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The Iran Primer

Treasury Targets Sanctions Evaders

            On February 6, the Treasury announced sanctions targeting entities and individuals across Europe and the Middle East for evading U.S. sanctions on Iran. Some allegedly aided Tehran’s nuclear and missile programs or supported terrorism. “The global targets designated today play key roles in supporting Iran’s nuclear program and active support for terrorism. The United States has made clear that as it implements the Joint Plan of Action [interim nuclear agreement], contingent on Iran satisfying its own commitments, the overwhelming majority of sanctions remain in effect and will continue to be vigorously enforced,” said Under Secretary for Terrorism and Financial Intelligence David S. Cohen.  The following are excerpts from the press release.

Today’s actions target entities and individuals located across the world, operating in Turkey, Spain, Germany, Georgia, Afghanistan, Iran, the United Arab Emirates, and Liechtenstein.
The actions under Executive Orders (E.O.) 13224 and 13382 generally prohibit transactions between the designated entities and individuals and any U.S. person, and block any property and interests in property under U.S. jurisdiction of the designated entities and individuals.  In addition, any foreign financial institution or person that facilitates significant transactions or provides material support to the designated entities or individuals may have their access to the U.S. financial system severed or their property and interests in property under U.S. jurisdiction blocked. 
The actions under E.O. 13608 generally prohibit transactions involving the sanctioned persons that are subject to U.S. jurisdiction, including transactions by U.S. persons, wherever located.
Foreign Sanctions Evaders
Pourya Nayebi, Houshang Hosseinpour, and Houshang Farsoudeh
Pursuant to E.O. 13608, which targets foreign persons engaged in activities intended to evade U.S. economic and financial sanctions with respect to Iran and Syria, the Department of the Treasury sanctioned Georgia-based Pourya Nayebi, Houshang Hosseinpour, and Houshang Farsoudeh and eight companies owned or controlled by these individuals.  These three individuals have established companies and financial institutions in multiple countries, and have used these companies to facilitate deceptive transactions for or on behalf of persons subject to U.S. sanctions concerning Iran.  In 2011, they acquired the majority shares in a licensed Georgian bank with direct correspondent ties to other international financial institutions through a Liechtenstein-based foundation they control.  They then used the Georgian bank to facilitate transactions worth the equivalent of tens of millions of U.S. dollars for multiple designated Iranian banks, including Bank Melli, Mir Business Bank, Bank Saderat, and Bank Tejarat.
Nayebi, Hosseinpour, and Farsoudeh deceived the financial regulatory authorities of the Republic of Georgia by withholding required reports of transactions involving Iranian banks.  The Government of Georgia has worked closely with the United States to detect and address illicit and deceptive Iranian behavior in Georgia, and it has taken steps to ensure that Iranian entities under U.S. and international sanctions are prevented from exploiting the Georgian financial system.
Treasury is also imposing sanctions on eight companies located in multiple countries that are owned and/or controlled by Nayebi, Hosseinpour, and Farsoudeh (acting individually or together), including: Caucasus Energy (Georgia), Orchidea Gulf Trading (UAE and/or Turkey), Georgian Business Development (Georgia and/or UAE), Great Business Deals (Georgia and/or UAE), KSN Foundation (Liechtenstein), New York General Trading (UAE), New York Money Exchange (UAE and/or Georgia), and European Oil Traders (Switzerland).  KSN Foundation was used to disguise the control of the Georgian bank by Nayebi, Hosseinpour, and Farsoudeh, and the other entities were involved in the transactions for designated Iranian banks discussed above.  On multiple occasions, these front companies deceived the international financial community, including by generating false invoices in connection with transactions involving designated Iranian banks.
Iran’s Nuclear and Weapons Proliferation Activities
The following entities and individuals are sanctioned pursuant to E.O. 13382, which, among other things, targets weapons of mass destruction proliferators and their supporters. 
Ali Canko and the Tiva Sanat Group
Turkish citizen Ali Canko assisted the Iran-based Tiva Sanat Group in its attempts to procure and reverse engineer a weapons-capable fast boat to be used by the IRGC-Navy.  The Tiva Sanat Group is comprised of Tiva Kara, Tiva Darya, and Tiva Polymer.  Tiva Sanat Group uses front companies to acquire foreign technology and components, with at least one intermediary expressing concern that a payment would be interdicted by the U.S. Treasury because the intermediary falsely claimed to be the end-user for equipment that was intended for Tiva Sanat. Ali Canko has served as a financial intermediary for payments from the Tiva Sanat Group to various international suppliers.  The IRGC was designated pursuant to E.O. 13382 in October 2007 for having engaged, or attempted to engage, in proliferation-related activities.
Advance Electrical and Industrial Technologies SL and Pere Punti
Advance Electrical and Industrial Technologies SL (AEIT), located in Spain, procures items from foreign suppliers and facilitates financial transactions for the previously E.O. 13382-designated Neka Novin.  Spanish citizen Pere Punti is AEIT’s sole shareholder and also arranges to facilitate payments on behalf of Neka Novin.  Neka Novin was designated pursuant to E.O. 13382 in November 2011 for its involvement in the procurement of specialized equipment and materials that have direct application to Iran’s nuclear program.
Ulrich Wippermann, DF Deutsche Forfait Aktiengesellschaft, DF Deutsche Forfait Americas Inc.
German firm DF Deutsche Forfait Aktiengesellschaft (Deutsche Forfait) and Deutsche Forfait board member Ulrich Wippermann facilitated oil deals in circumvention of oil sanctions for NIOC, an entity determined to be an agent or affiliate of the IRGC and designated under E.O. 13382.  DF Deutsche Forfait Americas Inc. is the U.S. subsidiary of Deutsche Forfait.  NIOC was designated pursuant to E.O. 13382 in November 2012 for providing or attempting to provide, financial, material, or other support for and services in support of the IRGC.
Terrorism – Entities and Individuals Affiliated with Mahan Air
The U.S. Department of the Treasury announced today the designation pursuant to E.O. 13224 of key Mahan Air officials and front companies in the UAE that have served as critical conduits for Mahan Air financial payments as well as intermediaries for the airline’s acquisition of aircraft, engines, and other parts.These front companies have served as part of the procurement backbone of Mahan Air, enabling the sanctioned airline to continue ferrying significant quantities of weapons and other illicit cargo into Syria on its own passenger aircraft to support the Assad regime’s violent crackdown against its own citizens.Mahan Air was previously designated pursuant to E.O. 13224 in October 2011 for its support to Iran’s IRGC-QF.  
Blue Sky Aviation Co FZE (BSA FZE)
BSA FZE is a UAE-based company that is owned or controlled by Mahan Air and acts for or on behalf of the airline.  BSA FZE’s primary function has been to serve as a payment channel for Mahan Air to obscure the origination of funds.  Mahan Air has used BSA to make payments to oil suppliers, and purchase aircraft, engines, and parts. 
Avia Trust FZE
Avia Trust FZE is another UAE-based company that is owned or controlled by Mahan Air and acts for or on behalf of the airline.  Mahan Air has used Avia Trust FZE to procure sanctioned aircraft parts and equipment, to include items that are of U.S.-origin. The IRGC has used Avia Trust FZE as a front to procure aviation-related items, some of which are subject to international sanctions.  In addition, the IRGC has used Avia Trust FZE as a front to assist with avoiding customs inspections in the UAE of cargo destined for Iran, some of which included items subject to international sanctions. 
Hamidreza Malekouti Pour
Hamidreza Malekouti Pour has served as the regional manager for Mahan Air in the UAE and the managing director of Sirjanco Trading LLC and BSA FZE.  Malekouti Pour, operating out of Mahan Air’s office in the UAE, has supplied equipment to the IRGC-QF. Sirjanco Trading LLC was designated pursuant to E.O. 13224 on May 31, 2013, for acting for or on behalf of Mahan Air.
Pejman Mahmood Kosarayanifard
Pejman Mahmood Kosarayanifard acts for or on behalf of Mahan Air through his actions as the owner of Avia Trust FZE and several other companies engaging in business on behalf of Mahan Air.  Kosarayanifard has established agreements with Mahan Air to have Avia Trust FZE serve as a cutout for the repair and overhaul of Mahan Air aircraft engines. Kosarayanifard has also established agreements with Mahan Air to manage the airline’s cargo shipments and is reportedly responsible for IRGC procurement activities in the UAE.
Gholamreza Mahmoudi 
Gholamreza Mahmoudi acts for or on behalf of Mahan Air as a senior official and corporate director at Mahan Air.  Mahmoudi has worked closely with Mahan Air Managing Director Hamid Arabnejad on sanctions evasion strategies to acquire U.S. aircraft.  Hamid Arabnejad was designated pursuant to E.O. 13224 on May 31, 2013 for acting for or on behalf of Mahan Air.
Terrorism – IRGC-QF in Afghanistan
Today the Department of the Treasury announced the designations pursuant to E.O. 13224 of three IRGC-QF officers and one IRGC-QF associate involved in Iranian efforts in Afghanistan.  This action underscores Tehran’s use of terrorism and intelligence operations as tools of influence against the Government of the Islamic Republic of Afghanistan.  
IRGC-QF utilized now-detained Afghan associate, Sayyed Kamal Musavi, who was designated today, to plan and execute attacks in Afghanistan.  Two IRGC-QF officers also designated today, Alireza Hemmati and Akbar Seyed Alhosseini, provided logistical support to this associate.  Another IRGC-QF officer, Mahmud Afkhami, is being designated today to highlight his influence over Afghan political affairs and his efforts to advance Iranian interests with the Government of the Islamist Republic of Afghanistan.
In August 2010, Treasury similarly took action against two IRGC-QF leaders supporting terrorism in Afghanistan and funneling Iranian assistance to the Taliban.  Treasury then designated IRGC-QF General Hossein Musavi, the Commander of the IRGC-QF Ansar Corps, whose responsibilities include IRGC-QF activities in Afghanistan. Treasury also designated IRGC-QF Colonel Hasan Mortezavi.  Both Musavi and Mortezavi provided funding and material support to the Taliban as part of their official duties as IRGC-QF officers.
Sayyed Kamal Musavi
Sayyed Kamal Musavi is being designated for acting for or on behalf of the IRGC-QF as a facilitator and operational planner.  Musavi assisted the IRGC-QF in conducting surveillance and planning terrorist attacks in Afghanistan in 2010 prior to his arrest.  Musavi operated in Kabul and was part of an attack cell targeting an Afghan official and was apprehended with associates, who were at the time carrying large quantities of explosives and detonators.  
Alireza Hemmati
Alireza Hemmati is being designated for acting for or on behalf of the IRGC-QF.  Hemmati is an IRGC-QF chief for Afghanistan-focused operations conducted by the IRGC-QF, who provided key logistics support for now detained Afghan associate, Sayyed Kamal Musavi. Hemmati worked closely with Musavi while Musavi plotted attacks in Afghanistan, having sent supplies from Iran to Musavi and arranged travel documents for him.  Hemmati is pressing for Musavi's release from detention.
Akbar Seyed Alhosseini
Akbar Seyed Alhosseini serves as a key IRGC-QF officer who oversees the group’s activities in Afghanistan and is being designated for acting for or on behalf of the IRGC-QF.  Seyed Alhosseini previously served as chief of the IRGC-QF’s office in Herat, Afghanistan. He has arranged travel documents and logistics for IRGC-QF officers and associates, including now detained Afghan associate Sayyed Kamal Musavi, prior to Musavi’s arrest.
Mahmud Afkhami Rashidi
Mahmud Afkhami is a high-ranking IRGC-QF official within the elite IRGC-QF operations unit working in Afghanistan and is being designated for acting for or on behalf of the IRGC-QF. Afkhami’s responsibilities include currying favor with Afghan politicians who are sympathetic to Iran to strengthen the Iranian power base in Kabul.
Terrorism – al-Qa’ida’s Network in Iran
Today the U.S. Department of the Treasury announced the designation of a key Iran-based al-Qa’ida facilitator who supports al-Qa’ida’s vital facilitation network in Iran, that operates there with the knowledge of Iranian authorities.  The network also uses Iran as a transit point for moving funding and foreign fighters through Turkey to support al-Qa’ida-affiliated elements in Syria, including the al-Nusrah Front.
Olimzhon Adkhamovich Sadikov
Treasury today designated Iran-based Islamic Jihad Union facilitator Olimzhon Adkhamovich Sadikov (also known as Jafar al-Uzbeki and Jafar Muidinov) for acting for on behalf of and providing support to al-Qa’ida.
Today's action, taken pursuant to Executive Order (E.O.) 13224, follows Treasury’s designations in July 2011 of Ezedin Abdel Aziz Khalil (also known as Yasin al-Suri) and October 2012 of Adel Radi Saqr al-Wahabi al-Harbi, two al-Qa’ida officials who served as the head and deputy of al-Qa’ida's Iran network, respectively.  The State Department also authorized rewards totaling $17 million for information leading to the locations of al-Suri and al-Harbi, and additionally offered $10 million in October 2012 for information leading to the location of Muhsin al-Fadhli, who previously led the Iran-based al-Qa’ida network, and was designated by Treasury and the United Nations in February 2005. 
Jafar al-Uzbeki is a member of the Islamic Jihad Union and provides logistical support and funding to al-Qa’ida's Iran-based network.  As an associate of designated al-Qa’ida facilitator Yasin al-Suri, al-Uzbeki serves as a key extremist smuggler based in Mashhad, Iran, near the country's border with Afghanistan, and has provided visas and passports to numerous foreign fighters, including al-Qa'ida recruits, to facilitate their travel.  Al-Uzbeki has assisted extremists and operatives transiting Iran on their way into and out of Pakistan and Afghanistan.  Al-Uzbeki has also provided funding to al-Suri, who has resumed leadership of al-Qa’ida's Iran-based network after being temporarily detained there in late 2011. 
As head al-Qa’ida facilitator in Iran, Yasin al-Suri is responsible for overseeing al-Qa’ida efforts to transfer experienced operatives and leaders from Pakistan to Syria, organizing and maintaining routes by which new recruits can travel to Syria via Turkey, and assisting in the movement of al-Qa’ida external operatives to the West.
Al-Qa’ida’s network in Iran has facilitated the transfer of funds from Gulf-based donors to al-Qa’ida core and other affiliated elements, including the al-Nusrah Front in Syria.  The Iran-based al-Qa’ida network has also leveraged an extensive network of Kuwaiti jihadist donors to send money to Syria via Turkey. 
Click here for the full press release.

Nasser Hadian: Reasons Iran Wants Peace in Syria

Nasser Hadian

      Iran has turned the corner on Syria, its longstanding ally in the Arab world. It still wants close ties to a country that is the strategic center of the Arab world. But after three years of war, Tehran is also increasingly concerned that Syria may not hold together if President Bashar Assad stays in power because of bitter passions that now divide political factions, religious sects, ethnic groups and territory. 
            The Islamic Republic is now looking for an internationally negotiated solution with five goals: protection of minorities, credible democratic election, stability, containing jihadi militants and sectarianism, and an end to the killing. Tehran has not been willing to publicly embrace the Geneva I framework for negotiations, but it still would prefer to be part of the process. Iran believes it could play the kind of role it did during the 2001 Bonn talks on Afghanistan, when the Iranian delegation was pivotal in convincing the Afghan opposition to accept the U.S.-backed plan for a post-Taliban government. The key Iranian envoy then was Mohammad Javad Zarif, who is today Iran’s foreign minister. Tehran even feels some urgency in achieving a deal, for fear of the spillover of Syria’s instability on the wider Middle East.
            The gradual shift in Iran’s position, especially notable since the mid-2013 election of President Hassan Rouhani, reflects regional, religious, sectarian and strategic considerations.
      First, Iran does not really care that much about the Assad dynasty. Few inside the government support Assad on ideological grounds; the ruling Baath party is avowedly secular and socialist. Iran is more concerned about the alliance with the Syrian state, whoever is in power. At minimum, Iran wants a government in Damascus that is not hostile to Tehran. At maximum, it wants a regime that is shares Tehran’s strategic goals and interests.
            Many in the Iranian leadership now believe that Syria cannot hold together as a stable and unified country as long as Assad is in power due to political and physical fragmentation. They fear three years of war have produced deep wounds that will not be healed as long as Assad is in power.
            But Tehran also believes that the dismantlement of the entire regime—as happened in Iraq after the 2003 U.S. ouster of Saddam Hussein’s government, ruling Baath Party and military in Iraq—would be disastrous. It could produce a vacuum and potentially chaos, with even deeper spillover on the Middle East.
            Second, Iran wants to protect Syrian territorial integrity. Syria’s fragmentation could endanger other countries, including neighboring Iraq. Over time, any attempt by Syria’s two million Kurds, who already operate in a semi-autonomous enclave, to break away could trigger aspirations for a wider Kurdish state cutting into other countries. And the breakup of the current Arab states would almost certainly produce wider insecurity across the region.

            The spillover of Syria’s instability on Iraq and Lebanon are particularly worrisome for Iran. Tehran has important allies in both countries, and instability could weaken their position—and Iran’s influence. In Iraq, the government is has become an ally since Saddam Hussein’s ouster. And Lebanon is home to a large Shiite population with centuries-old Iranian ties.
            Iran is also concerned about losing its strategic links to Hezbollah and Hamas, which have long run through Syria. Hezbollah is a Lebanese Shiite party and militia that Iran helped create in 1982 and has trained and armed ever since. And Hamas is a Palestinian party and militia that has been a key ally since shortly after it emerged in the late 1980s. Iran considers both parties to be forces for defense, deterrence, and retaliation in case of an Israeli or American attack on Iran.             
            Third, Iran fears the deepening politics of identity, including the politics of religious identity. Iran has supported revolutionary Islam, but among both Sunni and Shiite.  Ironically, however, the world’s only modern theocracy is now concerned that the Syrian civil war will increase the sectarian divide between Sunni and Shiite across the region in ways that will hurt Iran—and Islam.
For centuries, Iranians have performed pilgrimages to dozens of Shiite holy places in Syria, like the Tomb of Zaynab on the outskirts of Damascus (above).
            Sectarianism in the Islamic world, from North Africa across the Levant to the Gulf and south Asia, is already dangerous. It plays out among individuals, groups and nations. Iran’s Shiites, who are a minority among the world’s 1.6 Muslims, are concerned about the fate of Shiites in Iraq, Syria, Lebanon, Yemen, Pakistan, and Afghanistan.
            More broadly, Tehran is worried that the growth of religious identity will generate rivalries over their diverse absolute truths that could spark conflicts ultimately more violent and difficult to resolve. So Tehran has an interest in ending the Syrian conflict to extinguish the flames of sectarianism and prevent a deepening divide between Islam’s two major sects.
            In the same vein, Iran wants protection of Syria’s minorities, including the Christians, Druze, Kurds and most of all the Alawites. The Alawites are widely associated with Shiism, even though many Shiites, including Iranians, do not view them as a legitimate offshoot. The real reason is that Syria’s minorities are potential allies, since they share a common concern about Sunnis who already dominate the Middle East physically, politically and numerically—and are now producing a growing number of extremist groups. The jihadis in Syria are also all Sunnis.
            Fourth, Iran is increasingly concerned about the rising death toll—now estimated to total more than 130,000 from both sides—and the use of chemical weapons. Iran is sympathetic to the victims because of its experience, which included some 1 million casualties, from the eight year-war with Iraq in the 1980s. Iran was also the victim of the widest use of chemical weapons since World War I. Saddam Hussein’s regime repeatedly used mustard and nerve gas against Iran. Thousands are still dying from mustard gas today, more than a quarter century after the war ended.
            Fifth, because of its isolation during war with Iraq, Tehran actually feels vulnerable—or strategically lonely. Iran was temporarily strengthened by the U.S. intervention in Iraq and Afghanistan, after the removal of its arch-enemies—Saddam Hussein in Baghdad in 2003 and the Taliban in Kabul in 2001. Over the next decade, Iran gained more leverage than at any point since the 1979 revolution.
            But two factors have reversed the trend. As the West and key Arab governments grew concerned about a “Shiite Crescent” radiating from Tehran to Beirut, the United States offered even greater aid and more powerful arms to the Persian Gulf sheikhdoms, which are all committed to containing Iran. The U.S. drawdown of troops from both Iraq and Afghanistan also made Iran change its strategic calculation, with the rise of al Qaeda franchises among Sunnis along its borders and the potential return of Taliban political clout in Afghanistan.
            Finally, Iran does not believe there is a viable military solution for Syria. A military victory by either side is neither possible nor desirable. Iran now favors an inclusive solution for all faiths and all political parties. It even favors a secular government that will include all minorities.
            As a result, Iran believes the most viable solution is an election— organized and supervised by the international community—to choose the next government. It views an election as a means of conflict resolution as well as a means of selecting a new government.
            Tehran has less faith that the Geneva peace talks will produce a solution for a simple reason: Neither side is now either willing or capable of genuine or enduring compromise. The opposition is too divided, while the most active fighters—the jihadist groups—are not in Geneva. They are likely to just keep fighting. And Assad is unlikely to simply quit or negotiate his own political suicide. So Iran believes the solution must be left to the Syria people in a popular vote.
Nasser Hadian is a professor of political science at the University of Tehran.
Photo credits: Leader.ir, Syria-Iran by RonenY [GFDL (http://www.gnu.org/copyleft/fdl.html) or CC-BY-SA-3.0 (http://creativecommons.org/licenses/by-sa/3.0/)], via Wikimedia Commons, Zaynab Tomb by Argooya at en.wikipedia [Public domain], from Wikimedia Commons
Online news media are welcome to republish original blog postings from this website in full, with a citation and link back to The Iran Primer website (www.iranprimer.com) as the original source. Any edits must be authorized by the author. Permission to reprint excerpts from The Iran Primer book should be directed to permissions@usip.org

Nasser Hadian: Revolution at 35

Nasser Hadian

      On the 35th anniversary of its revolution, Iran has found often novel compromises in blending Islam and modernity—politically, economically and socially. The government and most Iranians today share three goals: honoring the great Persian past and retaining an Islamic identity while also integrating more deeply into a globalizing world. The revolution today is all about synthesis. The struggle is finding the right balance.
            Politically, Iran’s government borrows heavily from Western concepts, including separation of powers. Each branch has its own turf, to the point that they have the same kind of tensions that Western governments do—and sometimes even harsher. The parallel religious institutions—such as the Guardian Council—weigh in not to run daily government but as a fourth check on secular powers and politicians. Since 1988, Tehran has also added an Expediency Council of both religious and laymen to resolve political conflicts, another reflection of trying to negotiate a balance.
            The revolution has brought a wide array of players into the political space over the past 35 years. Iran’s spectrum grows with every election, as new factions and faces join the fray. There are now dozens of parties, ranging from reformist to ultra-conservative, who compete passionately against each other. The diversity of opinion is even wider within society, ranging from more leftist to more rightist.
       The idea of citizenry has also taken root in among Iran’s 80 million people, the majority of which has been born since the revolution and is highly educated. Voters have become more sophisticated in their demands. They are moving beyond passive obedience of either political or religious authority. People also have an impact on decisions, whether through the vote or street protests. So the government, for all its restrictions, has frequently been forced to accept public opinion, including electoral surprises.
            But Iranian politics still have a wild side. Politics is controlled by a minority and the rules – or political red lines – shift from one presidency to the next and from one parliament to the next. Iran’s elections also involve a strange combination: Freedom to run is very limited—and candidates approved to run in one election can be disqualified when they try to run again. Competition is fierce. Yet results can be unpredictable.
            Ironically, Iran has resolved the debate about an “Islamic economy.” After a lot of trial and error, Tehran opted to run the economy based largely on modern science and global standards rather than traditional religious practices. Aiding the oppressed is still a revolutionary tenet. But Iran has not become a socialist country. Modern economic principles, including respect for private property, have not been forfeited even as the government has tried to help the poor.
      The fight is far from over, however. Iran does not have a corporate economy largely because the government-backed charities, or bonyads, control vast resources. Government institutions, such as the Revolutionary Guards, and quasi-government groups also control large chunks of economic life. So Iran does not have a large number of private companies, even though commerce has been one of the pillars of Iranian society for millennia.
            The revolution has built infrastructure—such as roads, electricity, schools and some basic health services—particularly in small towns and rural areas. It paid off the shah’s foreign debt in the 1980s, revived the Stock Market in the 1990s, and has survived severe international sanctions, particularly since 2006. At great cost, Iran has also continued subsidies of basic commodities—from petroleum to basic foodstuffs.    
            But Iran’s economy has been plagued by gross mismanagement in recent years. Few in leadership positions have been willing to demonstrate the political courage to introduce the tough measures needed to turn the economy around, whether through more rigorous subsidy reforms, privatization or deficit reduction that would encourage local or foreign investment.
            Iran is also still a rentier state disproportionately dependent on oil income. And the economy is highly vulnerable because Tehran has been unable to update its oil infrastructure since the revolution. After the latest U.S. sanctions were imposed in 2012, oil exports then dropped by more than half, while the value of Iran’s currency plummeted by sixty percent. Oil revenues have also not been distributed equitably or wisely, with corruption and favoritism now rampant. Privatization and deregulation have been largely unsuccessful because the government has allowed its assets to be transferred to favored “clients.”
            Iran initially tried to Islamicize society, but the forces of modernity have often prevailed. The Islamic Republic now openly tolerates scientific and even secular ideas. More than three decades after the revolution, Iranian society is arguably more modern than it was under the monarchy.
      Changes in society are particularly evident among its youth and women. The Pahlavi monarchy may have been more progressive on women’s rights in the law, but the Islamic Republic has brought more women into education, the economy and politics, even though they have to comply with Islamic norms such as the dress code or strict family laws.
            Revolutionary Iran won a U.N. award for closing the gender gap in education. And the majority of students at Iranian universities are today female, despite recent restrictions on their coursework. Access to education and modern institutions has particularly brought many females from traditional families into the professions, politics and the arts.
            The revolution has also adapted to the forces of globalization, as education, urbanization and technology, which have transformed society in ways that the government could not control. Demographics—particularly the baby boom generation born in the 1980s now coming of age—are a strong counterbalance to the aging revolutionaries.
            But some sectors of society—the poor, the rural and women—clearly face serious inequities in politics and in life. The Islamic Republic is still patriarchal. Men dominate power and commerce. The poor and the rural have limited means of bettering their circumstances. And despite the pressures of globalization, the government controls freedom of speech and access to the outside world, although not completely.
            But, ironically, on its 35th anniversary, a religious government has produced one of the most secular societies in the Middle East. Indeed, for many living in the Islamic Republic today, the relationship between the individual and God is private, not political.

Nasser Hadian is a professor of political science at the University of Tehran.

Photo credits: @HassanRouhani via Twitter, Iran oil exports via U.S. Energy Information Administration, Isfahan University graduates by gire_3pich2005 (Own work) [FAL] via Wikimedia Commons,

Online news media are welcome to republish original blog postings from this website in full, with a citation and link back to The Iran Primer website (www.iranprimer.com) as the original source. Any edits must be authorized by the author. Permission to reprint excerpts from The Iran Primer book should be directed to permissions@usip.org

State Dept Outlines Terms for Enduring Nuke Deal

            On February 4, Under Secretary for Political Affairs Wendy Sherman testified before the Senate Committee on Foreign Relations on implementing the interim nuclear deal between Iran and the world’s six major powers − Britain, China, France, Germany, Russia and the United States. The following are excerpts from her statement.

Negotiation Update
The Iranian nuclear program constitutes one of the most serious threats to U.S. national security and our interests in the Middle East. An Iranian regime armed with nuclear weapons would destabilize the Middle East, put our allies and partners in the region at risk, and undermine the global nonproliferation regime. Fully aware of the seriousness of this challenge, the P5+1 (China, France, Russia, the UK, United States and Germany, coordinated by EU High Representative Catherine Ashton) has engaged over the past months in sustained negotiations with Iran over its nuclear program. On November 24, 2013, the P5+1 took an important first step as part of that diplomatic push by agreeing with Iran on a Joint Plan of Action (JPOA). This joint plan is sequenced over the next six months to explicitly block near-term Iranian pathways to a nuclear weapon, while creating space for further negotiations to reach a long-term comprehensive solution.
A little more than two weeks ago, on January 20, 2014, the JPOA went into effect. As the President noted, the implementation of the JPOA marked the first time in a decade that Iran agreed to specific actions that halt progress on its nuclear program and roll it back in key respects. Specifically, the International Atomic Energy Agency (IAEA) verified on January 20 that, among other things, Iran:
·         has stopped producing near-20 percent enriched uranium (UF6);
·         disabled the configuration of the centrifuge cascades that Iran has been using to produce it;
·         begun diluting its existing stockpile of near-20 percent enriched uranium and continued to convert near-20 percent enriched uranium to oxide for fuel plates at a rate consistent with past practices so that it will have eliminated its entire near-20 percent enriched uranium stockpile at the end of six months; had stopped installing additional centrifuges at the Natanz or Fordow facilities;
·         and had not installed additional reactor components at the Arak facility
·         begun providing some of the information required by the JPOA and is working with the IAEA on arrangements for increased access to its nuclear facilities.
In order to carry out its responsibilities under the JPOA, the IAEA will roughly double the size of its inspection team and install additional monitoring equipment. The size of the team and the access afforded under the JPOA mean the international community’s insight into Iran’s nuclear program will be significantly enhanced.
This was an important first step, and over the next six months, Iran has committed itself to further actions that will provide much more timely warning of a breakout at Iran’s declared enrichment facilities and will add new checks against the diversion of equipment and material for any potential covert enrichment program… As the President said in his State of the Union speech, these negotiations do not rely on trust; any long-term deal we agree to must be based on verifiable actions and constraints that convince us and the international community that Iran is not building a nuclear bomb…
The United States and the EU also took a series of actions on January 20 to implement the limited, temporary, and reversible sanctions relief we committed to as part of the JPOA, including:
·         The necessary steps to pause efforts to further reduce Iranian crude oil exports, allowing the six current customers of Iranian oil to maintain their purchases at current reduced levels for the duration of the JPOA;
·         Issuing the necessary waivers to suspend for the duration of the JPOA sanctions on non-U.S. persons engaged in transactions related to the export of petrochemical products from Iran, certain trade in gold and precious metals to or from Iran, and the provision of goods and services to Iran’s automotive sector.
·         The EU increased the size of financial transfers to and from Iran that are permissible by the EU without prior authorization.
·         The Administration is working with its partners and Iran to establish a mechanism to further facilitate payments for humanitarian transactions and to enable Iran to make payments for medical expenses – which are already explicitly exempt from Congressional sanctions – as well as, university tuition payments for Iranian students studying abroad, and its UN obligations.
·         The United States has also committed to license transactions for spare parts, inspections, and associated services in Iran necessary for safety of flight for Iran Air and non-designated commercial Iranian airlines.
·         Finally, on February 1, the U.S. government facilitated the repatriation of $550 million in Iranian funds restricted overseas. This transaction was part of the agreement to allow Iran to access – in monthly installments through July 20th – $4.2 billion of its own restricted funds contingent on Iran fulfilling its commitments under the JPOA.
First, a number of observers have criticized the JPOA, arguing that we should have negotiated a comprehensive solution with Iran over its nuclear program from the outset. If we believed we could have negotiated a comprehensive solution from the outset in a short period of time, we would have done so. But it became apparent that such a negotiation was going to take some time, and we wanted to make sure that during the intervening period Iran did not move forward on the most worrisome parts of its nuclear program.
Had we not agreed on the JPOA, Iran’s stockpile of near-20 percent enriched uranium would have continued to grow, Iran would have continued to install faster and more advanced centrifuges, and Iran would have made progress on the Arak reactor. The JPOA has instead committed Iran to stop the advance of its program, roll it back in some key areas, and give us time and space to negotiate a long term comprehensive solution that will address our concerns in an enduring manner.
Second, some have argued that the JPOA will weaken the unprecedented sanctions regime we have worked with Congress to build, and that it will give the Iranian economy enough breathing room so that it does not feel pressure to negotiate a comprehensive solution. We disagree. The core sanctions architecture remains firmly in place and the relief that Iran was granted through the JPOA was explicitly and intentionally tailored to maintain pressure and our ability to negotiate the comprehensive solution.
Our analysis indicates that the JPOA appears unlikely to provide Iran any significant economic benefits, especially any that could resolve the Iranian economy’s many problems. While Iran’s currency appreciated after Iranian President Rouhani’s election and just after the JPOA was announced, it now stands at about the same level as where it was at the time the JPOA was rolled out, perhaps reflecting a more sober assessment by the market of the limited relief it will provide.
Iran’s oil exports will still be constrained at levels that are down over 60 percent since 2011. This means that Iran will continue to lose $4-5 billion per month while the JPOA is in effect compared to 2011. The $4.2 billion being repatriated over the six months is a modest fraction of Iran’s $100 billion in foreign exchange holdings, the vast majority of which are restricted or inaccessible. And the six-month time frame will make it difficult for any long-term business to take place even in the sectors for which we have provided relief.
There is no doubt that companies are keeping an eye on Iran. We have always said Iran and its people hold vast potential. But we – the State Department and Treasury Department – have made, are making, and will continue to make, very clear to countries and companies around the world that we will vigorously enforce the vast set of sanctions that remain in place. Indeed, on December 12, 2013, we sanctioned a number of entities and individuals involved in the proliferation of WMD-related material and attempts to evade U.S. sanctions against Iran. We will remain vigilant. It is this vigilance that will keep the various trade delegations that we have seen going to Iran aspirational rather than practical.
Comprehensive Solution
Later this month, the P5+1 Political Directors will meet with Iran to begin discussions regarding a comprehensive solution on Iran’s nuclear program. As stated in the JPOA, our goal for these negotiations is to reach a mutually-agreed long-term comprehensive solution that would ensure Iran’s nuclear program will be exclusively peaceful... This comprehensive solution would build on the initial steps we have already begun to take. Ultimately, the comprehensive solution would be one under which we would be verifiably assured that Iran’s nuclear program is peaceful and that Iran will not acquire a nuclear weapon.
·         As to specifics of what we envision, the President and Secretary have recently laid down certain aspects that are indicative of what we envision.
·         As the President said at the Saban Forum on December 7, 2013, we know that Iran does not need to have an underground, fortified enrichment facility like Fordow in order to have a peaceful nuclear program.
·         They do not need a heavy-water reactor at Arak in order to have a peaceful nuclear program…
·         Among other elements, the final step of a comprehensive solution would have a specified long-term duration to be agreed upon and reflect the rights and obligations of parties to the Non-Proliferation Treaty and IAEA Safeguards Agreements.
·         Iran has committed itself to address the UN Security Council resolutions with a view toward bringing to a satisfactory conclusion the UN Security Council’s consideration of this matter.
·         Iran has committed to implement agreed transparency measures and enhanced monitoring. The Joint Commission set up between Iran, the P5+1 and the EU to oversee the implementation of the JPOA will also serve as a forum for discussion to facilitate the IAEA’s resolution of “past and present issues of concern” – which all parties understand means the possible military dimensions of Iran’s nuclear program…
We have agreed with Iran that the comprehensive solution will be part of an integrated whole where nothing is agreed until everything is agreed. What is also important to understand is that we remain in control over whether to accept the terms of a final deal or not. We have made it clear to Iran that, if it fails to live up to its commitments, or if we are unable to reach agreement on a comprehensive solution, we would ask the Congress to ramp up new sanctions. In that situation, we would be well-positioned to maximize the impact of any new sanctions because following a strong diplomatic effort 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 diplomacy I have just outlined, alienate us from our allies, and risk unraveling the international cohesion that has proven so essential to ensuring that our sanctions have the intended effect.
Terrorism, Human Rights and Regional Meddling
We will not relax our efforts to hold Iran accountable for its human rights violations and abuses, support for terrorism, and interference across the region. We remain deeply concerned with Iran’s destabilizing activities across the region, which threaten the security of partners such as Israel and our Gulf allies. Iran continues to fund, arm, train, and send troops to fight alongside the Asad regime in Syria, fueling sectarian violence and extremism.
Iran also continues to arm and train militants in Lebanon, Gaza, Iraq, Afghanistan, Yemen, and Bahrain. And Iran and Lebanese Hizballah continue to pursue terrorist activity around the globe. We are committed to working with our allies and partners to counter this destabilizing behavior. Due in part to our efforts, we have seen an encouraging trend in the past two years of increasingly firm responses from governments around the world to stand up to Iran’s and Lebanese Hizballah’s aggressive actions…Let me cite a few examples.
·         Together with our allies and partners, we have repeatedly intercepted Iranian shipments of weapons to militants in Yemen, Afghanistan, and Gaza.
·         Just over one month ago, Bahraini authorities seized a boat filled with Iranian explosives and arrested a dozen militants meant to receive the smuggled cargo.
·         We have assisted the governments of Georgia, India, Thailand, Kenya, Nigeria, and Bulgaria in investigating Iranian and Lebanese Hizballah-directed terrorist attacks and plots.
·         Wherever possible, we have pushed these countries and their neighbors to hold Iran and Hizballah accountable for these egregious acts.
·         Our diplomatic efforts resulted in the EU’s 2013 designation of Hizballah’s military wing as a terrorist organization and the Gulf Cooperation Council’s blacklisting of Hizballah.
·         And here at home, in May 2013, Mansour Arbabsiar, the man recruited by the IRGC’s Qods Force to assassinate the Saudi Ambassador to the United States, was sentenced to 25 years in prison.
Finally, we have expanded our own sanctions against Iran and its proxies. In February 2013, under the Iran Threat Reduction and Syria Human Rights Act, we designated 15 senior Iranian officials for involvement in illicit nuclear activities, support for terrorism, or human rights abuses. On January 23 of this year, we designated the Deputy Secretary General of the Palestinian Islamic Jihad (PIJ), Ziyad al-Nakhalah, as a Global Terrorist. Furthermore, the U.S. Government has identified the Lebanese Canadian Bank and two Lebanese exchange houses as financial institutions of primary money laundering concern, because their activities facilitated the money laundering activities of narcotics traffickers and provided support to the terrorist group Lebanese Hizballah.
Human Rights
We also continue to hold Iran accountable for its deplorable human rights record. In her December Human Rights Day speech, National Security Advisor Susan Rice said our support for the human rights of all Iranians will continue, even as we test the potential for a diplomatic resolution to the nuclear issue. With our allies, we will continue to highlight Iran’s ongoing human rights violations and abuses.
As part of this work, the United States partnered with 85 other countries to support and pass this year’s UN General Assembly 3rd Committee resolution condemning Iran’s poor human rights record. We are now working to build support for a Human Rights Council resolution to be voted on in March to extend the mandate of the UN Special Rapporteur on the Situation of Human Rights in Iran, and we will continue to urge the international community to press Iran to allow him to visit the country and directly observe its human rights conditions.
Every week on the Virtual Embassy Tehran website and in our social media, we highlight human rights violations and abuses in Iran. We were heartened by the September and October releases of more than 40 prisoners of conscience, including human rights lawyer Nasrin Sotoudeh – whom we had highlighted on the Virtual Embassy and commended publicly following her receipt of the EU Sakharov Prize in 2012.
We call on Iran to release all of its political prisoners, including Green Movement leaders Mir Hossein Mousavi and Mehdi Karroubi, who are approaching three years under house arrest with no formal charges. We will also continue to document Iran’s human rights violations and abuses in our annual Human Rights and International Religious Freedom Reports, drawing attention to the government’s treatment of its people. We too hear the promises of President Rouhani to his people and we will continue to support Iranians as they call on him to fulfill these promises and to ensure Iran meets its international human rights obligations.
American Citizens Detained in Iran
We also continue to call on Iran to release Saeed Abedini and Amir Hekmati and support our efforts to bring Robert Levinson home. We welcome Foreign Minister Zarif’s comments that clemency may be possible for Mr. Abedini and Mr. Hekmati and look forward to hearing more from Iran about this option. We repeatedly have asked the Iranian government for assistance in locating Mr. Levinson, and for Iranian authorities to permit a visit by officials of the Swiss Embassy in Tehran to determine the well-being of Mr. Hekmati and Mr. Abedini and to release them. We are aware of the transfer of Mr. Abedini to Rajai Shahr prison and have concerns about his medical condition. We have asked the Iranian authorities to address our concerns about his health and prison conditions and transfer him back to Evin.
The President raised the three cases with Iranian President Rouhani during their September 27 call. The Secretary has raised the issue directly with Iranian Foreign Minister Zarif, including just this weekend. On the sidelines of our negotiations in Geneva, I raised the three cases with Iranian officials and urged them to address our concerns. We have raised the issue with our international partners to request they raise the cases directly with Iran and we will continue to do so until they return home. They remain a top priority of the U.S. government and we will continue to press the Iranian government to take actions to allow them to reunite with their families.
Our policy and approach to Iran remains multi-pronged, yet we seek one ultimate goal: an Iran that respects its international obligations and commitments, that respect the rights of its citizens and neighbors, and that plays a constructive role in the region. The P5+1’s negotiations with Iran underscore that it is possible to begin making progress on this effort.
We are not blind to the more than 30 years of difficult history between the United States and Iran or Iran’s past actions, but it is important that we give diplomacy a chance to succeed. If Iran lives up to its commitments then the world will become a safer place. If it does not, then we retain all options to ensure that Iran cannot obtain a nuclear weapon. The coming months will be a test of Iranian intentions, and of the possibility for a peaceful resolution to this challenge to peace and international security.
Click here for her full testimony.

Treasury Dept: Sanctions Far from Being Lifted

            On February 4, Treasury Under Secretary for Terrorism and Financial Intelligence David S. Cohen testified before the Senate Foreign Relations Committee on the limited sanctions relief for Iran included in the interim nuclear deal. The following are excerpts from his statement.

Maintaining Pressure on Iran
Viewed in light of the depths to which Iran’s economy has sunk – brought about in large part by the sanctions that continue to remain in place – the approximately $7 billion in relief that Iran stands to receive over the next six months will not materially affect its economy.  To the contrary, because of our ongoing active efforts to implement and enforce the manifold U.S. and international sanctions that remain in place, we expect the economic pressure on Iran will continue unabated during the pendency of the JPOA.
For the first time in 20 years, Iran will be in a recession for two consecutive years; its economy contracted 6 percent in the Iranian fiscal year ending in March 2013, and we assess that it will contract again this fiscal year.  Iran will continue to have limited or no access to almost $100 billion in foreign exchange holdings in accounts overseas.  Its budget deficit reached about 5 percent of GDP last year and will remain sizable in the current budget year.  And Iran’s currency, the rial, has lost around 60% of its value against the dollar since 2011 while the official inflation rate is around 38%. 
Going forward over the six-month duration of the JPOA, Iran’s economy will continue to be buffeted by sanctions, as the core architecture of U.S. sanctions remains firmly in place. 
For example, we are continuing to implement and enforce our oil sanctions, which have driven down Iran’s oil exports by more than 60% over the last two years.  These sanctions also preclude the purchase of Iranian oil by any country other than Iran’s six remaining oil customers, who may not exceed their current purchase levels as outlined in the JPOA and our sanctions relief.  During the period of the JPOA, the oil sanctions alone will cost Iran approximately $30 billion in sales it cannot make. 
We are continuing to implement and enforce our financial sanctions, which require the payment for oil imported from Iran by the six current customers to be paid into accounts that can be used only to facilitate humanitarian transactions or bilateral trade between the importing country and Iran.  This Iranian oil revenue can neither be brought back to Iran nor moved to third countries, except to facilitate humanitarian trade.  And since the accounts that receive the oil revenue already hold more funds than Iran chooses to spend, the effective value of those oil sales to Iran is far less than 100 cents on the dollar.
We are continuing to implement and enforce our banking sanctions, which call for the exclusion from the U.S. financial system of any foreign bank that knowingly engages in significant transactions with designated Iranian banks.  The EU is also continuing to implement and enforce its banking sanctions, which have led to the termination of SWIFT access for most Iranian banks.  Altogether, these banking sanctions – which all remain fully in force – have largely cut-off the Iranian banking sector from the international financial system. 
We are continuing to implement and enforce the vast majority of our sanctions on Iran’s energy sector.  That includes, among other things, sanctions on significant investment in Iran’s energy sector and on the sale of significant goods or services that could be used in Iran’s energy sector.
And we are continuing to implement and enforce the broad trade embargo between the U.S. and Iran.  Outside of transactions involving humanitarian goods, U.S. banks and businesses, including their overseas subsidiaries, are largely forbidden from engaging in any transactions with Iran.
Now, to be sure, since the election of President Rouhani in June, there has been some improvement in a few economic indicators, such as the value of the rial and the inflation rate.  None of that improvement, however, is attributable to the limited sanctions relief in the JPOA which, of course, went into effect only two weeks ago.  Indeed, these indicators are largely unchanged over the past few months.  Instead, much of the uptick in these metrics occurred over the summer following the election of President Rouhani in June; they appear to be due largely to public optimism that the Rouhani administration would put in place competent economic managers and obtain comprehensive sanctions relief.     
While President Rouhani did, in fact, replace many of those responsible for mismanaging the Iranian economy during President Ahmadinejad’s tenure, the JPOA does not deliver comprehensive sanctions relief.  To the contrary, because the most potent sanctions remain firmly in place, Iran’s economy will remain under pressure.  Most importantly, its oil revenues will remain significantly depressed and the vast majority of its foreign reserves will remain restricted or inaccessible.  As a result, Iran will continue to struggle to finance its imports, to fund its government operations, and to defend the value of the rial. 
Even with a slight uptick here or there in some economic indicators, the continuing impact of our core oil, banking, financial, and energy sector sanctions – and the cumulative impact of those sanctions – means that the Iranian economy is operating at significantly reduced levels and will continue to massively underperform for the foreseeable future.  To get out of the hole that it is in, Iran needs better economic management and substantial, structural economic relief that can come only from lifting the broad sanctions that remain in place – something the JPOA does not contemplate, but the promise of which we assess will motivate Iran to negotiate a serious and comprehensive solution to our concerns with Iran’s nuclear program in the next phase.
Engagement with Foreign Counterparts and The Private Sector
So while we remain committed to providing, in good faith, the relief agreed to under the JPOA, we also remain hard at work implementing and enforcing a sanctions regime left largely intact by the JPOA – a sanctions regime of unprecedented force and scope.  The reason is simple: We know that intense sanctions pressure helped bring about the JPOA, and likewise will be a critical component in the negotiations to come. 
To ensure the force and scope of our sanctions, we are continuing our long-standing efforts to work with our international counterparts in the application and enforcement of our sanctions.  This has been a whole-of-government effort, involving officials at all levels of the Administration.  Secretary Lew, for example, has met with many of his counterparts in Europe and with literally hundreds of business and banking executives to drive home the point that the sanctions relief in the JPOA is narrow, that the sanctions that remain in place are broad, and that we intend to enforce our sanctions vigorously.  And over the last six weeks, I have traveled to the UK, Germany, Italy, Austria, Turkey and the United Arab Emirates carrying the same message: Iran is not open for business. 
In meetings with banks, businesses and trade promotion authorities, as well as with our governmental counterparts, I have explained that complex, robust, and broad sanctions remain in effect.  This means, of course, that substantial legal risk remains for anyone attempting to do business with Iran.  I have pointed out in particular that all of our banking sanctions, and all of the EU’s banking sanctions, remain in place, which means that any business looking to get paid for delivering goods to Iran will continue to confront an Iranian financial sector largely cut-off from the SWIFT network and mostly unable to transact internationally. 
And I have also emphasized that anyone doing business with Iran continues to incur significant reputational risk.  For years, we have exposed the complexity and sophistication of Iran’s deceptive attempts to evade sanctions to acquire material for its nuclear program – hiding behind false front companies, deleting identifying information from contracts and payment messages, and disguising the origin of its oil.  The line between licit and illicit Iranian business has always been blurry at best, and that has not changed.
Continued Robust Enforcement of Sanctions
Now, we recognize that most businesspersons and bankers do not set out intentionally to engage in sanctionable transactions.    And I would also strongly encourage anyone, anywhere who thinks now might be a good time to test the boundaries and challenge our resolve to think again. 
As President Obama has made clear, we will continue to vigorously enforce the vast array of sanctions that are not suspended by the JPOA – sanctions that reach Iran’s energy, banking, and trade sectors, along with its access to the international financial system.  We also will continue to target Iran’s support for terrorism and human rights abuses.  And we will continue – in the days, weeks, and months ahead – to respond to Iran’s efforts to evade our sanctions, wherever they may occur.  
We know that some companies are talking to the Iranians.  While there is nothing necessarily sanctionable about just talking, if those conversations turn into deals that exceed the narrow bounds of the relief agreed to in the JPOA and involve sanctionable activity, we will not hesitate to respond.  Indeed, the JPOA implementation understandings themselves explicitly recognize that we will enforce existing sanctions.
And we are doing so.  Just last week, for example, Treasury reached a $9.5 million settlement with the Bank of Moscow to settle potential civil liability for 69 transfers it sent to or through U.S. banks that were for or on behalf of Bank Melli Iran ZAO, a sanctioned Iranian entity.  None of the payment messages Bank of Moscow sent included direct references to Bank Melli Iran ZAO.  Instead, the Iranian bank was identified through the use of abbreviations while the Bank of Moscow avoided using terms such as “Melli,” “Iran,” or the bank’s SWIFT Business Identifier Code.  This settlement follows a string of Iran-related enforcement actions we have taken over the past few weeks and months.
Two weeks ago, we announced a landmark $152 million settlement agreement with Clearstream Banking S.A., of Luxembourg, to settle its potential civil liability for providing Iran with substantial and unauthorized access to the U.S. financial system.  Specifically, Clearstream served as the intermediary through which the Central Bank of Iran was able to maintain a beneficial ownership interest in securities held in custody in the United States.       
And before that, we reached a $33 million settlement with the Royal Bank of Scotland and a $91 million settlement with Weatherford International, Ltd.  Both settlements involved investigations of apparent violations of our sanctions on Iran; the latter was Treasury’s largest ever settlement outside of the banking industry.
At the end of last year, we designated more than a dozen targets located inside Iran and around the world – from Cyprus to Singapore – involved in efforts to help Iran or its military procure goods and technology for Iran’s nuclear or defense sectors through front companies and deceptive financial transactions. 
And we will continue to detect, disrupt, and disable those facilitating Iran’s nuclear and missile programs by identifying front companies, evaders, and violators and sanctioning them. We have done so more than 600 times before and we will continue to do so during the next six months.
The message should be clear: The United States is watching, and the Administration is poised to deploy our tools against anyone, anywhere, who violates our sanctions.
The Joint Plan of Action has created the space, over the next six months, to explore the possibility of a long-term, comprehensive solution to concerns with Iran’s nuclear program.  Achieving that goal will require, among many other things, that we deliver on our commitments to provide the specific, limited relief contemplated by the JPOA while maintaining significant pressure on Iran.  And that is precisely what we intend to do. 

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