be permitted to use neither its restrained foreign reserves nor its own currency, the rial, to buy gold. As a consequence, any gold Iran purchases would be offset by the hard currency it would spend to buy it, resulting in negligible economic benefits.
Limited Access to Funds for Tuition Purposes
            Under strict guidelines, we will allow Iran to transfer $400 million of restricted Iranian funds to defray tuition costs for Iranian students studying outside of Iran, and will ensure that these funds are used for their intended purpose.
License Safety-Related Repairs And Inspection for Certain Airlines in Iran
            We will license Iranian aircraft, to occur in Iran. Previously, we had licensed these activities for Iranian aircraft only outside of Iran. Notably, Mahan Air, an Iranian airline that has been designated by Treasury for providing financial, material and technological support to Iran's Islamic Revolutionary Guard Corps-Qods Force and Lebanese Hizballah, will not be permitted to benefit from these repairs, nor would any other entity subject to sanctions under our counter-terrorism authorities.
Financial Channel to Facilitate Humanitarian Trade
            Finally, we will assist in establishing a financial channel to facilitate humanitarian trade in food, agricultural commodities, medicines, medical devices for Iran's domestic needs, and to pay for the medical expenses of Iranian citizens incurred abroad. This will not provide Iran access to any new source of funds, because humanitarian trade with Iran is not targeted under existing sanctions authorities and because we intend that funds for medical expenses will come from Iran's limited stores of unrestricted hard currency. Humanitarian transactions have been explicitly exempted from sanctions by Congress and U.S. law places limits on the President's ability to regulate such trade.
The Relief Package in Context
            The total value of the relief package – approximately $6 billion to $7 billion – will not materially improve the condition of the Iranian economy. Indeed, at the end of the six-month period, we expect that Iran will be even deeper in the hole economically than it is today due to the continuing and mounting impact of the sanctions we have in place and that we will continue to energetically enforce.
            Indeed, the limited relief offered Iran in the JPA is dwarfed by the depths of Iran's economic distress. Our oil, financial and banking sanctions, in particular, have driven Iran into a deep recession. Since 2011, oil sanctions imposed by the EU and the U.S. have forced Iran's oil exports to decline from about 2.5 million barrels per day at the end of 2011 to about 1 million barrels per day today – costing Iran roughly $80 billion in lost sales. In that same period, Iran's currency, the rial, has lost around 60 percent of its value against the dollar. Approximately $100 billion of Iran's foreign exchange holdings are restricted or inaccessible due to our financial and banking sanctions. Over the last year, inflation in Iran has been about 40 percent. All told, last year Iran's economy contracted by more than five percent, and we expect Iran's economy to contract again this year. By contrast, according to the IMF, the economies of Iran's neighboring oil exporting competitors expanded last year by an average of over five percent and are expected to grow by an average of almost four percent this year.
            These macroeconomic indicators reflect the impact of sanctions on, and the deep structural problems with, Iran's economy, none of which will be solved by the limited relief agreed to in Geneva. Indeed, over the six-month duration of the JPA, our oil sanctions alone will cost Iran an additional $30 billion (i.e., 4-5 billion per month) in lost revenue, which far surpasses the total sum of the relief package. Even taking into consideration the modest relief package, these staggering figures represent a bleak reality for Iran's economy, which we expect will continue to deteriorate over the next six months.
The International Sanctions Regime Remains Robust
            We and our international partners will continue to impose increasing pressure on Iran's economy through the implementation and enforcement of sanctions, the overwhelming majority of which are not affected at all by the JPA. This includes the core architecture of our oil, financial and banking sanctions, which remain firmly in place.
            Throughout the duration of this first-step deal, we will continue to enforce sanctions to ensure that Iran's oil sales are held down at their current, greatly depressed levels. Moreover, our financial sanctions remain fully in place, in particular the sanctions imposed by section 504 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which became effective on February 6, 2013, and that "locks up" Iran's oil revenue in the few jurisdictions that still import oil from Iran.
            As a result, with the exception of the $4.2 billion in funds that we will allow Iran to access in stages over the next six months, the revenue that Iran earns from its oil sales during the six- month duration of the JPA will remain subject to our financial sanctions. Those sanctions prevent Iran from using those funds for any purpose other than paying for goods from the oil importing country or humanitarian transactions. And any financial institution that facilitates a payment to Iran for oil imports beyond what is provided for in the JPA risks being cut off from the United States financial markets. In other words, over the next six months Iran cannot sell any more oil than its current levels, and any additional oil revenue it does earn (other than the limited funds to be made available under the JPA) will be locked-up and unavailable for transfer or repatriation.
            In addition, the key banking sanctions imposed by the U.S. and the EU, which have resulted in the near-total isolation of Iran's financial sector, remain fully intact. That means that under Section 104 of the Comprehensive Iran Sanctions Accountability and Divestment Act of 2010, any foreign bank that engages in a significant transaction with Iran's designated banks risks losing its correspondent account access to the U.S. And it also means that all the banks designated by the EU will remain cut off from specialized financial messaging services, denying them access to critical networks connecting the rest of the international financial sector. Taken together, these sanctions – which remain fully in force – will ensure the continued isolation of Iran from the global banking system, and will continue to make it extraordinarily difficult to do business with Iran.
            We also are focusing on enforcing additional elements of the U.S. sanctions program that deprive Iran of other sources of revenue. For example, sanctions will continue to constrict Iran's energy sector. Not a single prohibition or sanction on investment in Iran's energy sector will be suspended – for U.S. or international companies. All of the United States' sanctions on long- term investments in Iran's energy sector will remain in effect, as will the related sanctions on providing technical goods and services to the energy sector. This will ensure that Iran's oil and gas infrastructure remains severely impaired and increasingly obsolete.
            Furthermore, all UN and EU designations, as well as our targeted sanctions on the more than 600 individuals and entities tied to the Government of Iran, its nuclear and ballistic missile programs and its energy, shipping, and shipbuilding sectors, remain in effect. Among other things, these sanctions mean that selling Iran cargo ships and tankers, providing insurance services or support for most Iranian shipping activities, providing flagging and classification services to Iranian ships, and helping Iran build port terminals or other facilities remain sanctionable activities.
            In addition, sanctions remain in place against Tidewater Middle East Company, an IRGC-owned port operating company that manages the main container terminal at Bandar Abbas – which has been responsible for some 90 percent of Iranian container traffic and has operations at six other Iranian ports. These sanctions will continue to deter the export of products to Iran as well as the import of products from Iran.
            This first-step deal also does not affect the longstanding U.S. trade embargo, meaning that Iran will continue to be shut out of the world's largest and most vibrant economy and precluded from engaging in business with U.S. companies and U.S. subsidiaries overseas.
            Finally, it remains the case that Iran is the leading state sponsor of terrorism in the world today. Nothing in the JPA affects our continued efforts to contest and combat Iran's support of terrorism, its abhorrent human rights practices, or its destabilizing activities in Syria. All of our sanctions programs aimed at undermining this loathsome Iranian conduct remain active and energetic.
Vigorous Enforcement of Existing Sanctions
            As President Obama said when he announced the JPA on November 23, "the broader architecture of sanctions will remain in place and we will continue to enforce them vigorously." This vigorous enforcement will be accomplished through the continued dedicated, resolute and creative work of professionals in our intelligence community, in the Treasury and State Departments, and across the Administration. We understand well the important role that sanctions pressure on the Iranian economy played in the lead-up to the JPA, and how important maintaining that pressure will be over the next six months as we explore the possibility of a long- term, comprehensive solution.
            As I have just discussed, the vast majority of our sanctions remain in place, which we will continue to vigorously enforce, even as implement the JPA. We are determined to continue – in the days, weeks, and months ahead – to respond to Iran's evasion efforts, wherever they may occur, and to continue to aggressively enforce our sanctions.
            For example, just yesterday, Treasury reached a $33 million settlement with the Royal Bank of Scotland plc for, among other things, apparent violations of U.S. sanctions on Iran and other sanctioned parties, including removing material references to U.S.-sanctioned locations or persons from payment messages sent to U.S. financial institutions. A few weeks ago we announced Treasury's largest settlement outside of the banking industry for violations of U.S. sanctions on Iran. As part of a combined $100 million settlement with several federal government partners, Weatherford International, Ltd. agreed to pay $91 million to settle its potential liability for extensive oilfield services provided in Iran from 2003 to 2007.
            We believe our actions have put the international business community on notice: Iran is still off limits, including designated Iranian banks and businesses. Foreign banks and businesses still have to make a choice – they can do business with Iran, or they can do business with the U.S.— not both. I can assure this that we will continue to take action against those who evade, or attempt to evade, our manifold sanctions on Iran.
            New designations and enforcement actions, moreover, are only one part of our strategy to ensure that the international business and banking community understands that now is not the time to expand activity in Iran. We have already begun a global campaign to ensure that foreign governments and the international private sector understand that the relief in the JPA is limited and targeted and that we and our partners are committed to ensuring that the pressure brought to bear on the Iranian economy remains robust. This campaign will continue in the weeks and months ahead, so that no one makes the mistake of believing that Iran is now open for business. It is not.
            I have a clear message for every government, bank, business or broker that thinks now might be a good time to test our resolve: We are watching closely, and we are prepared to take action against anyone anywhere who violates, or attempts to violate, our sanctions.

Click here for the full testimony.

GCC Annual Summit: Communique on Iran

            On December 11, the Gulf Cooperation Council issued a communique welcoming Tehran’s new efforts to engage with member states. The group -- which includes Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the United Arab Emirates -- discussed regional developments at a two-day summit in Kuwait. The following are excerpts from the communique on Iran.

Relations with Iran
      The Supreme Council stressed the importance of closer cooperation between the GCC countries and Iran on the basis of the principles of good neighborliness and non-interference in internal affairs, respect for the sovereignty of countries in the region, and to refrain from the use of force, or the threat of the use of force.
      The Supreme Council welcomed the new trends of the Iranian leadership towards the GCC countries, hoping these trends are followed by concrete steps that would reflect positively on the peace, security and stability in the region.
Iran's Nuclear Program
            The Supreme Council welcomed the interim agreement which was signed by the P 5 +1 with Iran on November 24, 2013 in Geneva, as a preliminary step towards a comprehensive and lasting solution to the Iranian nuclear program , that would put an end to concerns on the international and regional level about this program, and enhance the region's security and stability , and contribute to the elimination of all weapons of mass destruction , including nuclear weapons; and the Supreme Council reaffirmed the importance of the strict implementation of the agreement in full under the supervision of international Atomic Energy Agency (IAEA).
Disputed Islands
            The Supreme Council renewed emphasis on the continued occupation of the Islamic Republic of Iran of the three islands, Greater and Lesser Tunbs and Abu Musa, which belong to the United Arab Emirates, a point that has been stressed in passed communications. The Supreme Council further emphasized the following:
• Support for the right of sovereignty of the United Arab Emirates over its three islands of Greater and Lesser Tunbs and Abu Musa, and the territorial waters, airspace, continental shelf and exclusive economic zone of the three islands as an integral part of the United Arab Emirates.
• Any decisions, practices or acts carried out by Iran on the three islands are null and void and do not change any of the historical facts and the legal right to the sovereignty of the United Arab Emirates over its three islands.
• We invite the Islamic Republic of Iran to respond to the efforts of the United Arab Emirates to resolve the issue through direct negotiations or resorting to the International Court of Justice.
Faris Al Sulayman, a research assistant at the Woodrow Wilson International Center for Scholars, contributed to this translation.

Iran & South Asia #2: India Readjusts Ties

Sunil Dasgupta

What is the status of relations between India and Iran?
            New Delhi has had relatively close ties to Tehran since the mid-1980s, but India has recalibrated relations over the last few years as Iran became the litmus test for its ties with Washington. India has also been under pressure from Israel—one of India’s leading military equipment suppliers—and the Gulf states — where millions of Indian migrants live and work – to cut back relations with Iran. So while the Indian government would have preferred to pursue unimpeded diplomatic and trade ties with Tehran, it ultimately opted to diminish dealings with the Islamic Republic.
      India continues to import Iranian crude oil using exemptions from the U.S. sanctions, but it backed out of a multi-billion-dollar natural gas pipeline project with Iran due to the complications from U.S. sanctions and the fact that the pipeline was going to traverse Pakistan.
      New Delhi and Tehran continue to coordinate on development and trade issues on Afghanistan. But broader political coordination on Afghanistan is now minimal compared to the 1990s. They have not as yet joined forces, for example, to influence the succession to President Hamid Karzai or to counter Pakistani influence in Afghanistan.
            The Indian government is paying a price domestically for this policy shift. It faces opposition—particularly among political forces on the left and Muslim leaders—to moving away from Iran and toward the United States.
            So New Delhi welcomed the nuclear deal struck by Iran and the world’s six major powers in November 2013, which it hopes will eventually lead to the lifting of sanctions. India’s one concern, however, is that Iran’s return to the global oil market will cut its interest in trading oil with New Delhi in Indian rupees — on terms favorable to India.
On what issues do they collaborate? On what issues are they divided?
            People-to-people contacts between India and Iran are limited despite often-cited rhetoric from both governments. India has one of the world’s five largest Muslim populations, but 90 percent are Sunni—while Iran is predominantly Shiite. So India-Iran relations—and contacts—center narrowly on three main issues:
  oil and gas, with entrepreneurs in both state-owned and private firms pushing for more opportunities
  regional issues, notably Afghanistan and Pakistan, which are pursued mainly by Indian intelligence agencies
  defending Indian freedom of action in foreign policy, which has been a priority for politicians and thinkers who want to protect Indian national sovereignty
           Oil and Gas: On energy, India and Iran are natural trade partners. India depends on imports for up to 80 percent of its crude oil needs and 25 percent of its natural gas needs while Iran has the world’s fourth-largest proven oil reserves and second-largest natural gas reserves. India imported $11.6 billion of Iranian oil in fiscal year 2012-2013. New Delhi is Tehran’s second-largest oil customer. Some of this trade was conducted in Indian rupees, which was beneficial to India.
            Over the last decade, the Indian government had made some efforts to promote a natural gas pipeline from Iran to India through Pakistan. Pakistan had signed on to the project and even executed a gas purchase agreement with Iran. But U.S. sanctions on Iran and Indian apprehension about Pakistan derailed the project. Even if Washington lifted its sanctions, New Delhi’s interest in the pipeline project would be unlikely to revive without significant improvement in India-Pakistan ties.  
            Regional Issues: On Afghanistan, India worked with Iran to develop trade links that bypass Pakistan. The 135-mile Chabahar-Zaranj-Delaram Highway, completed in 2009, is one example, but developing alternative trade routes is an uphill—and perhaps quixotic—task for five reasons.
  Movement of people and goods across the Afghanistan-Pakistan border is larger and more established.
  Cultural ties across the Afghanistan-Pakistan border are stronger and involve Afghanistan’s largest ethnic group, the Sunni Pashtuns. In contrast, the Shiite Hazaras are a smaller population.
  Since Kabul is the main Afghan market, going through Iran is longer and more expensive.
  Private infrastructure already in place makes the Pakistani route cheaper and more feasible.
  Pakistan is unlikely to sit back and allow its influence to wane.
      Coordination between India and Iran on Afghan development is likely to remain limited. India’s overall development assistance to Afghanistan outweighs what New Delhi does there jointly with Tehran. Surprisingly, India and Iran do not appear to be coordinating their public positions on future political developments in Afghanistan, even with the prospect of the imminent U.S. withdrawal.
What is New Delhi’s position on Tehran’s controversial nuclear program?
            Since India tested nuclear weapons in 1998, New Delhi has rejected the argument that its nuclear tests and subsequent rehabilitation within the international non-proliferation regime sets a precedent that applies to Iran. New Delhi has tried generally to prevent India and Iran being seen in the same category. Even domestic critics of the government embrace this position, which explains why India voted against Iran at the IAEA on a 2009 resolution sponsored by Russia and China. The IAEA resolution, which criticized Iran for building a secret nuclear plant, became the basis for U.N. action against Iran and U.S. sanctions.
      The problem in India’s position has been that it has not been willing to accept the connection between the nuclear issue and its oil and gas trade with Iran. The United States and Israel view Iran’s oil wealth as a key resource for Tehran’s nuclear program— and sanctioning its trade as a way to pressure Iran into dismantling the program. But India has wanted to treat the issues separately out of self-interest.
India, Iran and Russia were key supporters of the Northern Alliance against the Taliban in the 1990s. In Afghanistan, what issues have Iran and India cooperated on? What has divided them?
            India and Iran have interests that align, but that does not always translate into alliances in action. The lack of public coordination between India and Iran on Afghanistan after the withdrawal of most U.S. troops has been particularly surprising, given the history of joint support for the Northern Alliance. India and Iran still cooperate on infrastructure projects and want to develop an alternative trade route bypassing Pakistan, but both are quixotic and limited in scope.
In 2005, Indian Prime Minister Manmohan Singh told The Washington Post “Iran is the largest Shiite Muslim country in the world. We have the second largest Shiite Muslim population in our country…And I do believe that thanks to our unique history we can be a bridge.” What kind of relationship does India’s Shiite population have with Iran, the world’s largest Shiite country? Have the two countries pursued ties along these lines?
     There is a difference between rhetoric and reality here. Yes, India has the second largest Shia community. But this Shia community is a small albeit vibrant minority of India’s Muslims. Indian Shiites do have religious ties to Iran, but even Indian Shiites go to Mecca for Hajj. The relationship between Shiite scholars is not so much religious as it is intellectual.
Sunil Dasgupta is director of the University of Maryland, Baltimore County’s Political Science Program and a nonresident senior fellow at the Brookings Institution.

Click here for Iran & South Asia #1: Pakistan’s Delicate Balancing Act

Click here for Iran & South Asia #3: After US Withdrawal from Afghanistan

Click here for Iran & South Asia #4: Issues, Facts & Figures

Photo credits: President Rouhani via President.ir, Manmohan Singh by World Economic Forum [CC-BY-SA-2.0 (http://creativecommons.org/licenses/by-sa/2.0)], via Wikimedia Commons, Bushehr nuclear power plant via NuclearEnergy.ir, Moulana Shahwar by Moulanashahwar (Own work) [CC-BY-SA-3.0 (http://creativecommons.org/licenses/by-sa/3.0)], via Wikimedia Commons

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