NIAC Statement on Trump Administration’s Latest Sanctions on Iran

FOR IMMEDIATE RELEASE: Friday, September 20, 2019
CONTACT: Mana Mostatabi | 202.386.6325 x103 | mmostatabi@niacouncil.org

In response to the Trump administration’s announcement of new sanctions on Iran for its alleged role in attacks on Saudi oil facilities, Ryan Costello, Policy Director of the National Iranian American Council (NIAC), released the following statement:

“President Trump’s recent sanctions designations appear duplicative at first glance, but in fact will likely eviscerate humanitarian trade with Iran that had already been sharply reduced following the U.S. exit from the nuclear deal. The Central Bank of Iran (CBI) had continued to play a major role in existing humanitarian trade with Iran, despite its prior designation, due to preexisting exemptions set down by Congress and the prior administration. 

“The new terrorism authorities (EO 13224) that the Central Bank of Iran has been designated under contains no similar exemption, nor has the Trump administration updated its guidance to add a new exemption. In fact, the Treasury guidance hints at this potential complication by noting that the U.S. ‘will continue to consider requests related to humanitarian trade with Iran as appropriate.’ Such actions were previously exempted by general license.

“The end result of this shift in policy – whether out of criminal negligence or willful vindictiveness – is likely to be pain for the Iranian people in the form of more medicine shortages for drugs produced in the West and sharply rising prices for food. 

“Congress and prior administrations understood the importance, and basic humanity, of exempting humanitarian goods from sanctions. The Trump administration has never updated its guidance related to humanitarian trade, creating a policy of deliberate ambiguity, and now appears to have deliberately removed one of the pillars allowing further humanitarian trade with the Iranian people. If the Trump administration does not immediately reverse its decision, Congress needs to legislate an exemption with haste. 

“After the crisis triggered by attacks on Saudi oil facilities, the President should be doing everything he can to undo his senseless actions that once again brought the U.S. and Iran to the brink of war. Instead, he is building a sanctions wall designed to lock both the Trump administration and a potential future administration into a playbook for war. There is no bigger loser of this policy than the Iranian people, who are crushed between their own government’s repression and inhumane sanctions that will now deliberately target humanitarian trade. This latest move – which could be illegal under international law – should be a wake-up call to all in the United States who claim support for the Iranian people. You can’t support maximum pressure and the Iranian people at the same time. It’s imperative that this dangerous step be reversed before the full impact is felt.”

NIAC Statement on Iran’s Intent to Reduce Compliance with Nuclear Deal

FOR IMMEDIATE RELEASE: Wednesday, September 4, 2019 
CONTACT: Mana Mostatabi | 202.386.6325 x103 | mmostatabi@niacouncil.org

WASHINGTON DC – Today, Iranian President Hassan Rouhani warned that Iran would reduce compliance with the Iran nuclear deal, known formally as the Joint Comprehensive Plan of Action (JCPOA), this Friday. This is the third time Iran has taken such steps since the Trump Administration abrogated the agreement last year. The latest declaration comes ahead of the deadline set by Iran for Europe to uphold sanctions lifting obligations in exchange for Iran’s continued compliance with the nuclear accord. 

Simultaneously, French President Emmanuel Macron is leading an effort to offer Iran a bailout package in exchange for returning to full compliance with the deal. The proposal includes a $15 billion credit line to offset oil revenue lost under U.S. sanctions, but its payout requires a commitment from the U.S. not to block the funds.

In response to these latest developments, NIAC President Jamal Abdi issued the following statement: 

“Iran’s announcement is a predictable consequence of the Trump administration seemingly closing off every opportunity to resolve the Iran standoff diplomatically. A U.S. failure to pivot from maximum pressure to the diplomatic opportunities initiated by France and other American allies ensures a continued cycle of escalation that could quickly spin out of control.

“Iran’s decision to stop abiding by further JCPOA restrictions risks playing into the escalation trap set by John Bolton and other diplomatic spoilers. While France and other mediators have sought to mitigate U.S.-Iran tensions and safeguard the JCPOA, Bolton and other administration hawks are furiously attempting to fuel the flames of hostility.

“Importantly, Iran’s actions on the JCPOA are reversible and it has indicated its readiness to return to full compliance with the deal if parties to the accord provide Iran with sanctions relief. The current French proposal to establish a $15 billion credit line for Iran stands to achieve this, but only if President Trump allows it to materialize. 

“The ball is in the President’s court. He has the option to de-escalate the dangerous tensions with Iran and move the two countries off the path to war. But only if he shifts away from counterproductive “maximum pressure” and towards practical actions that build the confidence necessary for successful diplomacy.”

NIAC Congratulates Sharif University Students on 2019 AIAA Win

FOR IMMEDIATE RELEASE: Thursday, August 29, 2019 
CONTACT: Mana Mostatabi | 202.386.6325 x103 | mmostatabi@niacouncil.org

NIAC President Jamal Abdi issued the following statement regarding travel and sanctions restrictions placed on Iranian students from Sharif University of Technology, who won the engine design competition at the 2019 American Institute of Aeronautics and Astronautics’ (AIAA) Propulsion and Energy Forum:

“We would like to commend the group of Sharif students who defied the odds to win an engine design competition at a prestigious AIAA forum, as well as to extend our apologies on behalf of our elected government for the ridiculous and offensive hurdles placed in these students’ way.

“This group of engineering students from Sharif University entered the AIAA competition only to have their entry into the U.S. denied due to President Trump’s discriminatory Muslim ban that denies visas for all Iranians with few, apparently arbitrary, exceptions. Undeterred, the group participated by video conference and managed to win the competition only to learn that they could not receive the cash prize for their program due to U.S. sanctions.

“These students are among Iran’s best and brightest, and U.S. policies should seek to empower them and allow humanity to benefit from their ingenuity. However, instead of celebrating their successes, these extraordinary students have been met with hurdles and indignities. This is a microcosm of the self-defeating and nonsensical treatment of Iranians by U.S. government policies. The Iranian people already have to deal with their own government’s deplorable human rights record, corruption, and other failings. Unfortunately, our American government often chooses to makes the situation worse. 

“NIAC reiterates its condemnation of the Trump administration’s unjust and xenophobic Muslim ban and the broad sanctions policies that are punishing ordinary Iranians. NIAC calls for an end to these destructive measures and for a U.S. approach towards Iran that prioritizes peace and engagement. We will continue our work to press for change and remain determined to remove barriers and instead build bridges between the American and Iranian people.”

NIAC Statement on the Imposition of U.S. Sanctions on Iranian Foreign Minister Zarif

FOR IMMEDIATE RELEASE: Wednesday, July 31, 2019 
CONTACT: Mana Mostatabi | 202.386.6325 x103 | mmostatabi@niacouncil.org 

WASHINGTON DC – Moments ago, the U.S. Department of the Treasury announced that it was imposing sanctions on Iranian Foreign Minister Mohammad Javad Zarif. The sanctions were imposed on Zarif, according to the Treasury, because he has acted on behalf of Iran’s Supreme Leader. The move comes after reports earlier this month that Trump had instructed U.S. Secretary of the Treasury Steven Mnuchin to impose sanctions on the Iranian diplomat, before reversing his decision.

In response, NIAC President Jamal Abdi said:

“Again, President Trump has chosen an action to push Iran away from the negotiating table, isolate America on the world stage, and take diplomatic options off the table. If Trump was serious about negotiating with Iran, he would appoint a credible envoy and direct them to negotiate with Iranian diplomats rather than subjecting them to a ridiculous sanctions designation. Instead, Trump is ensuring that there will be no serious negotiations with Iran during his tenure. Once again, without a clear line to Zarif or any other Iranian officials to de-escalate tensions, the next crisis that the U.S. or Iran precipitates will once again risk war.

“Regardless of any personal animosities Trump’s team felt toward Zarif, dealing with him has served U.S. interests on several occasions. Zarif assisted the U.S. in forming a government in Afghanistan after the 2001 invasion, credibly hammered out a nuclear accord with former Secretary of State John Kerry, and was pivotal in both freeing American sailors who strayed into Iranian waters and the prisoner swap that freed unjustly detained Americans in 2016. All the while, Zarif represented Iran’s interests and was able to convince the Supreme Leader and other Iranian officials to buy into the more moderate approach represented by the Rouhani administration. His sanctioning now by Trump plays into the hands of Iranian hardliners and forces on all sides that want to entrench U.S.-Iran hostilities.

“It is without a doubt that Zarif has deflected from the regime’s human rights abuses and other Iranian actions to escalate around the region. Yet, if that were a credible standard for imposing sanctions, the U.S. should also designate top diplomats in Saudi Arabia, Israel, the United Arab Emirates, Egypt, and countless other nations around the world.  

“The timing of this move, coming after Sen. Rand Paul reportedly was dispatched to meet with Zarif on behalf of Trump, underscores that hawks like John Bolton are trying to box in the administration and eliminate diplomatic off-ramps. Trump can’t simultaneously hold out the option of credible negotiations while implementing the path to war plotted by John Bolton. Only yesterday did we publish a letter in conjunction with prominent foreign policy practitioners outlining pragmatic steps that the U.S. and Iran can take to deescalate this crisis. The time is running out for Trump to shift tracks, lest he be locked into the inevitable result of his failing maximum pressure strategy leading to a disastrous war.”

Coalition of Foreign Policy Experts Outline 8 Recommendations to Deescalate Tensions with Iran

FOR IMMEDIATE RELEASE: Tuesday, July 30, 2019
CONTACT: Mana Mostatabi | 202.386.6325 x103 | mmostatabi@niacouncil.org

WASHINGTON DC – Today, an expert group of foreign policy practitioners published a letter underscoring the dangerous new phase that has put the U.S and Iran on the path toward war. The signatories include prominent academics, such as John Mearsheimer, Stephen Walt, and Andrew Bacevich; foreign policy analyst Rula Jebreal; former Member of Congress John F. Tierney;  former ambassadors and diplomats, such as Thomas Pickering, François Nicoullaud, and Peter Jenkins; national security expert Edward Price; and Iran experts such as Jamal Abdi, Dina Esfandiary, and Farideh Farhi.

The letter outlines a series of eight bold but practical recommendations to the U.S., Iran, and Europe that could widen the path to diplomacy that has narrowed considerably since the U.S. initiated a tit-for-tat ratcheting up of tensions with Iran. 

The signers urge the U.S. to suspend recent sanctions to provide space for deescalation and Iran to return to full compliance with its obligations under the nuclear deal. After these initial trust-building steps, the signers recommend further negotiations aimed at a prisoner swap and an Incidents at Sea agreement to calm tensions in the Persian Gulf. 

The full text of the letter and signatories is below and can be found on the web here.

Expert Letter on Deescalating with Iran

July 30, 2019

As foreign-policy practitioners with decades of collective experience in national security and diplomacy, we write to warn that U.S.-Iran tensions have entered a dangerous new phase that has put us on the brink of a disastrous and avoidable war. The administration’s decision to violate the Iran nuclear agreement in pursuit of a so-called maximum pressure strategy is damaging the accord and U.S. interests in ways that could be difficult to reverse. There remains a narrow path for the U.S. and Iran to avoid military conflict and resolve ongoing disputes through negotiations. Doing so, however, will require bold action and constructive steps from all sides, as outlined below.

The U.S. Should Suspend Recent Sanctions to Provide Space for Diplomacy

  • The U.S. should suspend sanctions imposed after its withdrawal from the nuclear accord with Iran in May 2018 to provide space for de-escalation and assurance that it is serious about pursuing and adhering to a negotiated solution.

Iran Should Return to Full Compliance with the Nuclear Accord

  • Iran’s recent decision to cease adherence with aspects of the July 2015 nuclear deal in response to U.S. sanctions feeds into a counterproductive escalatory cycle and could lead to an irreversible collapse of the agreement. Iran should welcome the suspension of U.S. sanctions by returning to full compliance with the nuclear deal.

The U.S. and Iran Should Pursue a Prisoner Swap

  • Iran has unjustly imprisoned at least five American citizens and dual nationals. According to publicized reports, at least a dozen Iranians are in custody in the U.S. on sanctions violation charges. Iran has publicly and privately offered to arrange a swap of American and Iranian prisoners held in each country’s jails. The Trump administration should pursue this overture and view it as the low-hanging fruit for negotiations that can build confidence for broader diplomacy.

Europe Must Take More Serious Steps to Address Challenges in Meeting Its Sanctions Relief Obligations

  • Due to U.S. extraterritorial sanctions, Europe has not been able to satisfy its obligations under the nuclear deal to ensure legitimate trade with Iran. To its credit, Europe’s development of a special financial mechanism to facilitate legitimate trade with Iran, known as INSTEX, is a constructive first step forward. Europe must now urgently take all necessary actions to ensure INSTEX is utilized to enable the trade and economic benefits promised under the nuclear deal.

The U.S. and Iran Must Reestablish Communication Channels 

  • The U.S. and Iran should reestablish a permanent and direct communication channel with Iran to de-escalate crises, such as the downing of the U.S. drone and the oil tanker attacks in the Gulf of Oman. Absent a dedicated channel for deconfliction and deescalation, as existed under the previous administration, the chances of disaster remain far too high. 

The U.S. Should Appoint a Credible and Empowered Iran Envoy

  • To signal U.S. seriousness about negotiations and to facilitate the process, a new Iran envoy with the ear of the President and experience in diplomatically engaging Iran is needed. As long as John Bolton and Mike Pompeo are viewed as leading the administration’s Iran policy, concerns that the U.S. seeks regime change and military action – and is not serious about a negotiated solution – will undermine any hopes for talks.

Pursue an Agreement to Avoid Confrontations in the Persian Gulf

  • The U.S. and Iran came dangerously close to war following several incidents in the Persian Gulf and unverified accusations leveled by both sides. To avoid similar confrontations in the future, the two sides should negotiate an “incidents at sea” agreement to avoid collisions between their naval and air forces operating in close proximity.

U.S. Congress Should Pass Legislation to Prevent War

  • Congress was not consulted when President Trump came just a few minutes away from attacking Iran, which could have dragged the U.S. into a major regional conflict far more damaging than the Iraq war. Congress must assert its war-powers authority and uphold its constitutional duty as a coequal branch of government by passing legislation to ensure the administration cannot start an illegal and disastrous war with Iran.

Signatories: 

Jamal Abdi, President, National Iranian Amerian Council

Arshin Adib-Moghaddam, Professor in Global Thought and Comparative Philosophies at SOAS, University of London and Fellow of Hughes Hall, University of Cambridge

Sanam Naraghi Anderlini, Founder and CEO, International Civil Society Action Network (ICAN)

Andrew Bacevich, Co-founder, Quincy Institute for Responsible Statecraft

Juan Cole, Richard P. Mitchell Collegiate Professor of History at the University of Michigan

Michael C. Desch, Packey J. Dee Professor of International Relations, University of Notre Dame

Dina Esfandiary, Fellow, International Security Program, Belfer Center for Science and Security Studies, Harvard University; Fellow, The Century Foundation

John L. Esposito, Professor of Religion & International Affairs and Islamic Studies at Georgetown University

Farideh Farhi, Affiliate Graduate Faculty of Political Science, University of Hawai’i at Manoa

Nancy W. Gallagher, Director, Center for International and Security Studies at Maryland and Research Professor of Public Policy, University of Maryland

Mark Gasiorowski, Professor, Department of Political Science, Tulane University

Kevan Harris, Assistant Professor of Sociology studying development and social change in the global South, UCLA

Rula Jebreal, Professor, American University of Rome

Peter Jenkins, Former UK Ambassador to the IAEA

Bijan Khajehpour, Managing partner at Vienna-based Eurasian Nexus Partners,  a strategy consulting firm focused on the Eurasian region

Lawrence Korb, Senior Fellow at the Center for American Progress, former Assistant Secretary of Defense (1981-1985) 

Peter Kuznick, Professor of History and Director, Nuclear Studies Institute, American University

Joshua Landis, Sandra Mackey Professor of Middle East Studies and Director of the Center for Middle East Studies at the University of Oklahoma

Daniel Larison, Senior Editor, The American Conservative

John J. Mearsheimer, R. Wendell Harrison Distinguished Service Professor of Political Science, University of Chicago

François Nicoullaud, Former French Ambassador to Iran

Rouzbeh Parsi, Visiting Research Scholar, Sharmin and Bijan Mossavar-Rahmani Center for Iran and Persian Gulf Studies, Princeton University; Head of the Middle East and North Africa Programme at the Swedish Institute of International Affairs -Stockholm; Senior Lecturer, Human Rights Studies, Lund University.

Trita Parsi, Co-founder, Quincy Institute for Responsible Statecraft; Adjunct Associate Professor, Georgetown University

Thomas R. Pickering, former Under Secretary of State and Ambassador to Russia, India, the United Nations and Israel.

Paul Pillar, Nonresident Senior Fellow at the Center for Security Studies at Georgetown University and Nonresident Senior Fellow in Foreign Policy at the Brookings Institution

Edward Price, Director of Policy and Communications, National Security Action; former National Security Council Spokesperson; Former Special Assistant to President Obama for National Security Affairs

Barbara Slavin, director of the Future of Iran Initiative at the Atlantic Council

John F. Tierney, former Member of Congress and Executive Director of Center for Arms Control and Non-Proliferation and of Council for a Livable World

Stephen Walt, Robert and Renee Belfer Professor of International Affairs, Harvard Kennedy School

Lawrence Wilkerson, Visiting Professor of Government and Public Policy at the College of William & Mary and former chief of staff to Secretary of State Colin Powell

بانک‌ها در برابر ایرانی-آمریکایی‌ها تبعیض قائل می‌شوند – این اقدامی است که ما در مورد آن انجام می‌دهیم

,دوست عزیز

سال‌هاست که بسیاری از ایرانی-آمریکایی‌ها، تنها به دلیل تبارِ ایرانی‌شان، با بسته‌شدن حساب‌های بانکی خود مواجه می‌شوند. این نوعی تبعیضِ آزاردهنده است که می‌تواند فرد را در حالی که منتظر آزادشدن پس‌انداز و سرمایه‌ی زندگی‌اش است، با مشکلات مالی بسیاری روبه‌رو کند.

بانک‌ها در گفت‌وگو با ما توضیح می‌دهند که این کار، نوعی اقدام احتیاطی برای پیروی از تحریم‌های آمریکاست که اشخاص را از کار کردن با حساب‌های بانکی در ایران منع می‌کند. در حالی که قانون این اقدام را طلب نمی‌کند، بسیاری از بانک‌ها ریسک تبعیض علیه ایرانیان آمریکا را به ریسک نقض تحریم‌ها ترجیح می‌دهند.

به همین خاطر، امروز شورای ملی ایرانیان آمریکا (نایاک) تقاضانامه‌ای را تنظیم می‌کند که از وزارت خزانه‌داری می‌خواهد تا با تغییر رسمی قانون، به آمریکاییان اجازه دهد که بتوانند با حساب‌های بانکی در ایران کار کنند. این عمل، هزینه‌ای برای ایالات متحده ندارد و باید به کارکرد بانک‌ها در قبال بستن حساب‌های ایرانی-آمریکایی‌ها و شهروندان ایرانی ساکن آمریکا پایان دهد. علی‌رغم این‌که انتظار داریم بازبینی این روند طولانی و زمان‌بر باشد، اما بر این باوریم که در نهایت می‌توانیم این قانون را تغییر دهیم و به اقدام تبعیض‌آمیز بانک‌ها در قبال جامعه‌مان پایان بخشیم.

علاوه بر این، بیشترین شکایت‌هایی که تاکنون دریافت کرده‌ایم، به عملکرد بانک آمریکا باز می‌گردد. با وجود تلاش‌های متعدد از سال ۲۰۱۴ در جهت مجاب‌کردن بانک آمریکا برای تغییر سیاست‌هایش در قبال اشخاصی که عضو جامعه‌ی ما هستند، این بانک کماکان بدون هشدار یا با اطلاع رسانی کوتاه، به بستن حساب‌های ایرانی-آمریکایی‌ها ادامه می‌دهد.

به همین دلیل، ما بار دیگر نامه‌ای به بانک آمریکا فرستاده‌ایم تا برای این نهاد روشن کنیم که تحریم‌ها، آنان را به بستن حساب شهروندان معمولی مقیم آمریکا مجبور نمی‌کند و تصریح کرده‌ایم که برای حفاظت از منافع جامعه ایرانی در آمریکا، گزینه‌ی اقدام حقوقی را باز گذاشته‌ایم تا به رفتار تبعیض‌آمیز این بانک پایان دهیم.

اگر شما از جانب یک بانک با تبعیض مشابه روبه‌رو شده‌اید یا حساب‌تان مسدود شده، از شما می‌خواهیم که روایت‌تان را با ما در میان بگذارید تا بتوانیم پرونده مستندی تهیه کنیم برای اثبات این موضوع که این رفتار تبعیض‌آمیز باید خاتمه یابد. هر چه مثال‌های بیشتری داشته باشیم، پرونده‌هایمان برای تقاضای تغییر قانون در وزارت خزانه‌داری و پایان‌دادن به تبعیض‌های بانک آمریکا، محکم‌تر می‌شود.

داستان خود را این‌جا به اشتراک بگذارید

این را بدانید که ما از تلاش برای شما بازنخواهیم ایستاد؛ خواه در برابر وزارت خزانه‌داری دولت ترامپ باشد، خواه بانک آمریکا، یا هر کس دیگری که به جامعه ایرانی در آمریکا آسیب وارد کند.

با احترام،
جمال عبدی
رئیس شورای ملی ایرانیان آمریکا

گزینه کمک‌های مالی

NIAC Statement on Reports that Iran Will Halt Compliance with Aspects of Nuclear Deal

FOR IMMEDIATE RELEASE: Monday, May 6, 2019 
CONTACT: Mana Mostatabi | 202.386.6325 x103 | mmostatabi@niacouncil.org

In response to reports that Iran will halt its compliance with aspects of the Joint Comprehensive Plan of Action, or Iran nuclear deal, Jamal Abdi, President of the National Iranian American Council (NIAC), released the following statement:

“We call on all parties to fully uphold their commitments under the nuclear accord and condemn any and all violations of this agreement that is so important to preventing war and the spread of nuclear weapons. Iran’s potential move risks playing into a dangerous tit for tat that leads to military confrontation. Despite the deterioration of the accord, the window for diplomacy can be reopened if all parties forgo escalation, uphold their commitments under the JCPOA, and seek equitable compromise.  

“These forthcoming steps do not occur in a vacuum. Donald Trump, spurred on by John Bolton and Mike Pompeo, has been trying for months to shatter the nuclear deal. Now, he will own the consequences of Iran resuming aspects of its nuclear program that should be barred by the successful agreement that he inherited.

“Members of the Trump administration appear to be repeating the George W. Bush administration’s playbook for war with Iraqtying Iran to al-Qaeda, baselessly stating that Iran is pursuing nuclear weapons, and politicizing intelligence assessments on Iran. Bolton has gone into overdrive in recent weeks to spur Iranian retaliation to justify his reckless aggressionincluding using the routine deployment of an aircraft carrier group to the Persian Gulf to threaten “unrelenting force” against Iran.

“It is imperative that sober policymakers and commentators keep Iran’s actions in perspective, examine hyperbolic rhetoric with a critical eye, and remain cognizant of the consequences of further escalation.

“Meanwhile, the Iranian people are the primary victims of the Trump administration’s diplomatic sabotage. The reimposition of sanctions and unprecedented steps on oil exports are directly harming the Iranian people, who are now squeezed in a vice of oppressive sanctions and state repression under a growing threat of war.

“The choice to the U.S. is clear: return Iran to compliance with the nuclear deal by resuming sanctions-lifting obligations, or follow Trump and Bolton’s disastrous path to war. We hope all policymakers and 2020 candidates make clear that returning to the JCPOA is the only responsible choice.”

State Department Responds to Congressional Sanctions Concerns

Washington, D.C. – Last December, NIAC worked with Rep. Jared Huffman and a group of 13 lawmakers who sent a letter to the the State Department regarding the dire humanitarian impact of U.S. sanctions on the Iranian people. On February 15, the State Department sent its response to the lawmakers. Rep. Huffman’s letter requested responses on the following questions:

  1. Is it a deliberate strategy of the Trump administration to starve the Iranian people or deprive them of basic medicines? If not, what substantive steps has the administration taken to ensure the Iranian people have continued access to life-saving medicines?
  2. Which foreign nations have expressed concern about the humanitarian impact of U.S. sanctions on Iran, and what have they asked the administration to do to ensure the free flow of humanitarian goods to Iran?
  3. According to a report in The Guardian, the United Kingdom, France and Germany have pushed both the State and Treasury Departments to produce a “white list” that would “give clear guidelines about what channels European banks and companies should follow to conduct legitimate transactions with Iran without fear of future penalties.” Has the State or Treasury Departments acted upon this proposal to establish a white channel to ensure the flow of humanitarian goods? If not, why not?
  4. What additional measures have been contemplated to ensure the free flow of humanitarian goods to the Iranian people? If these were rejected, why were they rejected?
  5. Are broader license authorizations or exemptions necessary to ensure the flow of humanitarian goods to Iran? If not, what is the evidence for this assessment?

Unfortunately, the State Department failed to directly address these questions or acknowledge accountability for the humanitarian impacts of sanctions on ordinary Iranians. The response sidestepped any responsibility to uphold U.S. legal obligations to ensure essential goods, like food and medicine, are not blocked by sanctions. Yet, this is not the position of key U.S. allies in Europe, as the Huffman letter articulated.

As French ambassador to the U.S. Gerard Araud stated in November 2018: “The fact is the banks are so terrified of sanctions that they don’t want to do anything with Iran. It means that in a few months, there is a strong risk that there will be shortage of medicine in Iran if we don’t do something positive.”

The United Nations Special Rapporteur on the Negative Effects of Unilateral Coercive Measures has also warned that the administration’s reimposed sanctions “are destroying the economy and currency of Iran, driving millions of people into poverty, and making imported goods unaffordable.” Such concerns have led the European Union and Switzerland to create separate independent financial channels to facilitate humanitarian trade with Iran.

The administration’s failure to take these issues to heart is deeply concerning, as it appears to rule out steps that could alleviate the impact of sanctions on the same Iranian citizenry that the administration professes to support.

NIAC greatly appreciates Rep. Huffman and the lawmakers with whom he worked to spotlight this critical issue and for his efforts to hold the administration accountable to its humanitarian obligations. We will continue to work with its allies to shine a light on the impact of broad sanctions on the Iranian people and push the administration on its failure to properly facilitate humanitarian exemptions to U.S. sanctions.

The full text of the State Department’s response is below and Rep. Huffman’s original letter can be read here.

State Department Response to Congressional Sanctions Concerns

Rep. Jared Huffman and House Democrats Press the Trump Administration on Ensuring Sanctions & Humanitarian Aid

WASHINGTON D.C. — Earlier today, a letter organized by Rep. Jared Huffman and signed by 14 members of Congress demanded that the Trump Administration ensure that sanctions do not result in the blocking of humanitarian goods – like food and medical items – from reaching the Iranian people.

Jamal Abdi, President of the National Iranian American Council, issued the following statement, praising the letter and warning of a potential humanitarian crisis in Iran caused by overcompliance with US sanctions:

“There are strong indications that Donald Trump’s plan for Iran is to impose collective punishment on the Iranian people in violation of not just the Iran nuclear deal but of U.S. and international law. That’s why it is so important that Rep. Jared Huffman’s letter, backed by 14 Members of Congress, pressed the administration to ensure sanctions do not block humanitarian goods – like basic food stocks and medicines – from reaching the Iranian people.

“Since sanctions snapped back, we’ve already seen numerous reports on medicine shortages and skyrocketing costs of basic goods in Iran. The Iranian-American community knows this impact well, as many have heard from loved ones who are directly victimized. While the U.S. has exempted humanitarian trade on paper, in practice very few banks are willing to process humanitarian transactions out of the overriding fear of U.S. sanctions violations. Just today, reports indicated that three major global traders had halted food supply deals with Iran because sanctions have choked off all viable financial channels for the supposedly exempted goods.

“America’s European allies are pressing the Trump administration directly for guidance on how to process humanitarian transactions to avert a humanitarian crisis in Iran. Rather than deflect, the administration must engage seriously with the concerns raised by both Europe and Members of Congress and take proactive measures to facilitate humanitarian trade.

“The National Iranian American Council and its members are thankful for the leadership of Rep. Huffman and all of the Members who signed his timely letter, and looks forward to taking further action on this important issue in the new Congress.”

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Sanctions Snapback: Trump Reverses Iranian Sanctions Relief

President Trump’s snapback of nuclear-related sanctions on Iran previously waived under the Joint Comprehensive Plan of Action (JCPOA), or Iran nuclear deal, will be finalized at midnight on Monday, November 5. While a portion of the sanctions previously waived under the JCPOA came back into force on August 7, the November 5 tranche of Iran sanctions includes many of the most impactful sanctions to be levied on Iran, including those targeting:

  • Iran’s port operators and shipping and shipbuilding sectors;
  • Petroleum-related transactions with the National Iranian Oil Company, Naftiran Intertrade Company, and the National Iranian Tanker Company, including the purchase of petroleum, petroleum products, and petrochemical products from Iran;
  • Transactions by foreign financial institutions with the Central Bank of Iran and designated Iranian financial institutions;
  • The provision of specialized financial messaging services to the Central Bank of Iran and certain Iranian financial institutions;
  • The provision of underwriting services, insurance, or reinsurance; and
  • Iran’s energy sector.

In addition, the Trump administration will re-impose sanctions that applied to persons removed from OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”) and other U.S. sanctions lists pursuant to U.S. commitments under the JCPOA. This includes, for instance, the re-imposition of sanctions on most of Iran’s financial institutions, including the Central Bank of Iran.

Blowback from Snapback

The snapback of sanctions on Iran has precipitated a crisis in slow motion, threatening a range of U.S. national interests and tying America closer to the destabilizing campaigns of Saudi Arabia. The blowback from sanctions reimposition will:

Increase the Risks of an Iranian Nuclear Weapon

  • Trump’s snapback of nuclear-related sanctions has eviscerated Iran’s benefit for complying with the JCPOA, increasing the risk of Iran halting its compliance with the accord and moving closer to a nuclear weapon.
  • The re-designation of the Atomic Energy Organization of Iran (AEOI) threatens to disrupt international work to reduce proliferation risks at the Arak heavy water reactor and deeply buried Fordow facility.

Raise the Risk of War

  • Trump’s advisors John Bolton and Mike Pompeo have pushed for war with Iran as an alternative to negotiations, as have Iran’s regional rivals who have increased sway with the Trump administration.
  • A spark for a military confrontation could come from several directions in the absence of diplomacy with Iran – whether over Iran’s nuclear program, regional tensions or a naval confrontation in the Persian Gulf.

Isolate the United States

  • The U.S. is in material breach of the UN Security Council-endorsed JCPOA, which all other parties to the accord – including our allies in Britain, France and the European Union (EU) – are seeking to keep alive.
  • JCPOA participants and Iran are seeking to establish independent payment channels, with ramifications that could undercut U.S. dominance of the global financial system and the power of U.S. secondary sanctions far into the future.

Raise Oil Prices

  • President Trump has repeatedly called on Saudi Arabia and Russia to pump more oil to offset Iranian oil that has been taken off the market, reducing spare capacity that could be key to respond to any emergency.
  • Iranian oil cannot be offset forever, and a crisis risks soaring oil prices and substantial harm for American consumers.

Increase U.S. reliance on Saudi Arabia

  • At a time when Saudi Arabia appears to be an increasingly unsavory partner for the U.S. after the brutal murder of Jamal Khashoggi, the Trump administration has pigeonholed itself into an approach to the Middle East that relies on Saudi Arabia.
  • Overlooking Saudi Arabia’s crimes to pressure Iran bears eerie resemblance to America’s early backing of Saddam Hussein throughout the Iran-Iraq war. A more balanced approach to the region is needed.

Undercut Moderate Forces in Iran

  • Trump’s Iran sanctions are likely to crush the Iranian middle class and private sector, unleashing economic desperation in the country and limiting prospects for internal moderation.
  • Iran’s hardliners have been vindicated by Trump’s decision to violate the JCPOA and snap back sanctions, and will benefit from sanctions that crush forces for moderation while leaving them relatively unscathed.

Trigger a Humanitarian Crisis in Iran

  • Sanctions on Iran under the Obama administration triggered shortages of key life-saving medicines and contributed to the impoverishment of ordinary Iranians by depressing the economy and increasing the cost of basic goods. Similar effects are already being felt from Trump’s snapback.
  • The Trump administration has already targeted private Iranian financial institutions that facilitated humanitarian transactions, raising the risk of further humanitarian crises in the months ahead and more damage to American credibility.

ICJ Orders US to Provide Licenses for Food, Medicine, and Civil Aviation in Iran

Washington, DC – NIAC President Jamal Abdi issued the following statement after the International Court of Justice ruled that the U.S. must provide licenses for transactions related to medicine, food, civil aviation, and other humanitarian grounds:

“Today’s ruling by the International Court of Justice (ICJ) reflects the consensus of the international community that access to medicine, food, and civil aviation must not be weaponized against an entire people for the political aims of one administration.

“The decision orders the Trump administration to take all necessary steps to ensure that its sanctions do not inhibit trade in humanitarian goods with Iran, including trade in agricultural commodities, medicine and medical devices, and spare parts for civil aviation.  The ICJ’s provisional order acknowledges the ‘irreparable harm’ that the Trump administration’s re-imposition of sanctions—in contravention of its obligations under the Joint Comprehensive Plan of Action—could cause to Iran’s people, as the Trump administration prepares to upend Iran’s economy by prohibiting most foreign trade with Iran.   

“By virtue of the Court’s order, the Trump administration is now obligated as a matter of international law to take such actions as necessary to ensure trade in humanitarian goods with Iran, including through the issuance of all necessary licenses to guarantee the transfer of funds related to such trade. NIAC urges the Trump administration to adhere to the U.S.’s international law obligations and issue additional license authorizations to ensure that such humanitarian trade is left unaffected by the U.S.’s re-imposition of sanctions.  This should include—at a minimum—the institution of a direct banking channel between the U.S. and Iran so that exporters of humanitarian items are able to make and receive payments related to trade in humanitarian goods with Iran. Currently, all payments related to such trade in humanitarian goods must travel through third-country intermediary financial institutions before being received by a U.S. financial institution.”

“Prior to the Joint Plan of Action—the interim deal negotiated between the U.S., other major world powers, and Iran—U.S. sanctions inhibited humanitarian trade with Iran, as exporters were unable to receive payment related to their trade in humanitarian goods.  This led to significant shortfalls of medicine and medical devices in Iran, as was routinely reported in the U.S. and foreign press. By re-instituting these same sanctions, the Trump administration risks a return to this era with all its attendant harm to the Iranian people. The Court’s decision should leave the Trump administration with no choice but to take all necessary action to ensure that the Iranian people have access to medicine, medical devices, and safe civil aircraft.

“Members of the Trump administration have repeatedly attacked the institution of international courts that were in part established by the U.S. to prevent a repeat of the horrors of the early 20th century. While the administration’s antipathy toward international courts is well known, it would be nothing short of reprehensible for the administration to fail to take all necessary action to ensure that the Iranian people have access to medicine, medical devices, and safe civil aircraft. The international community should press the U.S. to uphold the court’s ruling.”

“Iran should also recognize that the foremost advocate of ensuring that sanctions do not block humanitarian goods for the Iranian people, Siamak Namazi, is now languishing in jail in Iran along with his father Baquer in a profound miscarriage of justice. As Iran presses the U.S. to comply with its international obligations, NIAC reiterates its call on Iranian authorities to release the Namazis, Xiyue Wang, other dual nationals and all prisoners of conscience unjustly held in Iran.”

Update (12:00 PM ET): 

“Rather than take the well-founded international concerns with America’s Iran sanctions seriously, Secretary Pompeo has decided to impetuously withdraw from a treaty aimed at solidifying friendly relations between the American and Iranian peoples. That treaty has proven immensely valuable to the United States historically, including in the judgment against Iran over the 1979 Hostage Crisis.

“As has been demonstrated by past and current experience, when the U.S. chokes off banking channels to Iran it also renders goods that should be exempt from U.S. sanctions – including life-saving medicine – impossible to deliver to the Iranian people. The U.S. could have ameliorated this serious concern of the Iranian people, including by establishing a clear banking channel between the U.S. and Iran for exempted goods. Instead, the Trump administration chose to render its rhetoric on the Iranian people even more hollow by further eroding the remaining infrastructure of U.S. relations with Iran.”

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Sanctions Bar Educational Platform from Servicing Iranians

A nonprofit online education platform, edX, cited a delay in obtaining a U.S. government license as the basis for a recent suspension of services that inadvertently affected Iranian Americans. After sending an open letter to the company, the National Iranian American Council (NIAC) has been working with edX to resolve complications arising from the suspension.

According to a response from edX, its specific license from the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) for Iran expired prior to being granted a renewal. U.S. sanctions targeting Iran prohibit U.S. companies, such as edX, from exporting services to Iran, including educational services to Iranian nationals located in Iran, which impacted the availability of some edX courses. In order to comply with U.S. sanctions absent a specific license for work involving Iran, across a learner base of over 17 million users, edX identified individuals who could be resident in Iran based on self-identified country residence and IP address and barred them from coursework.

This appears to have included at least some individuals who are not currently resident in Iran (but whose last activity on edX indicated an Iran IP address), including at least one U.S. citizen based outside Iran. However, NIAC has found no evidence of discriminatory intent by edX, and NIAC staff has been assured by edX that it is willing to work to resolve any remaining complications for individuals who should be legally permitted to access edX’s online coursework. If you or a friend believe that they have been erroneously barred from edX coursework, please do not hesitate to contact either NIAC staff (info@niacouncil.org) or edX Support (info@edx.org).

NIAC notes that the availability of coursework to Iranian nationals, regardless of their country of residence, ultimately serves U.S. interests by building bridges to and empowering the Iranian people. Unfortunately, by failing to issue broad enough general licenses to permit edX and similar educational platforms to make its coursework available to Iranians, OFAC has once again ensured that sanctions harm the Iranian people but not the regime. We encourage OFAC to issue necessary licenses for platforms like edX and to carve out broad exemptions to enable Iranian nationals the ability to access educational and communications tools.

EdX Response to NIAC