When Iranian Americans started reaching out to us a few weeks ago asking why websites like Kayak and Priceline were no longer allowing users to book flights to Iran, NIAC contacted the top executives of seven online travel agencies currently engaging in the practice to attempt to fix the problem. We told these companies – Orbitz, Priceline, Expedia, Tripadvisor, Cheaptickets, Hotwire, and Kayak – that, while sanctions are broad and confusing, they do not prohibit travel or the booking of travel to Iran. Since then, we’ve been contacted by Orbitz’s VP for Corporate Affairs who told us that the reason they block these sales is indeed sanctions. Or rather, the over-enforcement of sanctions that are so broad and ambiguous, private companies have been scared out of doing any business related to Iran even if it means booking flights for Iranian Americans to visit family.

Travel hurdles and restrictions aren’t a foreign concept in the U.S. You can’t simply book a flight to Cuba, either. In fact, all travel to Cuba by Americans traveling as individuals is expressly prohibited. Though, as of 2012, you can go to Cuba in a group – so long as you travel with an organization that has an official license from the U.S. State Department. In any case, given the stringent travel restrictions on Cuba, it makes sense that if you search for a flight to Havana on Tripadvisor, your attempt fails and the same error message – “we cannot complete your request…” – appears.
In the case of Iran, however, U.S. federal regulations explicitly do not restrict travel, and they certainly do not prohibit online travel agencies from facilitating Iran-related travel. And yet, as is the case with most other goods and services that are technically exempted from the sanctions, it appears that many companies are simply unaware of or unwilling to take advantage.
But what about North Korea, the country threatening war with the U.S. and our allies, and with a much more extensive nuclear war capability than Iran? Interestingly, we noticed yesterday that you actually can book flight tickets to Pyongyang, North Korea, through one of the websites, Kayak.com. Type in “Pyongyang” as your destination on Kayak, and you can find flights with no problem; although, some of the other online travel sites won’t process your request.
So why can’t you book flights to Iran? De jure technicalities aside, the de facto consequences of broad sanctions on Iran is clear. The Iran sanctions are the harshest sanctions regime ever imposed on a country during peacetime, according to the American Israel Public Affairs Committee. Many businesses, like many of these online travel agencies, have been convinced that zero association with Iran is a better business decision than the potential costs associated with any sort of business association. This has actually been the unofficial U.S. policy with regard to Iran sanctions for some time, to convince private actors that any business involving Iran, even if it’s perfectly legal, is simply not worth the risk. And this has also been the mission of organizations like United Against Nuclear Iran who name and shame any company doing any business with Iran, even if its legitimate.
The cost-benefit analysis imposed on private companies by sanctions goes something like this: the significant time and expense involved in compiling records about our business activities related to Iran, which we’re required by the SEC to report + the wrath of the U.S. government if we’re discovered to have missed or violated any of their far-reaching sanctions, is not outweighed by the fraction of the market we retain if we continue to conduct any sort of business related to Iran.
It’s unclear whether the human costs associated with the wide-reaching de facto ban on Iran-related business is being factored into executives’ cost-benefit calculations, or has ever been brought to their attention. (Although, NIAC did take one step in bringing these costs to their attention, via our letters to the top executives of these flight-booking companies.) These costs include the obstacles imposed on Iranian Americans attempting to visit friends and family in Iran.
Much more concerning, however, have been the repercussions of banks’ refusals to conduct medicine and other humanitarian sales with Iran. Though these items, too, are technically exempted from sanctions, the de facto consequence has been massive medicine shortages in Iran; and the human cost has been deadly.
An article in Sanction Law, an online resource and blog about U.S. sanctions, writes that oftentimes, “U.S. sanctions on Iran can have myriad unintended consequences.” This is particularly the case when sanctions legislation is broadly written, rather than targeted to affect solely the Iranian government or persons with decision-making power. Unfortunately, the bulk of these “myriad unintended consequences” are negative, and the majority of their victims are ordinary Iranian and Iranian-American citizens.