NIAC Pushes for Broader Sanctions Exemptions for Humanitarian Relief

Washington, DC – In response to Iran’s deadly 2017 earthquake in Kermanshah province, hundreds of thousands of U.S. citizens donated to humanitarian relief efforts to rebuild devastated areas. Humanitarian relief efforts have long been exempt from U.S. sanctions law, though in practice there continue to be sanctions-related hurdles both in how American citizens contribute to relief efforts and how humanitarian NGO’s are able to finance relief work on the ground. On numerous occasions, NIAC has raised concerns regarding these complications and pushed the administration to ensure that U.S. sanctions were not standing in the way of urgent relief. In November, Sen. Bernie Sanders (I-VT) and four other Senators led a letter urging the administration to broaden its sanctions exemptions to facilitate relief.

On March 22, the Department of Treasury solicited feedback on the effectiveness of its current licensing procedures for humanitarian aid to Iran and Sudan. Given the importance of this issue to both the people of Iran and the Iranian-American community, NIAC submitted comments recommending opportunities for improvements, including by encouraging the Treasury Department to authorize a direct banking channel between the U.S. and Iran to finance relief work. This is of critical importance, as we have heard directly from humanitarian organizations regarding the continued difficulty of finding banks willing to transact with them given the perceived risk of running afoul of U.S. sanctions.

We will continue to work to advance our recommendations and ensure that U.S. sanctions do not inadvertently impede humanitarian relief to the people of Iran. You can see the text of NIAC’s comment below:

ATTN: Request for Comments (TSRA)
Office of Foreign Assets Control
United States Department of the Treasury
Freedman’s Bank Building
1500 Pennsylvania Avenue NW
Washington, D.C. 20220

Re: NIAC’s Comments Regarding OFAC’s TSRA Licensing Procedures

Dear Sir or Madam:

            On March 22, 2018, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it was “soliciting comments on the effectiveness of OFAC’s licensing procedures for the exportation of agricultural commodities, medicine, and medical devices to Sudan and Iran.”[1]  OFAC is required to solicit such comments as part of its biennial report to Congress on the operation of the licensing procedures pursuant to § 906 of the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”) and will consider any such comments during the development of its report to Congress.  

By means of this instant submission, the National Iranian American Council (“NIAC”), the largest grassroots organization in the United States representing the interests of Iranian Americans, submits its comments regarding the effectiveness of OFAC’s licensing procedures for the export of agricultural commodities, medicine, and medical devices to Iran for the time period between October 1, 2014 to September 30, 2016. NIAC submits such comments with the sole intent of encouraging the robust facilitation of humanitarian trade between the United States and Iran in order to benefit the Iranian people, as is the purpose of the underlying TSRA legislation.

  1. Factual Background

            The Trade Sanctions Reform and Export Enhancement Act (“TSRA”), 22 U.S.C. § 7201 et seq., terminates any unilateral agricultural sanction or unilateral medical sanction in effect as of October 28, 2000 against a foreign country or foreign entity and prohibits the President from imposing any such unilateral agricultural sanction or unilateral medical sanction unless a proposed sanction is enacted into law by a joint resolution of the Congress.[2]  However, this provision does not direct the termination of, or prohibit the imposition of, any unilateral agricultural sanction or unilateral medical sanction that prohibits, restricts, or conditions the provision or use of any agricultural commodity, medicine, or medical device that is controlled on the United States Munitions List (“USML”), controlled on any control list established by the Export Administration Act of 1979 (“EAA”) or any successor statute, or used to facilitate the development or production of chemical or biological weapons or weapons of mass destruction.[3]

            Moreover, TSRA provides that the export of agricultural commodities, medicine, or medical devices to Cuba or to any U.S.-designated state sponsor of terrorism shall only be made pursuant to one (1) year licenses issued by the U.S. government for contracts entered into during the one (1) year period of the license and shipped within the twelve (12) month period beginning on the date of the signing of the contract.[4]  OFAC applies the licensing procedures required by this latter provision to all exports and re-exports of agricultural commodities, medicine, and medical devices to U.S.-designated state sponsors of terrorism – including Iran and Sudan – that are within the current scope of OFAC’s licensing jurisdiction.[5]

            Iran remains a U.S.-designated state sponsor of terrorism; and, as such, TSRA’s licensing procedures are applicable to the export of agricultural commodities, medicine, or medical devices to Iran.  These licensing procedures are codified in the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 C.F.R. Part 560.  Section 560.530 of the ITSR promulgates a general license and specific licensing procedure for the sale, export, and re-export to Iran of agricultural commodities, medicine, and medical devices, while § 560.532 of the ITSR identifies authorized means of making payment for and financing any such licensed sales, exports, or re-exports of agricultural commodities, medicine, and medical devices to Iran. 

  1. NIAC’s Comments Regarding OFAC’s TSRA Licensing Procedures

            The most significant impediment to U.S. person engagement in humanitarian trade with Iran remains the lack of a financial channel to remit payment for humanitarian goods.  Despite licensing the making of payments and financing for sales, exports, and re-exports of agricultural commodities, medicine, and medical devices to Iran, OFAC’s licensing procedures have failed to provide U.S. persons with reliable options for receiving payment for the provision of permissible humanitarian items to Iran.  Unable to reliably receive payment for their provision of humanitarian goods to Iran or receive financing to permit the sale of such humanitarian items to Iran, a substantial number of U.S. persons that otherwise would have made use of OFAC’s licensing procedures for humanitarian trade with Iran have elected not to pursue such trade.  This undermines U.S. foreign policy interests vis-à-vis Iran, as well as the purposes underlying TSRA’s legislation, by enacting a de facto embargo on the sale, export, or re-export of agricultural commodities, medicine, and medical devices to Iran. 

            Pursuant to 31 C.F.R. § 560.532(a), OFAC provides general license authorization for the following payments terms for sales authorized under § 560.530(a)

(1)       Payment of cash in advance;

(2)       Sales on open account, provided that the account receivable may not be transferred to the person extending the credit;

(3)       Financing by third-country financial institutions that are not U.S. persons, entities owned or controlled by U.S. persons and established or maintained outside the United States, Iranian financial institutions, or the Government of Iran.  Such financing may be confirmed or advised by U.S. financial institutions and by financial institutions that are entities owned or controlled by U.S. persons and established or maintained outside the United States; or

(4)       Letter of credit issued by an Iranian financial institution whose property and interests in property are blocked solely pursuant to 31 C.F.R. Part 560. Such letter of credit must be initially advised, confirmed, or otherwise dealt in by a third-country financial institution that is not a U.S. person, an entity owned or controlled by a U.S. person and established or maintained outside the U.S., an Iranian financial institution, or the Government of Iran before it is advised, confirmed, or dealt in by a U.S. financial institution or a financial institution that is an entity owned or controlled by a U.S. person and established or maintained outside the United States. 

Section 560.532(c)(2) further states that “[n]othing in this section authorizes payment terms or trade financing involving debits or credits to Iranian accounts, as defined in § 560.320.” 

            OFAC’s licensing procedures prohibit direct interaction between U.S. and Iranian financial institutions, as evidenced above.  Indeed, OFAC itself has stated that “it is contrary to U.S. foreign policy to allow U.S. financial institutions to maintain active correspondent relationships with Iranian banks.”  As a result, any financing for or receipt of payment from the licensed export of agricultural commodities, medicine, and medical devices to Iran must involve a third-country financial institution prior to the involvement of a U.S. financial institution, and U.S. person engagement in humanitarian trade involving Iran is contingent on the willingness of third-country financial institutions to issue letters of credit or otherwise process transactions involving the export or re-export of agricultural commodities, medicine, or medical devices from the United States or by a U.S. person, wherever located, to Iran.

            Unfortunately, OFAC has ample precedent at this time demonstrating that third-country financial institutions are generally unwilling to aid U.S. persons seeking to engage in humanitarian trade with Iran authorized pursuant to 31 C.F.R. § 560.530(a).  As a result, U.S. persons have not taken advantage of the permitted trade openings to the extent that would otherwise be possible if there were a reliable, authorized financial channel to remit funds from Iran to the United States.  OFAC has been presented with numerous options to resolve this ongoing problem, including, but not limited to, a direct financial channel between the United States and Iran for licensed dealings between the two countries.  For reasons that remain unclear, OFAC has chosen not to pursue these solutions and has persisted with an authorization that fails to produce the desired outcome.

            It is NIAC’s hope that OFAC will revisit its licensing procedures, including, most especially, its authorization for making payments and financing for the export and re-export of agricultural commodities, medicines, and medical devices to Iran, and will broaden the scope of current license authorizations to ensure that U.S. persons are able to timely and reliably receive payment and financing for humanitarian trade with Iran.

            III.      Conclusion

            NIAC submits this comment pursuant to OFAC’s March 22, 2018 Request for Comment and hopes that the agency will consider this feedback concerning its TSRA licensing procedures.  It is our considered view that while the agency has made important progress expanding the scope of license authorizations relating to the sale, export, and re-export of agricultural commodities, medicine, and medical devices to Iran – including by broadening the scope of medical devices that are generally authorized for export or re-export to Iran – OFAC should ensure that these license authorizations can be fully utilized by ensuring reliable options exist for making payments for and financing the export of such humanitarian items.  For the reasons explained above, NIAC believes that OFAC’s license authorizations have been under-utilized as a result of the lack of a reliable financial channel to facilitate payments for humanitarian items, and only new solutions – including, for example, a direct financial channel between the United States and Iran – can ease this ongoing problem for U.S. exporters and re-exporters.

[1]Effectiveness of Licensing Procedures for Exportation of Agricultural Commodities, Medicine, and Medical Devices to Sudan and Iran; Comment Request, U.S. Dep’t of Treasury, 83 Fed. Reg.12513, March 22, 2018, available athttps://www.gpo.gov/fdsys/pkg/FR-2018-03-22/pdf/2018-05638.pdf.

[2]See 22 U.S.C. § 7201 et seq.

[3]Resource Center: Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) Program, U.S. Dep’t of Treasury, January 13, 2017, https://www.treasury.gov/resource-center/sanctions/programs/pages/tsra_info.aspx. See also22 U.S.C. § 7203.

[4]22 U.S.C. § 7205.

[5]Resource Center: Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) Program, U.S. Dep’t of Treasury, January 13, 2017, https://www.treasury.gov/resource-center/sanctions/programs/pages/tsra_info.aspx.

 

FDD Scholar: War with Iran ‘Is On’

“The war is on”, declared Michael Ledeen, a “Freedom Scholar” with the anti-Iran deal Foundation for Defense of Democracies, at an event to discuss Iran policy following President Trump’s appointment of John Bolton and nomination of Mike Pompeo. “We’re in the war now. So all these people who keep on saying, ‘well if we sign, or if we don’t re-sign, or if we renew or we don’t renew (the Iran nuclear deal) then war,’ that’s all crazy. The war — we are in the war.”

Speaking on a panel at the Hudson Institute last week, Ledeen asserted his belief that the Iranian people had asked the U.S. for help in toppling the regime. His assertion was challenged by an Iranian American supporter of NIAC in the audience who asked Ledeen why he felt Iranians would want the United States’ help. “All they have to do is look at the neighboring countries and see that every country the United States has tried to change the leadership there, it has created a stateless country,” she said. “It’s like asking me to go to a doctor who all of his patients have died in the hospital, and asking ‘could you please operate on me?’ Why would they want the United States to aid them for any sort of help in the regime change?”

Ledeen’s response was to insult and bully rather than to engage in serious debate. Ledeen stated, “the question from this woman right here is not a question, but a provocation. So I am sorry that you’ve wasted your time coming here today to voice the line of your friends in Tehran…The reason why the Iranian people look to us for help, support, guidance in carrying out a revolution against the regime is because they hate the regime.” Ledeen then rudely told her to “sit there quietly” as the moderator moved on to the next question. The tense exchange showed both the stakes of the Iran debate in the months ahead – that Trump’s supporters think “war is on” with Iran – and that so-called “freedom scholars” will go out of their way to stifle debate on the road to confrontation.

Hawkishness and dismissiveness of alternative views was not limited to Ledeen. Richard Goldberg, another FDD adviser who served as a staffer for the hawkish former Senator Mark Kirk (R-IL), predicted that Trump would kill the deal. Goldberg indicated that with negotiations between Trump and the Europeans stalled and Bolton and Pompeo poised to enter the administration, “we have set the stage now for the likely exit of the U.S. from the nuclear deal and the potential for re-imposition of sanctions – at least on the Central Bank on May 12th, and perhaps much more.” Goldberg went on to argue that the reimposition of such sanctions, which he helped to initially pass as a staffer in Congress, would help topple the Iranian regime but avoid harming the Iranian people.

I asked Goldberg how the re-imposition of sanctions on Iran could be designed to be in favor of the Iranian people and avoid causing mass devastation. “With respect to our sanctions policy, the Iranian people are our greatest asset and we do not target the Iranian people, we do not target them, we have no quarrel with them,” Goldberg said. “And so our policy, when it targets the Central Bank of Iran (CBI), when it targets government banks, when it targets the Supreme Leader’s empire, this is about the lifeblood that keeps the Islamic Republic in business of oppressing its people.”

Goldberg’s answer might sound persuasive, yet the reality is that ordinary Iranians themselves are intricately connected to the Iranian economy and banking system – not just the regime. There is absolutely no way a country’s entire banking system can be sanctioned without its people suffering the consequences of the sanctions. We saw this at the height of nuclear sanctions, where the Iranian people suffered from mass unemployment and sanctions while the Islamic Revolutionary Guard Corps (IRGC) expanded its business empire.

Michael Pregent, a fellow with the Hudson Institute, stated that president Trump “has his Iran team in place,” with John Bolton in as National Security Advisor and Mike Pompeo hoping to be confirmed as Secretary of State. If Pompeo and Bolton share the Hudson panelists’ proclivities, it appears that war could be very difficult to avoid.

“Peace is not the opposite of war,” Ledeen ominously concluded. “Peace is the result of war. Peace happens when a war is fought and one side beats the other.”

Don’t Let Trump Turn Iran into North Korea


Thirteen months into Trump’s presidency
, the Iran nuclear deal is alive but wounded. Ironically, while many in the U.S. argued that Iran could not be trusted to abide by its terms, it is the U.S. under Trump that has violated the agreement on multiple occasions. Ominously, Iran has warned that if the status quo does not change, it could withdraw from the accord. Unless the administration changes course and halts its diplomatic sabotage, the JCPOA risks the same fate as another landmark nonproliferation agreement, the Agreed Framework with North Korea, to the profound detriment of U.S. security and the nonproliferation regime.

Read the full article on Defense One…

 

Think Again: Iran’s Missile Program

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In spite of Iran’s verified implementation of the Joint Comprehensive Plan of Action (JCPOA), which has rolled back Iran’s nuclear program and subjected it to far-reaching inspections, Iran’s periodic testing of ballistic missiles has provoked substantial angst in Washington. Under UN Security Council Resolution 2231, the resolution endorsing the JCPOA, Iran is “called upon not to undertake any activity related to ballistic missiles designed to be capable of delivering nuclear weapons” including tests for a period that will last up to eight years. While that language does not impose a binding legal obligation on Iran, both the U.S. and other parties have criticized Iran’s missile testing as “inconsistent” with UNSC Resolution 2231, though not a formal violation.

Since President Trump entered office, his administration has rolled out eight rounds of new sanctions designations and signed new sanctions legislation into law targeting Iran’s missile program. Moreover, the President in January threatened to terminate the JCPOA unless Congress passes legislation stating “that long-range missile and nuclear weapons programs are inseparable, and that Iran’s development and testing of missiles should be subject to severe sanctions.”

Despite this flurry of activity, there have been subtle shifts in Iran’s missile program that could reduce the program’s threat. In particular, Iran’s articulation of a range limit to its missiles and a shift toward short-range solid fueled missiles signals an interest in conventional, regional deterrence, not long-range nuclear missiles.

Iran is Focusing on Short-Range Missiles Aimed at Conventional Deterrence

The commander of the Islamic Revolutionary Guard Corps (IRGC), Gen. Mohammad Ali Jafari, asserted that Iran’s missile program is limited to a 2,000 kilometer radius around Iran under a policy endorsed by Iranian Supreme Leader Ali Khamenei. Similar statements have been issued in the past, though Jafari’s statement appears to be a firming up of prior policy and a signal to the U.S. and others regarding the relative limits of Iran’s missile ambitions.

Moreover, Iran’s testing since the conclusion of the JCPOA appears consistent with this limit. According to an analysis from the Center for Nonproliferation Studies and Nuclear Threat Initiative, Iran has shifted from seeking longer range systems toward short-range missiles primarily suited for conventional deterrence. According to the study:

“the JCPOA has helped redirect Iran’s priorities for its missile program away from developing an ICBM (whose only purpose would be as a nuclear delivery system), to developing solid-fueled versions of its short-range missiles. While such missiles could also be nuclear-capable, they do not extend Iran’s range or payload capabilities meaningfully, and appear intended to serve a conventional purpose.”

While a 2,000 kilometer range limit would include Israel and Saudi Arabia, in addition to numerous U.S. bases in the region, Iran’s focus on conventional solid-fueled missiles suggests they are indeed aimed at regional deterrence – as opposed to long-range missile development that could threaten Europe or the U.S. mainland. Such a shift also meshes with Iran’s signing of the JCPOA, which ensures Iran’s missile program cannot be fitted with nuclear warheads. This is a positive that could be built upon through deft diplomacy, or undermined via diplomatic sabotage.

Pressure Is Unlikely to Change, and May Even Reinforce, Iran’s Missile Calculus

Director of National Intelligence Daniel Coats stated in the annual Worldwide Threats Report this week that Iran “has the largest inventory of ballistic missiles in the Middle East.” Yet, Iran’s competitors are not without missile inventories that match or exceed Iran’s capabilities. Saudi Arabia reportedly maintains dozens of missiles capable of striking Iran, with a maximum range of 2,650 kilometers. Israel is believed to possess both a sizable nuclear arsenal and ballistic missiles capable of traveling up to 6,500 kilometers. Moreover, Iran lacks a modern air force due to a continuing arms embargo and is outspent militarily by Saudi Arabia at a 5:1 rate.

While Iran may prove willing to negotiate over the range of its missiles or confidence building measures with other states if the JCPOA is adhered to, Iran views its missile program as a regional deterrent that is central to its national defense doctrine. Sanctions have not altered that calculus and major arms buildups among Iran’s neighbors have likely strengthened it.

Much of this doctrine stems from Iran’s experience in the Iran-Iraq war, when Iran was almost completely isolated within the region and globally as the world turned a blind eye and even aided Saddam Hussein’s chemical attacks on Iran. Moreover, while Hussein was able to target missiles at Iranian cities from within Iraq, Iran had no similar deterrence or response capability. Iranian Foreign Minister Javad Zarif has stated that Iran needs its missile program “to prevent another Saddam Hussein around the corner attacking us with chemical weapons because the international community has failed miserably in protecting the Iranian people.” The development of a conventional deterrent and response capability is one that has broad support within Iran across political divides. Unless the U.S. and international community engages on the fundamental issues at the heart of Iran’s missile calculus, no amount of sanctions or regional arms sales will succeed in altering it.

Iran’s Missile Testing Has Remained Sporadic

There were only a handful of confirmed reports of Iranian missile launches in 2017. These include:

  • Iran test-fired a medium-range ballistic missile January 29;
  • Iran test-fired a pair of short-range ballistic missiles in early March;
  • Iran launched eight missiles at ISIS (a U.S. enemy) on June 18 in response to a terror attack in Tehran;

While President Trump took to Twitter to allege another Iranian missile launch September 23, this report was actually based on old video of the January test. Further, while Iran test-fired a Simorgh satellite rocket July 27 amid passage of Congressional sanctions targeting Iran’s missile program, that rocket is not designed to be capable of reentering the atmosphere and thus has limited military applications.

It is noteworthy that the July 27 launch appears to be the last undertaken by Iran – a testing pause of more than six months that has extended into 2018. In roughly the same period, the U.S. Navy has reported a significant lapse in dangerous run-ins with the IRGC in the Persian Gulf. While these trends should be monitored, it appears possible that Iran is attempting to avoid giving the U.S. a pretext to sabotage the JCPOA and turn Europe against Iran.

Iran launched roughly five missile tests per year from 2006 to 2012 before nuclear negotiations involving the U.S. gained traction in 2013, according to Michael Elleman of the International Institute for Strategic Studies. Iran largely abstained from missile tests while the negotiations that led to the JCPOA were underway. Since then, the frequency of Iran’s missile tests has been largely consistent with past practices, and – barring major changes – there remains little reason to expect Iran to dramatically ramp up or seek to field a missile capable of reaching beyond the region.

To put Iran’s missile testing in perspective, the CNS-NTI report notes that North Korea tested 14 missiles capable of traveling more than 3,000 kilometers between the signing of the JCPOA and August of 2017, a feat that has not been replicated by Iran.

Transfers to Yemen?

U.S. Ambassador to the United Nations Nikki Haley has taken the lead for the administration in alleging that Iran transferred missiles to Houthi rebels in Yemen, which were in turn launched against Saudi Arabia. Iran has vociferously denied the claim while indicating that Houthi missile stocks were left over from prior Yemeni governments. While Russia has dismissed the Trump administration’s allegations as inconclusive, a confidential UN report has indicated that Iran “failed to block ballistic missile supplies from being used by Houthi rebels.”

Saudi Arabia’s intervention in Yemen – with substantial military assistance from the U.S – has been heavily focused on rolling back Iran’s alleged influence there. Yet, at least at the outset of the conflict, ties between Iran and the Houthis were tenuous at best, with Houthi rebels ignoring Iran’s warnings against taking the capital Sanaa in 2014. If Iran-Houthi ties have now progressed to the point where Iranian support has enabled the Houthis to nearly strike key targets in Riyadh, it should be a clear signal to policymakers that U.S. backing of Saudi Arabia’s intervention is having the opposite of its intended effect and is endangering Saudi and regional security.

What is needed is what the Trump administration has avoided since it came into office: serious, multilateral diplomacy aimed at ending the conflict in Yemen and ameliorating all the actors’ security concerns. Absent this, the negative trend line of the war in Yemen is likely to continue, with disastrous results for the Yemeni people and regional security.

Trump is Escalating Missile Sanctions without a Serious Diplomatic Plan

Thus far, the Trump administration has continued to designate entities and individuals with ties to Iran’s missile program, while also signing new legislation into law targeting the program. Calls to subject Iran’s program to “severe sanctions” would be largely redundant, as the program is already heavily sanctioned. The administration and Congress’ actions since January 2018 include:

  • February 2, 2017 – The Treasury Department imposes sanctions on 25 individuals and entities following Iran’s January launch;
  • May 17, 2017 – The Treasury Department sanctions seven individuals and entities, including a Chinese network, for supporting Iran’s missile program;
  • July 18, 2017 – The Department of State designates two entities for supporting Iran’s missile program while the Treasury Department designates sixteen entities and individuals for supporting the IRGC;
  • July 28, 2017 – The Treasury Department imposes sanctions on six Iranian entities supporting Iran’s missile program in response to its launch of the Simorgh space rocket;
  • August 2, 2017 – The administration signs the Countering America’s Adversaries Through Sanctions Act (CAATSA) into law, which mandates the imposition of additional sanctions in response to Iran’s missile program;
  • August 14, 2017 – The Treasury Department imposes sanctions on eleven entities and individuals, including one entity for supporting Iran’s missile program;
  • October 13, 2017 – The Treasury Department designates the IRGC as a Specially Designated Global Terrorist (SDGT), while also designating four entities including for ties to Iran’s missile program;
  • October 25, 2017 – The House of Representatives passes H.R. 1698, the Iran Ballistic Missiles and International Sanctions Enforcement Act.
  • January 4, 2017 – The Treasury Department sanctioned “five Iran-based entities subordinate to a key element of Iran’s ballistic missile program.”
  • January 12, 2017 – In addition to sanctioning Iranian persons and entities under human rights sanctions, the Treasury Department designated persons and an entity for ties to entities sanctioned for supporting Iran’s missile program.  

In the absence of serious, direct diplomatic engagement between the U.S. and Iran, there is little possibility of changing Iran’s security calculus and no possibility of trading in sanctions for concessions on Iran’s missile activity or other concerning behavior – ensuring that the status quo remains the same or worsens, but never sustainably improves.

Moreover, while it is fair to be concerned about the potential uses of Iran’s missile program or other Iranian activity that runs counter to U.S. interests, it is important to ensure that economic pressure is calibrated and proportional. Continuing to ramp up sanctions designations and legislation at such a pace risks undermining sanctions relief obligated under the JCPOA and could harden domestic political pressure within Iran to begin hedging on JCPOA-compliance and take a more aggressive stance towards the U.S. across the region.

Instead of replacing nuclear escalation with missile escalation, the Trump administration and Congress should protect the gains of the nuclear accord and seek to build on them through serious diplomatic engagement. Failure to do so will risk the unraveling of the nuclear accord and the U.S. once again facing the threats of a nuclear-armed Iran or war.

Will the Israeli-Iranian Showdown Be in Syria — or New York?

In today’s Middle East, when parties look for a greater power to pressure regional actors not to escalate, they don’t turn to Washington. They turn to Moscow. With leverage over Israel, Iran, and Syria, Russia is in a unique position to stop the wider conflict that threatens to erupt — and particularly after a single day saw an Iranian drone reportedly penetrate deep into Israel, the downing of an Israeli F-16, and Israel’s massive bombardment of targets inside Syria. And although the military situation could yet spin our of control, there are reasons to believe that the fight may turn political instead.

At the root of the tensions is the shifting regional balance of power. Over the past fifteen years, Israel has steadily seen its own maneuverability in the region recede, while Iran’s has been bolstered by Washington’s disastrous invasion of Iraq, the subsequent loss of U.S. influence and credibility, and even Bashir al-Assad’s survival in Syria. On top of that, the nuclear deal prevented Tehran from acquiring a nuclear weapon, but also recognized Iran as a de facto regional power and ended a decades-long U.S. policy of seeking the country’s complete isolation. Similarly, major powers in Europe, Russia, and China began treating Iran as a legitimate regional actor whose involvement and buy-in was necessary for stability.

According to the Iranian foreign ministry and Tehran’s ally Hezbollah in Lebanon, the events of Feb. 10 signify that the “era of Israeli strikes on Syria is over” — and mark a further reduction in Israel’s maneuverability, who for years have freely bombed targets in Syria without significant repercussions.

But despite the tough rhetoric, few see much appetite in Israel or in Iran for a direct military engagement. Instead, Israel is more likely to shift the conflict to a different theater — the UN — where it will seek to reimpose Iran’s pariah status, return Tehran to diplomatic and economic isolation, and reverse 15 years of change in the regional balance.

Such a shift would fit well with efforts prepared by Saudi Arabia and the Trump administration, who for weeks have prepared the ground to reimpose new UN sanctions on Iran. Some of their efforts have already born fruit.

Earlier last month, a little-noticed leaked UN Panel report accused Iran of violating a UN-imposed arms embargo on Yemen. The report doesn’t claim that Iran has provided weapons to the Houthi rebels in Yemen, but rather that Tehran has failed to keep the rebels from obtaining Iranian weapons. As a result, the panel concludes that Iran is in non-compliance with UN Security Council Resolution 2216.

The somewhat far-fetched Saudi plan has been to use the report to impose on Iran a new resolution under Chapter VII of the United Nations Charter, which allows the UN Security Council to “determine the existence of any threat to the peace, breach of the peace, or act of aggression” and to take action to “restore international peace and security.”

Such a resolution would once again put Iran in the penalty box, with its economy sanctioned and its political pathways for influence in the region blocked — i.e., an all-out containment of Iran. In Riyadh’s calculation, this will thwart Tehran’s rise and shift the regional balance in favor of Saudi Arabia and Israel.

The value of such a resolution to Israel and Saudi Arabia — and its threat to Iran — go far beyond the rather limited economic impact of the sanctions it may impose. A Chapter VII Security Council resolution “securitizes” a country, in the words of Iran’s Foreign Minister Javad Zarif. Anything pertaining to Iran — whether regular trade or even participation in political bodies — will be seen through a security lens, Zarif told me in an interview for my book Losing an Enemy – Obama, Iran and the Triumph of Diplomacy.

In Iran’s case, it meant that it was viewed as having a menacing nuclear program before it was viewed as a country or a nation. The country and its activities were now officially defined as a threat to international peace and stability. Though the UN sanctions imposed on Iran were not biting per se, they were nevertheless a critical component of the securitization of Iran. “Sanctions were both an outcome of this securitization environment and also perpetuated by it,” Zarif argued. “It showed that this country [Iran] is a security threat because of the sanctions.”

Israel and Saudi Arabia’s opposition to the nuclear deal was partly rooted in their desire to keep Iran permanently isolated. By striking the nuclear deal and neutralizing that threat, Barack Obama deprived Israel and Saudi Arabia of their main tool for pursuing Iran’s containment.

Now, whether through the UN Panel report on Yemen or allegations of Iranian drones violating Israeli airspace, the Israeli-Saudi alliance hope they have a path towards a new UN Security Council resolution that once again puts Iran in the penalty box and paves the way for an all-out American containment of Iran.

Thus, despite high rhetoric and tough statements, the real showdown may soon move from the Israeli-Syrian border to New York. Not only is the cost less for Israel, but the impact will arguably also be greater. While a strong military assault against alleged Iranian positions in Syria may win Israel and Saudi Arabia a few weeks, a Chapter VII resolution at the UN can win them a decade.

But just as Putin blocked Israel’s bombing campaign in Syria, he holds a similar trump card in New York: a Security Council veto. Israel and Saudi Arabia may have Donald Trump and Nikki Haley where they want them, but without Russia, their campaign to shift the regional balance of power against Iran remains an uphill climb.

Originally published in Defense One

Poll of Iranians Punctuates Points Made in Protests

 

Conducted after weeks of sweeping protests across the country, the latest national poll of Iranians by the Center for International and Security Studies at Maryland and IranPoll underscores growing Iranian discontent with the economy, Tehran’s mismanagement and corruption, disillusionment with the JCPOA and the effectiveness of international diplomacy, and increasing disapproval of the policies of the Trump White House.

When asked their opinion regarding “how good or bad our country’s [Iran’s] economic situation” was, 68.9% of Iranians believed the economic situation in Iran was somewhat or very bad, with 40.7% of all Iranians responding the state of the economy was “very bad.” This overwhelming negativity comes as little surprise to most pollsters, given unemployment rates among Iranian youth as high as 40% and the depreciation of the Rial by 25% in the past 6 months. Dr. Ebrahim Mohseni, a research scholar at CISSM, commented on the discontent among many young Iranians at a panel discussion hosted by the Atlantic Council, stating “[I]f the educated segment of the population feels they are not being utilized or are unemployed, then that becomes a severe source of discontent; both for the people who have attained the education and the people who have paid for it.”

When asked what has had the greatest negative effect on the economy, 63.3% of Iranians believed that domestic economic mismanagement and corruption,were the most responsible for Iran’s current economic issues, while only 32.1% of the population believed foreign sanctions and pressures were the most culpable.

This frustration and discontent with domestic economic policy manifested itself in the protests this January. When polled on the issue of price inflation for food products, 81.3% of Iranians strongly agreed the government should do more to prevent this issue. Likewise, 85.2% of Iranians strongly agreed with the statement that “the government should do more to fight financial and bureaucratic corruption in Iran.”

The poll also demonstrated growing disappointment with perceived lack of economic benefits from the JCPOA, and strong sentiments that diplomacy has been ineffective in achieving the country’s interests.  When surveyed on the effect of the JCPOA on people’s living conditions, 74.8% of Iranians responded that their living conditions have not improved. Regarding their opinion of the success of the JCPOA, 67.4% of Iranians supported the statement that the “JCPOA experience shows that it is not worthwhile for Iran to make concessions, because Iran cannot have confidence that if it makes a concession world powers will honor their side of the agreement.”

The poll found growing disapproval of the Trump Administration’s policies toward Iran. 60% of Iranians believe the United States has not complied with all of its promised sanctions removals, and 89% percent lack confidence that the United States will live up to its JCPOA obligations. When asked to rate President Trump’s Iran policies on a scale of 0-10 (0 being completely hostile and 10 being completely friendly), 69% of Iranians found his policies to be completely hostile, and when asked to indicate to what degree [they] held a favorable or unfavorable view of the United States government, 67% had a very unfavorable opinion.  

Also speaking at the Atlantic Council presentation on the survey was Esfandyar Batmanghelidj, founder and publisher of the online platform Bourse & Bazaar which supports Iranian “business diplomacy.” He expressed his concerns that the botched execution of sanctions relief under the nuclear deal –  by the current U.S. administration in particular – devalued the very idea of diplomacy to the Iranian people. “Sanctions, at least in the Iranian context, have been one of the most self-defeating diplomatic tools imaginable; because in their application and flawed removal, they have actually harmed the idea and the prospect of diplomacy moving forward,” stated Batmanghelidj.

When analyzing these findings, it is also vital to bear in mind potential constraints associated with conducting national polls in an authoritarian country. Dr. Mohseni acknowledged the need to phrase polling questions in a manner that those surveyed would not feel compelled to self-censor, particularly with phone interviews.

Trump and His Allies Are Ready to Sabotage the Iran Deal

President Donald Trump has punted the fate of the Iran nuclear deal to Congress, vowing to terminate the multilateral accord by mid-May if his unrealistic demands are not met. By issuing ultimatums from the White House while outsourcing the work to Congress, Trump has set up a process that can seemingly only fail. The United States cannot simply legislate new demands to an international agreement and the current Congress lacks the political wherewithal to approach the matter seriously. One need look no further to back up this claim than the first Iran bill in line with Trump’s demands, offered by Reps. Peter Roskam and Liz Cheney and backed by the hub of Iran nuclear deal opposition at the Foundation for Defense of Democracies. It is such an unrealistic piece of legislation that the only rational way to explain it is as part of a broader approach to ensure the termination of the deal.

The fact that Trump is in the White House should not give a free pass to such recklessness, particularly when it has to do with war and peace and nonproliferation in the Middle East. Serious legislators and policymakers must step up to warn against the path that Trump and his lackeys in Congress are leading us down, while taking what actions are available to try to preserve the accord.

Far from altering the deal, the Roskam-Cheney bill would force the United States to materially breach the agreement, also known as the Joint Comprehensive Plan of Action (JCPOA). It does so by mandating a series of certifications every ninety days on activities beyond the scope of the JCPOA to forestall the snapback of nuclear sanctions, a move that would kill the deal.

The bill would reimpose the sanctions that the United States committed to lift under the JCPOA in ninety days if Iran does not ratify the IAEA Additional Protocol in that time, a step that is not required by the deal until October 2023. Sanctions would also snap back if Iran ever moves above 130 tons of heavy water, which is not strictly limited by the JCPOA and is far less important than other areas of the agreement, such as inspections and enrichment. Moreover, if Iran undertakes any launches utilizing ballistic missile technology—an area outside the JCPOA—the legislation would snapback sanctions. Given Iran’s frequent rhetoric ruling out inspections of military sites, a position that has been bent in practice, it is also far from clear that Trump would certify that Iran has not “denied . . . anywhere, anytime” inspections as mandated by the bill.

The inclusion of these certifications would sacrifice the tangible protections of the JCPOA in the misguided hopes of achieving negligible gains. In lieu of Iran’s obligated ratification of the Additional Protocol in 2023, Roskam and Cheney would collapse the agreement and ensure the Additional Protocol is never ratified. Instead of suggested guidelines on Iranian heavy water that have been largely adhered to under the JCPOA, the United States would put at risk firm limits on enrichment that have distanced Iran from a nuclear weapon. In tying the accord’s fate to conventional missile testing, the bill would enable Iran to move closer to fitting their missiles with nuclear warheads. And, rather than be content with an established mechanism to ensure IAEA inspection of nuclear facilities and any suspicious facility in Iran—including military sites—it would sacrifice “the world’s most robust nuclear verification regime,” according to IAEA Director-General Yukiya Amano, on the basis of little more than right-wing conspiracy theories.

While the Roskam-Cheney bill includes additional poison pills, including certifications that would seek to lock in Iran’s current enrichment restrictions indefinitely and sanctions designed to nullify Iran’s benefits under the accord, any one of the above certifications would sabotage the JCPOA. While the bill’s proponents care little for the United States upholding its own obligations under the JCPOA, they should. If the deal collapses, the odds of an Iranian nuclear weapon and war with Iran will dramatically increase, while the United States will be isolated from our allies in Europe and other negotiating parties—like Russia and China—that would be key to enforcing continued sanctions against Iran or any negotiation over North Korea’s advancing nuclear weapons arsenal.

Rather than go along with Trump’s charade on the JCPOA, responsible legislators need to take the wheel. First, they should block any legislation, like that proposed by Roskam and Cheney, that would force the United States into material breach of the accord. Second, they should point to the president’s lack of good faith and disastrous threats to sabotage the accord as justifications for removing the president’s scheduled decision points on the JCPOA, which have been set into place in both Iran sanctions bills and the Iran Nuclear Agreement Review Act. Failure to do so will ensure that the deal is scheduled for potential termination every few months, a status quo that is at odds with U.S. commitments to implement the deal in good faith and abstain from any action that would adversely affect the normalization of Iran’s economic activities.

There is little reason to budge from these demands. While opponents of the JCPOA will point to Trump’s threats to kill the deal in an attempt to compel passage of legislative sabotage, there is no reason for responsible legislators to hop aboard the sinking ship that is Trump’s Iran policy. After all, they would only end up sharing the blame for the agreement’s collapse with Trump and his congressional cheerleaders.

Originally published in the National Interest

Stories & Insight One Year into Trump’s Muslim Ban

 

FOR IMMEDIATE RELEASE
Contact: Jamal Abdi
Phone: (206) 369-2069
Email: Jamal@niacaction.org

January 27, 2018, marks the one-year anniversary of Donald Trump’s Muslim Ban that remains in place today. The Iranian-American community has been particularly impacted by this ban, with 62% of the non-immigrant visas typically issued to countries on Trump’s list going to Iranians.

The next week is an excellent opportunity to evaluate the continued impact of the ban and the prospects for overturning it when it comes before the Supreme Court this spring or at the ballot box during the Congressional mid-term elections in November. NIAC Action legal, legislative, and community experts are available for comment.

We have included key resources below including stories of those impacted by the ban, an overview of how the ban has been implemented and details on efforts to overturn the ban:

Stories from Iranian Americans on the Continued Impact of the Ban:

“My wife is finally pregnant after 8 years. My mother in law couldn’t wait to see her grandchild, but with Muslim ban 3.0, she has no chance.”

    -Mahdi
 

“I sit in my lab at university everyday, thinking why my mom and I are being punished for the crimes we’ve never committed?! In what world anyone has the right to separate a daughter from her mom for 5 years?”

    -Sara
 

“I can’t hold back my tears when I’m asked by colleagues: “what are you doing for the holidays?” I can’t travel back home because I won’t be able to come back to the U.S. due to the new travel ban. On top of that, my parents whom I have not seen for 3 years, cannot obtain a visa to come visit me. This separation is unnecessary and unfair.”

    -Maral

I lost my father, the only family I had after losing both my mother and only young brother to cancer. My father died of a broken heart, after 16 months of waiting for a visa, he had given up hope that we were ever going to be together again.

I strongly believe my rights were violated not only in the first place when my father went to the U.S. Embassy, but also over and over again during this last 16 months until he died. 

My father died from disappointment and depression. I clearly stated my situation and the hardship we went through in my letters to Congressman, the White House, the U.S. Department of State and the U.S. Embassy. I also clearly stated my frustration at the neglecting of my father’s case with them, but they did nothing to help us. I strongly believe that they are responsible for all the hardships and grief my father went through, and also his death. I strongly believe my basic right to have my father in my home was subjected to political matter, hatred and discrimination. I don’t doubt that there are many others whose hopes have been dashed by what I perceive to be an uncaring, unfeeling bureaucracy.

-Mania
 

“My 73 year old dad is suffering from heart disease, stares at my 3 year old son with a mixture of enthusiasm and sorrow. While he tries to take a look at my son through my cell phone camera, I cry deep inside and curse myself for having to leave them for hope of a better life for my kids living in freedom. My parents may live and die without having their children and grandkids around. This is the price I am paying to be in land of freedom and opportunity.”

    -Sanaz
 

“My husband is Iranian, and is now a U.S. citizen. I was born and raised in America, and I’m a current military service member. We are recently married, and we had a destination wedding in Mexico due to the Muslim Ban. We knew there was no way my husband’s entire family would get tourist visas approved to come to our wedding in America, so we decided on a wedding in Mexico. The Mexican embassy in Tehran was great to work with. They were prompt, friendly, and fair. Now that we are back home in the States, it breaks my heart that I do not know when I will see half of my family again. What if we have kids? Since we are recently married, this is something we have been talking about a lot. Do we want to bring children into the world that may never know one set of their grandparents due to our president and administration being racist? Who will help us with childcare and life in general, as many grandparents do? As an Airman, I fight for the rights of everyone in this country. The fact that our president is taking them away everyday because of his misinformed, racist agenda breaks my heart. Will I ever see my sister again? Or brother? How has Congress let him get away with this time and time again?”

– Jennifer

The Legal Implications of the Ban:

The National Iranian American Council has been involved in two lawsuits to defeat all three versions of Trump’s ban. There was little doubt then that Trump’s Order “drips with religious intolerance, animus and discrimination,” and there remains little doubt a year later:

  • While Trump’s lawyers have not yet won on the merits, the fact that the ban has been allowed to go into force means that impacted communities cannot rely on the Supreme Court alone to strike down the ban.
  • Dating back for over 40 years, no national from the targeted countries has ever killed anyone in a terrorist attack on U.S. soil;
     
  • The Department of Homeland Security’s Office of Intelligence and Analysis has confirmed that nationality is a poor predictor of terror threat;
     
  • The criteria used to justify the new proclamation were applied arbitrarily, not in an objective manner as the Trump administration has asserted;
     
  • The ban will impact more Iranians and Iranian Americans than any other group on the restricted countries list. National Iranian American Council’s analysis predicts that Muslim Ban 3.0 will disproportionately impact Iranians with 62% of those potentially impacted being Iranian nationals, according to 2016 State Department data;
     
  • Even when the Muslim ban has not been in effect, it has applied “Extreme Vetting” measures that have resulted in a dramatic decline in visa issuance to the targeted Muslim-majority countries.

 
Legislative and Political Efforts to Overturn the Ban:

Vice News: The Vice News Guide to the World

Five Myths About Iran

For the past four decades, the United States and Iran have demonized each other to no end. According to Tehran, America is “the Great Satan” whose imperialist designs have destabilized the Middle East and brought nothing but misery to the people of the region. Washington, meanwhile, depicts Iran as the “leading state sponsor of terrorism” and a member of the “Axis of Evil” whose “evil hand” is behind every conflict in the region. But somewhere along the way, America’s and Iran’s knowledge about each other was edged out by myths. “Don’t know thy enemy” became the mantra. Here are some common American myths about Iran.

MYTH NO. 1
The nuclear deal only delays an inevitable Iranian bomb.
This has been a common criticism of the Iran nuclear deal, a.k.a. the Joint Comprehensive Plan of Action (JCPOA). As Secretary of State Rex Tillerson put it: “The JCPOA fails to achieve the objective of a non-nuclear Iran; it only delays their goal of becoming a nuclear state.”

This misconception is based on the fact that some of the restrictions on Iran’s nuclear program — namely, limits on the number of centrifuges it can have, the advanced research it can conduct and the amount of energy-grade uranium it can stockpile — expire after 10 to 15 years (as is the case with most arms-control treaties). However, the most important aspects of the deal — the intrusive inspections regime and the transparency and verification mechanisms — are permanent. Iran will be expected to abide indefinitely by the Additional Protocol to the 1970 Nuclear Non-Proliferation Treaty, and those inspections are the strongest guarantees possible to render an Iranian nuclear bomb an impossibility.

There’s one catch, though. Iran must live up to its end of the bargain only as long as the United States lives up to its end. If Washington violates the deal or “terminates” it, as Trump vowed to do again on Friday, the restrictions on Iran’s nuclear program will be lost.

MYTH NO. 2
Killing the deal would help support Iranian protesters.
By some accounts, abandoning the pact would be the best way to support the demands of protesters who have been demonstrating across Iran this month. “The deal has emboldened Iran’s ruling mullahs to continue the nation’s international isolation, as Tehran spends billions of dollars on expensive belligerent activities, money that was made available to it through sanctions relief and that it could have spent to shore up the civilian economy,” Fred Fleitz, a George W. Bush administration national security official, wrote for National Review.

It’s true that the protests have been driven by economic grievances and that Iranians, especially the working poor, have been frustrated that sanctions relief hasn’t improved the economy. But jettisoning the deal and reimposing broad economic sanctions would only further punish the Iranian people.

Promoting Iran’s integration in the global economy is a better way of empowering Iran’s working and middle classes — and striking a blow against reactionary forces within the regime whose main source of power is its stranglehold on the economy. Indeed, numerous polls show that Iranians overwhelmingly supported the nuclear deal precisely because they are desperate to break free from Iran’s isolation and reconnect with the outside world.

Those in Iran who would like to see the nuclear deal collapse are the very hard-line elements the United States shouldn’t be helping.

MYTH NO. 3
Iran’s Green Movement was a failure.
Practically every commentary on the recent demonstrations has compared them with the protests of 2009, frequently suggesting that the Green Movement, while valiant, failed. Typical was Vice President Pence’s op-ed in The Washington Post: “The Green Revolution was ruthlessly put down, and the deadly silence on the streets of Iran matched the deafening silence from the White House.”

Iran’s clerical government did indeed brutally suppress those protests, putting Green Movement leaders under house arrest. And the movement’s immediate demands were not met: Accusations of voter fraud were not properly addressed, political prisoners were not released, and Mahmoud Ahmadinejad went on to serve another four years as president.

But the Greens got some vengeance in 2013 through the election of Hassan Rouhani. Without the support of the Green voters, Rouhani — who lacked a clear political base — could not have won the presidency. And in 2017, reformists swept almost all seats in city council elections in Iran’s largest cities. In the conservative city of Mashhad, a woman ran on a platform of opposing the patriarchy. Her slogan was “Elect more women!” She won.

MYTH NO. 4
Iran’s enmity with Israel is ideological and immutable.
The Israeli-Iranian confrontation “is a sweeping ideological conflict,” proclaims Israeli political commentator Aluf Benn. “And history teaches that such conflicts end only when one side has been knocked out.”

Iranian leaders, too, often frame the clash as ideological, which enables them to pose as champions of the Palestinians and defenders of Islam against the West. In reality, though, the conflict is driven by geopolitical factors.

Historically, Iran and Israel enjoyed strong relations born out of common threats they faced: from the Soviet Union and from powerful Arab states, such as Egypt and Iraq. Although Iranian leaders turned against Israel rhetorically with the birth of Iran’s theocracy in 1979, the strategic reality did not change, and the two nations continued to collaborate behind the scenes. In fact, as I detail in “Treacherous Alliance,” Israel lobbied Washington to talk to Iran, sell arms to Iran (remember the Iran-contra scandal?) and disregard Iran’s anti-Western rhetoric.

But tension escalated in 1991 because of two geopolitical shocks: the collapse of the Soviet Union and the defeat of Saddam Hussein’s Iraq in the Persian Gulf War. The common threats that had brought Israel and Iran together evaporated. And in the struggle to define the new balance of power in the Middle East, Iran and Israel were no longer allies but rivals. That struggle has yet to be resolved.

MYTH NO. 5
Iranians hate Americans.
“When someone chants, ‘Yes, certainly, death to America,’ we should take him at his word,” said Sen. Tom Cotton (R-Ark.), referring to Ayatollah Ali Khamenei. But while the Iranian government’s hostility toward the United States (and vice versa) is unmistakable, the Iranian populace tends to hold positive views about American people, culture and values. It’s become almost cliche for American travelers to express surprise at the tremendous hospitality of Iranians toward Westerners in general and Americans in particular.

The admiration, curiosity and friendliness usually do not extend to the policies of the American government, however. From U.S. support for Saudi Arabia to President Trump’s ban on travelers from some Muslim nations, American policies don’t tend to get high approval ratings from the Iranian people. But just as Iranians make a distinction between themselves and their government, they do the same when it comes to America and Americans.

Originally published in The Washington Post

Media Availability: Experts Available to Discuss Iran Protests, Trump’s Iran Nuclear Deal Decision

FOR IMMEDIATE RELEASE

Trita Parsi, President, 202.386.2303, tparsi@niacouncil.org
Reza Marashi, Research Director, 206.383.9173, rmarashi@niacouncil.org
Jamal Abdi, Vice President of Policy, 206.369.2069, jabdi@niacouncil.org

MEDIA AVAILABILITY: Experts Available to Discuss Trump’s Iran Nuclear Deal Decision

Experts from the National Iranian American Council are available to discuss the protests in Iran and President Trump’s upcoming decision on whether or not to certify the Joint Comprehensive Plan of Action (JCPOA), or Iran nuclear deal. As Iran is gripped by the largest protests since the 2009 Green Movement, decisions made by President Trump could undermine the Iranian people’s demands for economic and social justice and spark a major security crisis in the Middle East.

Should Trump ignore the advice of his national security advisers and fail to extend sanctions waivers later this week, despite Iran’s continued compliance with the nuclear deal, he will put the U.S. into violation of the agreement’s terms and increase the risks of an Iranian nuclear weapon and war with Iran. Moreover, the Iranian government would seize upon U.S. violations to shift attention from its own failures to the bad faith of the United States.

The following experts at the National Iranian American Council are available to provide clear and nuanced analysis of the Iran protests, politics in Iran and President Trump’s upcoming decisions on the nuclear deal:

Trita Parsi: Trita is the 2010 recipient of the Grawemeyer Award for Ideas Improving World Order. He is the founder and president of the National Iranian American Council and an expert on civil rights and US-Iranian relations. Trita’s book, “Losing an Enemy” is considered the definitive book on Obama’s historic nuclear deal with Iran which focuses on Obama’s deeply considered strategy toward Iran’s nuclear program and reveals how the historic agreement of 2015 broke the persistent stalemate in negotiations that had blocked earlier effort.

Parsi’s articles have been published in the Wall Street Journal, New York Times, Los Angeles Times, Financial Times, Jane’s Intelligence Review, The Nation, The American Conservative, The Jerusalem Post, The Forward, and others. He is a frequent guest on CNN, PBS’s Newshour with Jim Lehrer,NPR, the BBC, and Al Jazeera. Follow Trita on Twitter: @tparsi

Recent analysis:

Watch Trita debate the Iran Protests with Bill Kristol on MSNBC: https://www.niacouncil.org/msnbc-interview-trita-parsi/

Watch Trita on MSNBC discussing Trump in Saudi Arabia: https://www.facebook.com/NIACouncil/videos/10155485192243938/

– America’s Relationship With Europe: Collateral Damage if Trump Kills the Iran Deal. The American Conservative

– Will Trump kill the Iran nuclear deal this week? China better watch out, South China Morning Post

There’s Something Different about these Iran Protests, CNN

These Are the Real Causes of the Iran Protests, The Nation

The Coming Crisis With Iran, New York Times

Reza Marashi: Reza joined NIAC in 2010 as the organization’s first Research Director. He came to NIAC after four years in the Office of Iranian Affairs at the U.S. Department of State, where he helped analyze the 2009 Green Movement for the U.S. government. Prior to his tenure at the State Department, he was an analyst at the Institute for National Strategic Studies (INSS) covering China-Middle East issues, and a Tehran-based private strategic consultant on Iranian political and economic risk. Marashi is frequently consulted by Western governments on Iran-related matters.

Reza’s articles have appeared in The New York Times, Foreign Affairs, Foreign Policy, and The Atlantic, among other publications. He has been a guest contributor to CNN, NPR, BBC, TIME Magazine, The Washington Post, and The Financial Times, among other broadcast outlets.

Recent analysis:

Watch Reza Marashi on CNN discussing the Iran protests here: http://edition.cnn.com/videos/tv/2017/12/30/exp-iranians-take-part-in-biggest-protests-since-1999.cnn

Watch Reza Marashi give his take on the Iran Nuclear Deal: https://www.facebook.com/NIACouncil/videos/10154909407473938/

– How Trump Could Use the Iran Protests to Kill the Nuke Deal, The Nation

Iran Protests: Civil Rights Movement Or Revolution?, Huffington Post

Trump and Israel Must Not Conflate North Korea Nuclear Threat With Iran, Haaretz

Jamal Abdi: Jamal is the Policy Director for the National Iranian American Council (NIAC) and the Executive Director of NIAC Action. He leads NIAC’s advocacy and education on civil rights and immigration issues, as well as diplomacy with Iran. He formerly served as Policy Advisor on foreign affairs, immigration, and defense issues in the U.S. Congress. Abdi has written for The New York Times, CNN, Foreign Policy, and blogs at The Huffington Post.  He is a frequent guest contributor in print, radio, and television, including appearances on Al Jazeera, NPR, and BBC News. Follow Jamal on Twitter: @jabdi

Recent Analysis:

Watch Jamal Abdi discuss the Iran nuclear deal on Al Jazeera: https://www.youtube.com/watch?v=889EPgBn5vk&feature=youtu.be

Trump Turns Terror Into Political Opportunity That Threatens Iranian Americans, The Iranian

Why Give Trump The Keys To War With Iran?, The Huffington Post

These Are the Real Causes of the Iran Protests

Trump’s threats to kill the nuclear deal have inhibited investment, leading to continued economic distress—but it was the Iranian government’s leaked budget that enraged the public.

When the Iranian protests broke out last Thursday, I immediately reached out to friends, family, and organizers of the Green movement that erupted after the 2009 stolen elections to find out what was going on. But almost everyone I spoke to gave me the same answer: We don’t know. We haven’t been able to piece it together yet. We are all confused.

But one person had quickly managed to put together the Persian puzzle: Donald Trump.

Although it took him days to figure out what was going on in Charlottesville, Iran was a piece of cake for America’s most unpresidential president. Since then, he has shot off half a dozen or so tweets purporting to support the protesters. In reality, however, the tweets seem more aimed at fanning the flames than aiding the demonstrators.

There is no evidence that the protesters in Iran are taking their cues from Trump—or even paying attention to him. Unlike the 2009 protests, when some of the demonstrators called on Barack Obama to speak out against the Iranian government’s brutal crackdown on peaceful protesters, no chants have been heard in Iran calling on Trump to do or say anything at all. Nor has any evidence emerged to substantiate the accusation that the protests were orchestrated from abroad.

Indeed, in the eyes of most Iranians, Trump has shown nothing but animosity toward the Iranian people since he took office. He imposed a Muslim ban on the Iranian people (even though no Iranian national has been involved in any lethal act of terrorism on US soil), while unreservedly hugging Iran’s regional rival and one of the main sources of Salafi terrorism, Saudi Arabia. He has continuously opposed and undermined the nuclear deal, which the Iranian people strongly support. He even blamed Iran instead of ISIS when that group conducted a terrorist attack in Iran that left 17 people dead.

But listened to or not, Trump has nevertheless contributed to the explosive mix of factors that gave birth to the Iranian protests.

Mindful of the ongoing political repression in Iran, widespread discontent with lack of political and social freedoms, as well as deep frustration and anger with corruption, economic mismanagement and inequality, the question that analysts wrestle with is: Why now? Clearly there have been decades of pent-up anger. But that still doesn’t explain why emotions boiled over now, and not a year ago.

The answer appears to lie in a few factors that have all come to a head in the past few weeks. Trump has figured prominently in the first factor: the economic dividends of the nuclear deal.

The Iranian people had high hopes for the nuclear deal. Not only did it prevent a war with the United States that appeared increasingly likely; they expected it to help break Iran out of its economic and political isolation. Iran is a young country, with a labor force that grows 2.5 percent annually and who will require roughly 3 million new job opportunities by 2020. And beyond jobs, Iran’s youth want to connect with the outside world and be part of the global community, rather than stand on the outside looking in.

On paper, the nuclear deal has paid economic dividends. Iran’s real GDP will expand by 3.8 percent in 2018, according to the IMF. But this growth is largely driven by oil sales, which increases the government’s coffers but does far less to benefit the private sector. More importantly, however, oil sales do not create jobs, which is a major problem, since unemployment rates among young people aged 15 to 29 is well over 24 percent.

Investments, however, do create jobs. To meet the needs of its growing labor force, Iran needs an estimated $150 billion in foreign investments. But those investments require financing from major banks, which in turn require confidence that the nuclear deal will endure, so that Iran does not once again come under US sanctions that would render such investments illegal.

And this is where Trump comes in. While banks have been hesitant to finance projects in Iran for a variety of reasons, including bureaucratic red tape in Iran, corruption, and concerns about the heavy-handed presence in the Iranian economy of the Islamic Revolutionary Guard Corps (IRGC), the primary barrier has been political uncertainty about the durability of the Iran deal. Banks are loath to begin financing investments, since they could see those projects fall under sanctions if (or once) Trump pulls the plug on the nuclear deal.

The never-ending drama about whether Trump will or will not kill the deal has been designed to achieve exactly this: create uncertainty about the deal’s future in order to deter investors from entering the Iranian market. This absence of investment, in turn, has contributed to growing unemployment and unmet expectations about the direction of the Iranian economy—an underlying cause of these protests.

If the nuclear deal and the sabotaged sanctions-relief process created unmet expectations, it was the government’s proposed 2018 budget that left the population seething. The leaked budget proposed slashing subsidies on basic goods, including food and services for the poor, while increasing fuel prices by as much as 50 percent. But while poor people would have to face austerity, opaque religious institutions controlled by conservative political elements would be spared from austerity cuts, as would the IRGC.

So when hard-liners in Mashhad tried to capitalize on the population’s growing frustrations by organizing a rally against centrist President Hassan Rouhani, they got more than they had bargained for. Spontaneous protests began erupting throughout the country, particularly in smaller cities, which also tend to be the hardest hit by the austerity measures. These crowds were not protesting just Rouhani, however, but rather the regime as a whole—up to and including Supreme Leader Ayatollah Ali Khamenei.

While poor people face austerity, opaque religious institutions controlled by conservative politicians will be spared from budget cuts, as will the IRGC.

Even though protests appear to have fizzled out over the past two days, the population’s anger and frustration will remain until the Rouhani government takes concrete steps to address the protesters’ legitimate grievances. While he can—and should—make changes to the budget, he has less control over the deeper problem of unemployment and the absence of foreign investment. And whatever difficulties Rouhani has had in convincing banks to finance investment thus far, he will face a far more challenging situation if Trump follows through on his promise to terminate the nuclear deal next week by not renewing sanctions waivers on Iran.

Precisely because Trump doesn’t care about the protesters and is more interested in destabilizing Iran and undoing anything and everything with Barack Obama’s name on it, he may well use the protests as a pretext to do what he has always intended to do: kill the nuclear deal.

The only deviation from Trump’s original plan could be that he will now pretend to do it out of love for the people of Iran.

Originally published in The Nation