Muslim Ban Statistics Show Continued Discriminatory Impact

For 2.5 years, the Muslim Ban has succeeded in separating American families and making the country less inclusive. Thanks to an amendment from Sen. Chris Van Hollen (D-MD), the Consolidated Appropriations Act of 2019 requires the Trump administration to provide a detailed report every 90 days until September 30, 2019 regarding the implementation of the ban. Below are some of the most relevant findings of the first report, which was issued in June. New data is due to be reported again this month.

While the ban is no longer being implemented in front of TV cameras at airports across the country, the data shows that its impact is still extensive – particularly on Iranian nationals. Between December 8, 2017 and March 31, 2019, there were only 1,607 nonimmigrant visas issued to Iranian nationals compared to 18,571 denials under the ban.1 During that same period, 227 immigrant visas were issued to Iranian nationals contrasted to 9,819 denials due to the ban.2

Waivers Remain Low & Visa Refusals Remain High

An alien subject to the Muslim Ban may apply for a waiver but the burden of proof is on the individual to establish that they are eligible for a visa and a waiver. There is no separate application for a waiver — the evidence presented during the consular interview process is what is considered during the waiver determination. Consular officers have wide discretion to make a waiver determination based on three criteria:

    • (A) denying entry would cause the foreign national undue hardship;
    • (B) entry would not pose a threat to the national security or public safety of the United States; and
    • (C) entry would be in the national interest.

Based on the data provided, the waiver process continues to be a sham. Waivers are issued irregularly and in such small numbers seemingly to uphold appearances that this is not a blanket ban fulfilling a bigoted campaign promise.

  • The overall waiver rate for all impacted nationalities as of March 31, 2019 is just 5.1%, according to calculations from the State Department.3
  • Between December 8, 2017 and Oct. 31, 2018, there were 413 waivers to Iranian nationals resulting in 269 visa issuances (immigrant & nonimmigrant).4 According to the latest data, which adds in additional details through the first three months of 2019, 279 nonimmigrant visas and 161 immigrant visa had been issued to Iranian nationals, for a total of 440 waivers dating back to December 8, 2017.5
  • Contrast those paltry waiver numbers to the 28,390 immigrant Iranian visas refused, and the totals continue to be staggering. For every 64 Iranian nationals subject to the ban who have failed to secure a visa, only one is lucky enough to secure a waiver.
  • Many spouses continue to be kept apart as a result of Trump’s ban, a particularly cruel dynamic where each is forced to put their love and lives on hold. Through March 2019, there were only 19 approvals for spousal visas (CR1/IR1) issued to Iranian nationals contrasted to 644 denials.6 That is approximately a 2.9% approval rate for Iranian nationals married to a U.S. citizen or permanent resident. 
  • Cumulatively, the number of Iranian nationals not subject to the ban who were issued visas over the lifetime of PP 9645 was 2,792, with 125 issuances in February and March. The majority of these were students on F1 or F2 visas. While the approval rate is higher than those subject to the ban, there were still 3,032 Iranian nationals refused dating back to December 8, 2017.7

Muslim Ban Deters Visa Applicants

Without a doubt, a major goal of the Trump administration appears to be to deter individuals from Muslim-majority nations from applying for visas to the United States, which fits the “white nationalist” goals attributed to the President and his allies. Over the course of the ban, the data indicates that far fewer individuals from nations subject to the ban are now applying for visas.

  • In the first three months of 2018, an average of 4,311 Iranian nationals applied for nonimmigrant visas subject to the Muslim ban per month. However, in the first three months of 2019, the average fell to just 558 per month.8
  • The average application rate for B1/B2 visitor visas to the U.S. from countries impacted by the Muslim Ban have fallen over the last year:
    • 3,397 per month for the first six months of 2018;
    • 1,124 per month for the last six months of 2018;
    • 1,068 per month for the first three months of 2019.9

Iranians Still Most Impacted Group, Discriminatory Intent Not in Doubt

Iranians continue to be the most-heavily impacted group by the ban, accounting for 23,495 out of 36,783 nonimmigrant visa applicants subject to the ban and 10,441 out of 23,492 immigrant visa applicants dating back to December 8, 2017. Cumulatively, that is 33,936/69,275 visa applicants subject to the ban. To put it another way, nearly half of all those impacted by the ban are Iranian nationals.
While two non-Muslim countries were added to the list of targets of Presidential Proclamation 9645, Venezuela and North Korea, these appear to have been added solely to make the argument that it is not a “Muslim ban.” Zero Venezuelans have been subject to the proclamation, while only 79 North Koreans have attempted to apply for a visa, with 57 North Korean nationals being approved. Contrast the lack of impact of these non-Muslim majority nations to the tens of thousands subject to the ban from Muslim-majority nations. This remains a Muslim ban, as envisioned and in practice.

1 See Table II (a),

2  See Table II (c),

3 Administration calculation. See Page 3,

4  See State Department Correspondence from Feb. 22, Table 1F & 1G,

5 Table III (a) & Table III (b),

6  See Table II (c),

7 See Table II (b),

8 See Table I (b),

9 See Table I (a),

NIAC Calls for Treasury to Protect Iranian Americans from Bank Account Closures


For years, Iranian Americans have had their bank accounts shuttered as a direct result of their Iranian national origin or heritage. This is a form of discrimination that is profoundly damaging, throwing individuals into financial limbo while they wait to see if and when the bank will release their life savings. If you have faced discrimination from a bank account or had your account frozen, consider sharing your story so that we can build a documented case for why these discriminatory actions need to halt. 

Banks cite this as precautionary efforts to abide by U.S. sanctions that prohibit individuals from operating bank accounts in Iran. While not technically required by law, many of these banks judge that the risk of running afoul of sanctions outweighs the risk of engaging in discrimination against Iranian Americans. 

This is why NIAC is petitioning the Department of Treasury for a formal rule change to license Americans to operate bank accounts from Iran. We believe that we can change this rule and end these bank’s discriminatory actions against our community. 

A significant majority of complaints we have received come as a result of actions from Bank of America. Despite multiple efforts since 2014 by NIAC to engage Bank of America to fix their policies, Bank of America continues to engage in account closures of Iranian Americans.

That is why NIAC has again sent a letter to Bank of America clarifying that sanctions do not obligate them to close bank accounts of individuals ordinarily resident in the United States, while holding the option open to take legal action to protect the interests of Iranian Americans and bring an end to their discriminatory treatment at Bank of America.

Know that NIAC will not stop fighting for you, whether we are up against Trump’s Treasury, Bank of America, or anyone else harming Iranian Americans.

Download a PDF of the letter here

July 19, 2019

Re:      Request for Rulemaking—Iranian Transactions and Sanctions Regulations

            31 C.F.R. Parts 501 and 560

Dear Ms. Gacki:

The National Iranian American Council (“NIAC”)—the largest grassroots organization in the United States representing the interests of Iranian Americans—respectfully petitions the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) for the issuance of a rule providing license authorization for certain transactions prohibited pursuant to the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 C.F.R. Part 560. This request is made pursuant to 5 U.S.C. § 555(b) and 31 C.F.R. § 501.804(b), the latter of which is applicable to the ITSR by virtue of 31 C.F.R. § 560.101.

NIAC requests that OFAC promulgate a rule providing license authorization for U.S. persons to operate accounts of persons in Iran consistent with license authorizations that have been promulgated with respect to other U.S.-embargoed countries and jurisdictions, including, for instance, Syria and the Crimea region of Ukraine. We believe that such a license authorization will help resolve a problem that has become endemic to the Iranian-American community—namely, the difficulties Iranian Americans have had opening and maintaining bank accounts at U.S. financial institutions. 

Over the past few years, NIAC has heard from countless Iranian-American citizens and Iranian nationals in the United States who have faced continuous harassing inquiries from their banking institutions regarding their legal status and physical presence in the United States and have had their banking accounts shuttered and their life savings mailed back to them via the postal service. Such actions cause tremendous disruptions in the lives of U.S. citizens and Iranian nationals present in the United States, impacting their finances and very well-being, for no reason other than their Iranian heritage. Some individuals who have had their bank accounts shuttered have never even traveled to Iran. 

Banks have justified their behavior with near-unanimous resort to the requirements of U.S. law under the ITSR, including, for instance, the prohibition on the provision of financial services to Iran. While NIAC has repeatedly pointed out to U.S. financial institutions that the ITSR does not require them to deny financial services to Iranian Americans who are neither ordinarily resident nor physically present in Iran, this has not mitigated banks’ practices. U.S. banks have made a ‘risk-based decision’ based on U.S. sanctions under which servicing the accounts of Iranian Americans is not worth the risk inherent in falling afoul of the law.  

We believe that it is OFAC’s responsibility to remedy this situation. We are herein proposing that OFAC adopt a rule similar in scope of that found in the Syrian Sanctions Regulations, 31 C.F.R. Part 542, or the Ukraine-Related Sanctions Regulations, 31 C.F.R. Part 589. For instance, § 542.515 of the Syrian Sanctions Regulations authorizes the operation of accounts in a U.S. financial institution for an individual in Syria other than a blocked individual, provided that transactions processed through the account (1) are of a personal nature; (2) do not involve transfers directly or indirectly to Syria or for the benefit of individuals ordinarily resident in Syria unless otherwise authorized; and (3) are not otherwise prohibited by the Syrian Sanctions Regulations. We believe that such a general license authorization can mitigate the risk that U.S. banks believe to be associated with handling the accounts of Iranian Americans.  

We also believe that this proposed license authorization is an important starting point with which OFAC may consider a remedy to this ongoing problem. NIAC welcomes the opportunity to start a dialogue with OFAC regarding the best path forward to ensuring that Iranian Americans are not unduly harmed by the U.S.’s trade embargo with Iran. Being unable to procure basic banking services in the United States—a country in which Iranian Americans live (and for some, have only lived)—is understandably an issue of immediate concern, and we trust that OFAC will dedicate the necessary resources to working towards an imminent solution.   

As part of this request for rulemaking, NIAC also intends to provide supplementary materials to OFAC to underline the immediate nature of the problem and to provide additional proposals to resolve the issue. This may include testimony for members of the Iranian-American community who have been especially affected by the practices of U.S. banking institutions. NIAC is also prepared to respond to any inquiries or requests for clarification that OFAC may have regarding this matter.

We thank OFAC ahead of time for its consideration of this issue, and we look forward to being in touch with the agency regarding a mutually satisfactory path forward.  


Jamal Abdi

President, National Iranian American Council

How to Deescalate the Dangerous Iran Standoff

The “maximum pressure” campaign, initiated by the Trump Administration under the stewardship of John Bolton and Mike Pompeo, has brought the U.S. and Iran to the brink of war. While President Trump apparently reversed course on his decision to launch strikes following Iran’s downing of a U.S. surveillance drone, the danger of the U.S. and Iran triggering an all out regional war remains imminent.

President Trump asserts he wishes to avoid a military confrontation with Iran. Yet his approach of piling on economic sanctions regardless of Iran’s adherence to the JCPOA lacks coherence or clarity and is highly unlikely to achieve its stated goal of Iranian surrender. Instead, it has led to an increasingly provocative Iranian response. 

If the Trump Administration stays the course on maximum pressure, war is all but inevitable. With both sides now engaging in dangerous brinkmanship, the U.S. must take concrete steps immediately to avert another catastrophic American military intervention in the Middle East.   

Abandon “Maximum Pressure” in Favor of Diplomatic Compromise

A new U.S. strategy on Iran that includes credible economic incentives must be pursued in order to convince Iran of the merits of negotiations. The U.S. should credibly signal that it will suspend sanctions imposed after May 2018 to provide space for de-escalation and credible incentive for negotiation. 

  • The Trump administration instigated a new escalation of tensions with Iran and isolation from its allies in May 2018 when it decided to abandon Joint Comprehensive Plan of Action (JCPOA), commonly known as the Iran nuclear deal, and began its “maximum pressure” sanctions policy in violation of the multilateral accord.
  • After a year of upholding its nuclear commitments in spite of the U.S. withdrawal and “maximum pressure” campaign, Iran is now taking limited, reversible steps to halt compliance with aspects of the JCPOA. This includes a decision to surpass the JCPOA’s limit on its low-enriched uranium stockpile on June 27th.
  • Iranian leaders have stressed that they won’t negotiate under pressure and, as recent actions show, have begun increasing their own leverage. Meanwhile, President Trump has exhausted all U.S. pressure tools short of war.
  • Trump must signal to the Iranians that he is prepared to exchange pressure relief in return for pressure relief if he truly wants to get a deal and avoid a disastrous war. To jumpstart negotiations, the U.S. should signal that it will suspend sanctions imposed in violation of the JCPOA. Once both sides have returned to their obligations under the JCPOA, negotiations can begin on building on the deal. 

Reestablish Communication Channels with Iran

The U.S. and Iran must reestablish the permanent communication channel that existed under the previous administration. Doing so is important to guard against a spiraling tit for tat and enable a dedicated channel for deconfliction and deescalation.  

  • The Trump administration eliminated the bilateral communication channels that were established during the negotiation of the JCPOA. These channels, which existed at the level of secretary of state, helped contain tense episodes under the Obama administration—including securing the speedy release of U.S. sailors that had strayed into Iranian waters.
  • The U.S. should appoint a senior special envoy for engaging Iran to focus on confidence-building and decreasing mutual distrust and animosity. The envoy should have a proven track record of successful diplomatic engagement, a deep understanding of Iran, and the confidence of the parties that negotiated the JCPOA.
  • A direct U.S.-Iran channel for dialogue will reduce tensions in the overall relationship, enable a mutual understanding regarding each side’s intentions, and allow both sides to talk quickly should an incident occur–such as dispute over violating territorial boundaries or threats to Persian Gulf stability.
  • Additionally, establishing a permanent emergency deconfliction channel between the U.S. and Iranian militaries will also help prevent misunderstandings and avoid dangerous escalation of accidents.


UN Investigation into Drone Downing & Other Recent Incidents

The global and U.S. public skepticism to the administration’s claims regarding the drone downing and sabotage of oil tankers reflect the erosion of American credibility. Any response to an alleged violation of international law and norms should be rooted in those established rules rather than perpetuate lawlessness. 

  • Iran’s shooting down of the RQ-4 Global Hawk drone came one week after the sabotage of two oil tankers in the Gulf of Oman, which the Trump administration blamed on Iran. Trump’s National Security Advisor John Bolton also blamed Iran for an attack on four commercial ships in the same area one month ago.
  • The bar for the evidence for the allegations should be extraordinarily high. Secretary of State Mike Pompeo and Bolton both have track records of manipulating intelligence. 
  • Much of the international community, including U.S. allies in Europe, have viewed with suspicion U.S. claims that Iran was behind the oil tanker sabotage.
  • Rather than further isolate itself internationally, the Trump administration should allow for an impartial international investigation spearheaded by the UN into the tanker and drone incidents.


Congress Must Act Now to Prevent War

Congress must uphold its responsibility as a coequal branch of government and the only party with the authority to declare war by sending a clear message that Trump and Bolton cannot make an end-run around Congress to start a war with Iran.


  • Congress should pass legislation to block funds for the Trump administration to launch a war on Iran without Congressional approval. The Senate can do so by voting on and passing the Udall-Kaine amendment to the annual defense authorization bill. Stand alone legislation in each chamber, the Prevention of Unconstitutional War with Iran Act (S. 1039/H.R. 2354) – introduced by Sens. Udall, Paul and Durbin and Reps. Eshoo and Thompson – also exists to bar such funding.

Congress should pass legislation to repeal the 2001 AUMF that some in the Trump administration claim provides authorization to wage war on Iran. The Repeal of the Authorization for Use of Military Force bill (H.R. 1274) from Rep. Barbara Lee would repeal the 2001 AUMF from using it as legal justification to attack Iran 17 years after it was introduced. The AUMF Clarification Act (H.R. 2829) from Reps. Massie and Levin would clarify that neither the 2001 AUMF nor the 2002 AUMF can be twisted to greenlight a war with Iran.

The Best Way to Avert War with Iran? Fire John Bolton

Iran’s decision to retaliate against the U.S. withdrawal from the nuclear deal was inevitable, so long as its back was pushed against the wall. Iran exercised “strategic patience” for the past year, hoping that the other parties to the deal would stand up to Trump’s bullying and defy U.S. sanctions if Iran remained fully compliant with the deal. Now it has decided on a measured response: to halt compliance with aspects of the accord that recent U.S. sanctions themselves obstruct but leave the window for diplomacy open.

The backdrop to Iran’s decision is incredibly dangerous brinkmanship from senior Trump officials, particularly National Security Advisor John Bolton. Even as Iran has kept open the option of climbing down the escalation ladder, war could become a fait accompli if Trump keeps Bolton in the White House.

Importantly, Iranian officials have stressed their countermeasures with respect to the U.S. withdrawal from the nuclear deal, formally known as the Joint Comprehensive Plan of Action (JCPOA), are reversible and that Iran will not precipitate a conflict. Iranian President Rouhani was careful to state that Iran’s decision did not amount to a withdrawal from the deal, but was permitted by the agreement, in particular its clause that Iran will treat the reintroduction or reimposition of sanctions “as grounds to cease performing its commitments under this JCPOA in whole or in part.”

Read the full article on Newsweek.

At NIAC Congressional Panel, Experts Warn Trump is Taking Iran Diplomacy Off the Table

“Beyond just violating the deal and unilaterally abandoning it, I think what the Trump administration is trying to do is make it impossible or next to impossible for a future Democratic administration to re-enter [the Iran nuclear deal],” said Ned Price, a former CIA and White House official now with National Security Action who was speaking on Iran policy on Wednesday. The Trump administration’s designation of the Islamic Revolutionary Guard Corps (IRGC) as a Foreign Terrorist Organization (FTO) is the “clearest example” yet, he said, of the White House seeking to tie the hands of a successor administration.

Price was speaking at a briefing hosted by the National Iranian American Council (NIAC) on Capitol Hill addressing the one-year anniversary of President Trump’s unilateral withdrawal from the Joint Comprehensive Plan of Action (JCPOA). The panelists, which also included Jamal Abdi, President of NIAC; Suzanne DiMaggio, Senior Fellow at the Carnegie Endowment for International Peace; and Asieh Namdar, anchor and journalist for CGTN, argued that the next administration must return the U.S. to its JCPOA commitments.

On what the Trump administration is hoping to achieve, “it really depends on who you talk to in the administration and on what day,” DiMaggio said. “If the goal of U.S. policy is to get the Iranians back to the negotiating table, then the policy is a failure.” Similarly, if the goal is “the fulfillment of Secretary Pompeo’s 12 goals,” DiMaggio warned, “the Iranians read the 12 goals as regime change.” Rather than send signals that the U.S. is pursuing “flatout economic warfare” that could lead to the use of military force, DiMaggio advocated for more engagement. She warned that as the maximum pressure campaign goes on, “with each pressure point, we are making it impossible for the Iranians to even consider to come back to the table.”

Price added similar warnings, noting that “the fatal flaw in the administration’s policy is that coercive sanctions cannot have the intended effect when the ultimate goal is regime change in everything but name.” In contrast to the Obama administration, which had the backing of the international community in first enforcing sanctions and then negotiating a final nuclear agreement, he outlined how the Trump administration has pursued a unilateral approach. When asked how much of Trump’s latest policies since leaving the JCPOA, including designating the IRGC as a FTO and the Muslim Ban, can be undone, Price was optimistic. “I think if Donald Trump has taught us one thing, it is that you can do a lot, especially in the realm of foreign policy, as long as you explain yourself.”

Abdi, meanwhile, warned that Trump’s policies are undermining the constituency inside of Iran for negotiations. “I think what we are seeing inside of Iran is, at least among the political class, a real consolidation around a more hardline position,” Abdi said. He said the Trump administration’s maximum pressure campaign is intended to push Iran to leave the JCPOA. In such a case, Iran may lose the international community’s support and the moral high ground.

Noting that National Security Advisor John Bolton has been a long-time proponent of military force against Iran, Abdi warned “If Iran can be goaded to leave the nuclear deal, then I think you will see some of the things that John Bolton had been advocating for potentially to come to fruition.” The Trump administration’s latest escalations are alarming because they have begun to “institutionalize that diplomacy with Iran is off the table.” Abdi argued that the U.S. must uphold its international commitments by returning to compliance with the nuclear deal. “When Pompeo talks about Iran behaving as a normal country, well, the United States is not operating as a normal country, and typically the United States derived its power from the international order and the notion that diplomacy works.” The Trump administration’s current strategy is such a departure from those norms, he said, that “regime change” may have already occurred in the U.S.

The panelists unanimously agreed that the current U.S. strategy toward Iran is not only self defeating but dangerous, including by signaling to other nations that the U.S. is unreliable. Moreover, while Abdi emphasized that Iranians clearly recognize that their government is behind a lot of the suffering inside Iran, he warned that the U.S. has given “the Islamic Republic a pretty compelling narrative for how it is the U.S. to blame for economic challenges in Iran.”

Returning to the negotiating table with Iran would help restore faith in U.S. leadership, but with the current administration, the future remains uncertain, and there may eventually not be a table to return to. Abdi warned that there is work to be done to ensure that “regime change” in the United States is not permanent, “and that the United States returns to being a responsible actor that the U.S. derives so much influence and power from for so many years.”

Sanctioning Iran’s Climate


Emblazoned across the jerseys of Iran’s 2014 World Cup soccer team is a symbol of national pride: the endangered Asiatic cheetah. Iranian conservationists have worked for years to reverse the cat’s dwindling population, and sadly their critical efforts are hampered by forces both in and outside of Iran. The world celebrated Earth Day on April 22, 2019 with its theme Protect Our Species; a reminder of the devastating impacts of climate change for species unable to adapt.

Iran’s climate change struggles are nothing new. Eager to develop infrastructure and technology as a way of catalyzing immediate economic benefits, the government paid little attention to long-term environmental impacts. Domestically, the Iranian government is failing to tackle this challenge and instead persecutes environmental conservations, which serves to further damage the environmental movement. On an international scale, additional US sanctions also continue to hamper Iranian efforts to combat current and future effects of climate change.

Iran needs a portfolio of solutions to approach climate change—one grounded in a re-evaluation of its resource management practices, and bolstered by international assistance. Until both domestic and international policies are overhauled, the fate of Iran’s changing climate and its people, looks grim.

Read more on MENASource from the Atlantic Council.

Growing U.S. Pressure is Emboldening Iranian Hardliners

The ingredients for a war with Iran are falling into place. The Trump administration’s termination of oil waivers for importers of Iranian oil and designation of the Islamic Revolutionary Guard Corps (IRGC), a branch of Iran’s state-run military, as a foreign terrorist organization (FTO) are dangerous acts of escalation. Surprisingly, the Iranian reaction to the IRGC designation has been restrained as Tehran’s top decisionmakers remain committed to waiting out the Trump administration and not being baited into conflict. However, their approach is under immense domestic challenge—and could soon become unsustainable.

Iranian president Hassan Rouhani and his reformist and moderate allies continue to prefer to minimize foreign tensions through diplomatic engagement. Despite President Donald Trump’s abrogation of the Joint Comprehensive Plan of Action (JCPOA) nuclear deal and the reimposition of hard-hitting unilateral sanctions, Rouhani has won elite consensus on refraining from retaliatory actions that could spur a multilateral front against Iran or risk conflict.

Rouhani has pushed for a policy that is best described as strategic patience. It has been marked by continuing to adhere to the JCPOA, reticence to escalate regional tensions, and preserving ties with Europe in the face of the Trump administration’s “maximum pressure” campaign. While Rouhani and other senior officials have ruled out talks with the Trump administration, they have left the door open to engaging a future White House that renters the JCPOA.

“[The U.S.] has burned the bridge,” Rouhani declared last August, “Now, the U.S. is standing on the other side … If it is honest, it should fix that bridge again.” In February, Rouhani reiterated that Iran would be willing to engage the United States “if America reverses its course.”

Read more on the National Interest.

NIAC Update on Flash Flooding in Iran

According to the latest report from the International Federation of Red Cross and Red Crescent Societies (IFRC), over 2 million people in Iran require humanitarian aid. Roughly 10 million Iranians in over 2,000 cities and villages in 31 provinces were impacted by the floods and heavy rains. IFRC further stated that based on the latest information, 78 people were killed, 1136 injured, and over half a million displaced as a result of the floods.

NIAC continues to support relief efforts for those impacted by the terrible flooding. We are urging the Treasury Department, State Department, and members of Congress to press for humanitarian exemptions so that U.S. sanctions and the U.S. trade embargo on Iran does not impede relief efforts. We also are supporting key organizations— which have proof of OFAC licensing— to encourage donations to relief efforts, including Moms Against Poverty, Children of Persia, and Child Foundation. Currently, these fundraisers are the best way for members of the Iranian diaspora to make a contribution to help those who need humanitarian aid in Iran.

Memo: The IRGC FTO Designation & Iran’s Shifting Domestic Landscape

Since President Trump’s abrogation last May of the Iran nuclear deal, or Joint Comprehensive Plan of Action (JCPOA), the trajectory of Iranian society and politics has shifted in significant ways.

Most consequentially, renewed U.S. pressure has debilitated moderate President Rouhani, who invested much of his political capital pushing for diplomatic engagement with the U.S. and promising an economic dividend to the Iranian people with the deal. Iran’s rivalrous political factions have since united in ruling out new negotiations with the U.S. but have sought to use the country’s deteriorating economic situation to advance their contrasting agendas.

The Trump administration’s designation of the Islamic Revolutionary Guard Corps (IRGC) as a foreign terrorist organization (FTO) has also spurred increased elite unity behind the Guards, including from reformist and moderate factions long publicly critical of their interference in Iranian politics and the economy.

In the past year, sporadic demonstrations and protests have also continued by various Iranian labor groups, civil society groups, and other Iranian activists expressing specific demands. Importantly, despite the increase in number of protests since last year, there exists no cohesive revolutionary movement or an organized, broad-based opposition to the ruling system. The protests that have occurred have been met with a mixture of repression—with many activists and prominent dissidents handed heavy prison sentences—and governmental concessions. Importantly, President Rouhani’s conservative rivals, who have outsized influence over state media outlets, have sought to exacerbate discontent and catalyze protests as well.

The National Iranian American Council (NIAC) produces a weekly digest, “Iran Unfiltered,” that tracks developments in Iranian society and politics based on Persian sources. The following is a summary of important developments in Iran drawing on recent issues of the digest.

Renewed U.S. Pressure Has Debilitated Iranian Moderates

  • The Trump administration’s abrogation of the JCPOA and reimposition of U.S. sanctions has discredited President Rouhani and his moderate and reformist allies domestically and validated hardline narratives regarding not trusting the United States. Hardline forces, including the Islamic Revolutionary Guards Corps (IRGC), have been significantly empowered.
  • The JCPOA experience has spurred a rightward shift in Iranian politics, including among many longtime advocates of U.S.-Iran engagement, such as Ali Akbar Salehi, who convinced Supreme Leader Ayatollah Khamenei of the need for bilateral U.S.-Iran talks in 2013 and led technical-level negotiations with former Energy Secretary Ernest Moniz.
  • Salehi, the current head of the Atomic Energy Organization of Iran (AEOI), recently stated: “It took awhile for many to believe that America is our enemy. But now everyone believes that America is our enemy … From the beginning the Leader [Ayatollah Khamenei] stressed that this government and American officials could not be trusted. Now this can be seen clearly and this itself is a huge achievement.”

IRGC Designation has Mitigated Internal Divisions

  • Foreign Minister Zarif’s short-lived recent resignation was rooted in his stance that the foreign ministry’s credibility and authority was being increasingly undermined by other institutions, including the IRGC.
  • Zarif’s resignation, a recent trip to Iraq by President Rouhani, and recent devastating flooding in large parts of the country brought differences between the IRGC and the Rouhani administration to the fore.
  • However, the Trump administration’s designation of the IRGC as an FTO has resulted in strong displays of support for the Guards among Rouhani officials and moderate and reformist public figures and members of parliament.
  • Mohammad-Ali Abtahi, a former reformist vice-president who was arrested by the IRGC after the contested 2009 presidential election, said that “all people are guards now, even Iranians who have been upset with the guards’ policies.”
  • Meanwhile, prominent reformist dissident Mostafa Tajzadeh, who was imprisoned for 7 years after 2009, has stated: “The intervention of the Guards in the economy and domestic and foreign politics is against the law and hurts the country. However, I strongly condemn labelling them as terrorists by Trump. His aim is not confronting terrorism or defending democracy or peace. Instead, Trump seeks to increase pressure on the Iranian people to destabilize Iran and increase tensions in the region.”

Rouhani Has Kept Door Open to Negotiations if the U.S. Returns to the JCPOA

  • While Rouhani has adopted more intransigent rhetoric and has blamed President Trump for eliminating diplomatic channels between the two countries, he has left open the possibility of negotiations if the U.S. returns to its commitments under the JCPOA.
  • “[The U.S.] has burned the bridge,” Rouhani declared last August, “Now, the U.S. is standing on the other side … If it is honest, it should fix that bridge again.” In February, Rouhani reiterated that Iran would be willing to engage the U.S. “if America reverses its course.”
  • However, Supreme Leader Ayatollah Khamenei has proclaimed that negotiations with the U.S. would be to Iran’s detriment unless Iran reaches a point where “U.S. pressures and blackmail don’t affect us.”

Hardliners in Stronger Position to Influence Supreme Leader Succession

  • Rouhani’s empowered hardline critics scapegoat him for the country’s increasingly dire economic circumstances, with an August 2018 letter from the Assembly of Experts—a constitutional body charged with supervising and electing the Supreme Leader—chastising “weak economic management and non-belief in the ‘resistance economy’ and infiltration by the enemy and corruption.”
  • Notably, the Assembly of Experts is chaired by hardline cleric Ahmad Jannati, who recently rebukedPresident Rouhani for not following a July 2016 proclamation by Supreme Leader Ayatollah Khamenei that Iran would “set the JCPOA on fire” if the U.S. violated the accord.
  • The Assembly of Experts also recently elected as its deputy Ebrahim Raisi, the conservative 2017 presidential candidate who was defeated by Rouhani but was appointed head of Iran’s judiciary earlier this month.
  • The increasingly powerful Raisi is considered a top contender to succeed the aged Khamenei and has a long track record in Iran’s judiciary, including a major role in mass executions that took place at the end of the Iran-Iraq War in 1988.

Prominent Activists and Pro-Democracy Groups Rebuke U.S. Intervention

  • Prominent Iranian political prisoners and opposition groups have repeatedly underscored that U.S. pressure policies hurt their cause.
  • Political prisoner Farhad Meysami, who was sentenced to six years in prison in January for his activism against Iran’s compulsory hijab law, wrote a letter last year disavowing support from the Trump administration and criticizing its withdrawal from the JCPOA.
  • Meysami lambasted the administration’s “inhuman sanctions,” which he said “have plunged millions of my fellow countrymen into poverty.”
  • The Freedom Movement, one of Iran’s oldest pro-democracy groups, wrote a letter last month censuring “unilateral” U.S. pressure policies for empowering “domestic hardliners [in Iran] and warmongers abroad.”
  • The letter added: “It is the Iranian people who suffer the most harm and economic hardship from sanctions. These sanctions have weakened the middle class and the downtrodden and disrupt Iran’s democracy-seeking trend.”
  • Recent widespread flooding across Iran–which killed over 70 and displaced tens of thousands–spurred accusations by Iranian officials that U.S. sanctions are obstructing foreign aid for relief efforts. The Red Crescent, a branch of the International Red Cross, has affirmed that sanctions are impeding aid, saying in a statement: “No foreign cash help has been given to the Iranian Crescent society. With attention to the inhumane American sanctions, there is no way to send this cash assistance.”

Warren Proposes Return to JCPOA in Senate Hearing

“If Iran maintains itself in compliance, then I believe the President should reverse his reckless decision to withdraw from the nuclear deal and reimpose sanctions because the deal makes America safer and the world safer,” declared Sen. Elizabeth Warren (D-MA) at a Senate Armed Services Committee nomination hearing on Tuesday morning.

The comments from Warren, widely viewed as a top contender for the Democratic presidential nomination in 2020, follow her articulation of a “progressive foreign policy” in a speech at American University last week. In a report released earlier this month, NIAC called on legislators and 2020 Presidential contenders to commit their support to returning to the Joint Comprehensive Plan of Action (JCPOA) and to take additional steps to rein in Trump’s reckless Iran policy.

Sen. Warren questioned Lt. Gen. Kenneth McKenzie, the nominee for commander of U.S. Central Command, if he agreed with the Director of National Intelligence’s 2018 Worldwide Threat Assessment that the JCPOA has “extended the amount of time Iran would need to produce fissile material for a weapon from a few months to about one year and has enhanced the transparency of Iran’s nuclear activities.” McKenzie responded affirmatively, prompting Sen. Warren to ask whether the Iranian government had “reduced its destabilizing” activities as a result of the Trump administration’s abrogation of the JCPOA, a key selling point for Trump’s decision. McKenzie replied that “Iranian destabilizing activities across the region were active before, during, and after the nuclear deal.”

In response to a question from Sen. Ted Cruz (R-TX) about whether Iran’s government is on the brink of collapse, McKenzie stated, “I haven’t seen anything that I would characterize as spreading or essentially threatening the fundamental nature of the Iranian regime.” In response to a question from Cruz on Iran’s missile program, McKenzie responded that Iran had “chosen to substitute ballistic missiles, both short, medium and long-range for their paucity of aviation assets.”

With respect to regional issues, Sen. Tim Kaine questioned whether the Trump administration was authorized to continue operations in Syria, highlighting comments by Secretary of State Mike Pompeo that “part of the mission in Syria is to provide a check against Iran.” McKenzie said in response: “Senator that may possibly be a derived effect of our presence on the ground, but that is not a mission that we are undertaking.”

On Yemen, Sen. Warren asked McKenzie whether the U.S. provides intelligence support and military advice to the Saudi-led coalition, including refueling aircraft that “bomb these targets in Yemen.” McKenzie stated that Warren was correct, leading her to call for a reassessment of the U.S.-Saudi relationship: “I think it’s time to reevaluate our relationship with Saudi Arabia in light of its actions not only in Yemen, but with the assassination of journalist Jamal Khashoggi.  And we need to ask ourselves if the benefits of this relationship with Saudi Arabia is worth the costs, if this kind of behavior continues.”

Mohammed bin Salman Is the Next Saddam Hussein

“Saudi Crown Prince Mohammed bin Salman is reportedly shocked over the backlash to his government’s killing of Washington Post columnist Jamal Khashoggi. In a recent phone call with U.S. President Donald Trump’s son-in-law and advisor Jared Kushner, according to the Wall Street Journal, his confusion over official Washington’s furor “turned into rage,” as he spoke of feeling “betrayed by the West” and threatened to “look elsewhere” for foreign partners.

Saudi Arabia’s indignation at the United States would not be the first time an autocratic U.S. ally in the Middle East has assumed it could act with virtual impunity due to its alignment with Washington in countering Iran. Indeed, the Saudi prince’s meteoric rise to power bears striking similarities to that of a past U.S. ally-turned-nemesis whose brutality was initially overlooked by his Washington patrons: former Iraqi dictator Saddam Hussein…”

Read more on Foreign Policy.

The Ahvaz terror attack in Iran may drag the US into a larger war

In this photo provided by Fars News Agency, a woman takes her children to shelter as an army member tries to help them, during a shooting at a military parade marking the 38th anniversary of Iraq’s 1980 invasion of Iran, in the southwestern city of Ahvaz, Iran, Saturday, Sept. 22, 2018. Gunmen attacked the military parade, killing several and wounding others, state media said. (Fatemeh Rahimavian/Fars News Agency via AP)

Iran has been hit by yet another terrorist attack. At least 29 people were killed in the southwestern city of Ahvaz when gunmen opened fire on a crowd watching a military parade on Iran’s equivalent of Memorial Day. But unlike previous terror attacks, this one may spark a much larger regional conflagration – involving not just regional rivals Saudi Arabia and Iran, but also the United States. In fact, it may have been designed to trigger just that.

The terrorist attack, which was first claimed by an Arab separatist group with alleged connections to Saudi Arabia, the Ahvaz National Resistance, did not occur in a vacuum. Iran’s regional rivals, particularly Saudi Arabia and the UAE, have increasingly taken their decades-long behind-the-scenes pressure on the US to bomb Iran into the open.

What used to be said in private is now increasingly declared in public. Moreover, these monarchies are no longer limiting themselves to pushing the US to take military action, but are announcing their own readiness to attack Iran.

Saudi and UAE threats towards Iran

Only a year ago, Saudi Crown Prince Mohammed bin Salman explained in an interview that Saudi Arabia would take the fight to “inside Iran“.

“We won’t wait for the battle to be in Saudi Arabia,” he said. “Instead, we will work so that the battle is for them in Iran.” His statement was widely interpreted as a sign that Riyadh would dramatically escalate tensions with Iran and intensify its support for various armed groups opposing the government in Tehran.

Abdulkhaleq Abdulla, an adviser to the Abu Dhabi government, justified the Ahvaz attack on Twitter, arguing that it wasn’t a terrorist attack and that “moving the battle to the Iranian side is a declared option“. Attacks of this kind, he ominously warned, “will increase during the next phase”.

If the terrorist attack in Ahvaz was part of a larger Saudi and UAE escalation in Iran, their goal is likely to goad Iran to retaliate and then use Tehran’s reaction to spark a larger war and force the US to enter since Riyadh and Abu Dhabi likely cannot take on Iran militarily alone (indeed, after spending roughly $6bn a month, they have failed to defeat the Houthi guerillas in Yemen).

If so, the terrorist attack is as much about trapping Iran into war as it is to trap the US into a war of choice. As former secretary of defense Bob Gates said in 2010, the Saudis “want to fight the Iranians to the last American“.

Iran hawks inside Trump’s administration

But the Trump administration may not be innocent bystanders to such a scheme. Trump’s own actions and the close coordination we have seen between his administration, Saudi Arabia, UAE and Israel on Iran raises the prospects of a different explanation: one in which the US itself is actively pushing its allies and being pushed by its allies towards war with Iran.

The Ahvaz attack comes only one day after Secretary of State Mike Pompeo issued a strong threat to Iran, declaring it would be held “accountable” if there were any more attacks on US consulates in Iraq.

The US consulate in Basra, Iraq, has come under attack in the past week allegedly by Iraqi Shia forces close to Iran. The Trump administration has not presented any evidence that Iran had any involvement in that attack, but has declared that it will attack Iran if any more such attacks take place.

The Iranian consulate in Basra, in turn, has been attacked several times during this same period, with Tehran laying the blame at the feet of the US (also without clear evidence).

‏The difference being that the US has issued a stern threat declaring it will take action against Iran for events neither Washington nor Tehran can provide any evidence for.

This pattern of bellicose statements and actions fits well with a memo National Security Adviser John Bolton – who has a history of manipulating intelligence in order to drag the US into war – wrote in August 2017, before he joined the Trump team.

The memo details how the US should coordinate with Israel and Saudi Arabia to build support – domestically and internationally – for a withdrawal from the Iran nuclear deal and a much more aggressive policy on Iran.

It specifically mentions “providing assistance” to Khuzestan Arabs – the minority group in Iran that the Ahvazi attack perpetrators claim to represent. Bolton also argues that the Trump administration should demand payment from Iran for its non-existing role in the 9/11 September attacks while disingenuously offering Iran dialogue amid a policy of confrontation.

The Trump administration’s Iran policy is following the Bolton memo almost point by point. The plea to provide assistance to Khuzestani separatists is particularly damning. This raises legitimate suspicions that if the terror attack has Saudi and UAE fingerprints on it, it may not be so much an attempt by them to drag the US into war as Trump operating in the driver’s seat.

For Saudi Arabia and the UAE, this makes strategic sense. Their ability to compete with the much larger and more cohesive Iranian state in the long run is highly questionable. If they can trap the US into doubling down on its military presence in the Middle East, however, then they can use American power to balance Iran.

For America, which is already overextended in the Middle East at the expense of its strategic interest in Asia as well as at home, this makes little to no sense.

This post originally appeared on Middle East Eye.