Fed Works With Prosecutors On Iran, Other Sanction Issues

August 7, 2012

Bloomberg on August 7, 2012 released the following:

“By Craig Torres

Federal Reserve Board spokeswoman Barbara Hagenbaugh said the central bank is working with prosecutors and the U.S. Treasury’s Office of Foreign Assets Control “on matters involving Iran and other sanctioned entities.”

“We cannot comment on ongoing investigations,” Hagenbaugh said by telephone. Hagenbaugh was responding to a query about accusations that Standard Chartered Plc violated U.S. money- laundering laws over its dealings with Iranian banks.”

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To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

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US should not continue to insist on sanctions against Iran

May 24, 2012

Global Post on May 24, 2012 released the following:

“Mansour Salsabili

Editor’s note: The writer, Mansour Salsabili, is on leave from Iran’s Ministry of Foreign Affairs. A senior political expert, he is a research fellow at Harvard Kennedy School’s Belfer Center for Science and International Affairs. He participated in a number of efforts ranging from UN reforms to the Non-Aligned Movement. The views expressed are entirely his own.

CAMBRIDGE, Massachusetts — Continuing to insist on sanctions against Iran will produce a bad deal for America.

Why? Because this week Iran is putting on the table in Baghdad a number of concrete and tension-reducing offers in response to the earlier requests of EU foreign policy chief Catherine Ashton.

These offers will have the strong support of Russia and China, and may attract positive votes from other European delegations as well. This will leave the US administration, which cannot force Congress to end sanctions, in the corner and in a passive position in any future talks.

In the second round of the current negotiation — between Iran and the five members of the UN Security Council plus Germany — any forward looking plan will need to be comprehensive, including all aspects of a final deal. However a comprehensive approach cannot be implemented in a single shot or in haste, but rather in a step-by-step process that produces concrete results for each step in turn. The final deal may commence from particular unresolved issues involving the Iranian nuclear program and then extend to more general questions of regional cooperation and even peace in the Middle East.

The success of the April 14 meeting in Istanbul between the six world powers and Iran was based on acceptance of the Non-Proliferation Treaty as a basic framework for the negotiation. The crucial point in this agreement is how to manage technical assurances to secure nonproliferation, without constraining Iran’s inalienable right to peaceful use of nuclear energy. This is possible only through mutual confidence building — something that was left in disarray in past efforts at negotiation.

The first way to secure mutual confidence is to avert confrontation to focus on collaboration: Cooperative and not confrontational behavior is needed to prepare a constructive, sustainable and encouraging environment. It is counter-productive to prejudge Iran as a proliferator and expect Tehran to cooperate. No one should expect Iran to sacrifice its sovereignty and its right to enrichment for peaceful nuclear uses in response to unsubstantiated allegations.

Here the vital task is clarifying and resolving in this case the inherent tension between the Non-Proliferation Treaty’s prohibition on proliferation and provision of the right to nuclear energy. This is not an easy job.

Concrete proposals need to be reciprocated to make progress not only possible, but also sustainable and irreversible. For this reason, the parties should address the issues that are most readily resolved first. A simultaneous swap of Iran’s stockpile of 20 percent enriched uranium for a similar amount of fuel for the Tehran Research Reactor could come first, to reduce any concern about proliferation and to increase mutual confidence.

In exchange, new sanctions on Iran’s oil industry and Central Bank must be eased, or at least postponed, until the next round of negotiation to pave the way for the realization of future steps.

Clearing up questions about past Iranian nuclear activity is the most difficult issue at hand. Its resolution requires a lot of trust on both sides. Confidence building through transparency and supervision by the International Atomic Energy Agency should go along with respect for confidentiality.

This subject is particularly sensitive in Iran because of incidents such as the assassinations of Iranian nuclear scientists during the past few years. Issues involving dual use technology are open to different interpretations, and must be treated as highly confidential. Resolution of these issues should come later in the process, as confidence increases.

In the meantime, fact-finding missions could continue to take place along the way as a step to verify that no previous military nuclear capability or undeclared facility in Iran now exists. To avoid prolonging such missions, let’s recall that other nuclear cases, such as Sweden’s, resolved with expanded additional protocol to secure the future rather than dig into the past.

”Every weapon is strongest before shooting,” is an old truism. Sanctions as the silver bullet of the West against Iran have already been fired and now it is time to compromise. Iran will adapt its economy and find its way around sanctions to gain access to the international community.

The passive US reaction to the current negotiations would result in a more polarized world and a loss to the United States and other struggling western economies as well.”

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

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To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

————————————————————–

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Obama Signs Executive Order Putting Tougher Sanctions on Iran

February 7, 2012

The Cypress Times on February 6, 2012 released the following:

“WASHINGTON, DC – Today, President Obama signed an Executive Order (E.O.) that takes a number of actions in furtherance of the Administration’s Iran sanctions program, including measures to implement section 1245 of the National Defense Authorization Act (NDAA). Among other things, the E.O. freezes all property of the Central Bank of Iran and all other Iranian financial institutions, as well as all property of the Government of Iran, further tightening the already broad-based and stringent U.S. sanctions on Iran.

These actions underscore the Administration’s resolve to hold the Iranian regime accountable for its failure to meet its international obligations. Iran now faces an unprecedented level of pressure due to intensified sanctions applied by the United States and complementary actions by many others around the world. The new E.O. issued today reemphasizes this Administration’s message to the Government of Iran – it will face ever-increasing economic and diplomatic pressure until it addresses the international community’s well-founded and well-documented concerns regarding the nature of its nuclear program.

Additional information describing the implementation of section 1245 of the NDAA pursuant to the authorities delegated under this E.O. will be made available in the near term.

Sanctions under the New Executive Order:

On February 5, President Obama signed a new E.O. effective at 12:01 a.m. on February 6, that blocks (i.e., “freezes”) all property of the Government of Iran as well as all property of Iranian financial institutions, including the Central Bank of Iran.

1. The E.O. blocks all property and interests in property of the Government of Iran, the Central Bank of Iran and all Iranian financial institutions (regardless of whether the financial institution is part of the Government of Iran) that are in the United States, that come within the United States, or that come within the possession or control of U.S. persons. Previously, U.S. persons were required to “reject,” rather than “block,” Iranian transactions.

  • Under the order, the Government of Iran, the Central Bank of Iran, and all Iranian financial institutions are now blocked (i.e. their assets within the jurisdiction of U.S. persons are frozen).
  • The U.S. sanctions in place since 1995 have required most transactions involving the Government of Iran, the Central Bank of Iran and all Iranian financial institutions to be rejected – that is, they could not pass through the U.S. financial system, but instead were turned back. Under the new E.O., transactions involving the Government of Iran, the Central Bank of Iran and all Iranian financial institutions that previously would have been rejected will now be blocked.
  • All entities that meet the existing definition of “Government of Iran,” such as Iranian ministries, state-owned entities and commercial firms owned or controlled by the Government of Iran, are blocked. This includes entities bearing the [IRAN] tag on the Treasury Department’s Office of Foreign Assets Control’s (OFAC) List of Specially Designated Nationals and Blocked Persons (SDN List). Transactions by U.S. persons involving such entities are now blocked unless exempt or otherwise authorized. OFAC will continue to update the SDN List and may add, delete, or edit existing entries as appropriate.
  • The E.O. does not change the sanctions that may be applied against foreign financial institutions engaging in arms-length transactions with certain Iranian financial institutions, including the Central Bank of Iran. Those foreign financial institutions remain at risk of U.S. sanctions if they engage in certain significant financial transactions with the Central Bank of Iran or certain other designated Iranian financial institutions pursuant to the NDAA, or the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).

2. Treasury is issuing general licenses to maintain existing authorizations for certain transactions that advance U.S. foreign policy interests.

  • Persons who currently use general or specific licenses from OFAC for transactions involving the Government of Iran or Iranian financial institutions should consult the OFAC website for new general licenses and other information on whether those transactions remain authorized under the new E.O.

Delegations of Authority under the New Executive Order:

The E.O. also delegates other authorities provided in section 1245(d) of the NDAA.

  • The E.O. delegates a number of other authorities provided in section 1245(d) of the NDAA, primarily to the Departments of the Treasury and State. These delegations will facilitate the implementation of section 1245 of the NDAA.
  • Additional information describing the implementation of the NDAA under these delegated authorities will be made available in the near term.”

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Douglas McNabb – McNabb Associates, P.C.’s
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To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


US levies new sanctions on Iran’s Central Bank

February 6, 2012

The Associated Press on February 6, 2012 released the following:

“By JULIE PACE
Associated Press

WASHINGTON (AP) — President Barack Obama has ordered new sanctions on the Islamic republic, including its Central Bank, in a move to enforce a law he signed in December.

In a letter to Congress Monday, Obama said the tougher sanctions are warranted “particularly in light of the deceptive practices of the Central Bank of Iran and other Iranian banks.” He said the problems included the hiding transactions of sanctioned parties, the deficiencies of Iran’s anti-money laundering regime and the unacceptably high risk posed to the entire international financial system posed by Iran’s activities.

The Central Bank sanctions were included as an amendment in the wide-ranging defense bill Obama signed into law at the end of 2011. The White House said Obama signed the executive order approving the sanctions on Sunday, well ahead of the six-month window he was afforded in the defense bill.

Obama’s fresh swipe at Tehran come as the White House tries to both ratchet up pressure on the Islamic republic to abandon its nuclear program and dissuade Israel from launching a unilateral strike on Iran, a move that could roil the Middle East and jolt the global economy.

Obama said Sunday he does not believe Israel has yet decided whether to attack Iran and still believes a diplomatic solution is possible.

Iran insists that its nuclear pursuit is for peaceful purposes, but the West accuses Iran of developing the know-how to build a nuclear bomb. Defense Secretary Leon Panetta last week would not dispute a report that he believes Israel may attack Iran this spring in an attempt to set back the Islamic republic’s nuclear program.

A Treasury Department statement said the sanctions underscore that the administration is determined to hold Iran accountable for meeting international obligations over its nuclear program. The statement said Iran should get the message that “it will face ever-increasing economic and diplomatic pressure” until it answers the world’s well-founded concerns about its nuclear intentions.

The department also said foreign financial institutions engaged in “arms-length transactions” with the Central Bank would not be impacted by the sanctions that Obama ordered Sunday, but remain at risk of such penalties if they undertake significant transactions with the bank or other Iranian financial institutions.

The sanctions amendment in the defense bill compelled U.S. punishment of foreign financial institutions that conduct transactions through Iran’s Central Bank in order to import petroleum. Several U.S. allies in Europe and Asia engage in such business with Iran.

The administration expressed concern at the time that the sanctions could lead to a spike in global oil prices, hampering the American economic recovery and perhaps perversely enabling Iran to reap even greater revenues from its oil exports. That would defeat the purpose of the bill, which is to hamper Tehran’s alleged support for international terrorism and its ability to fund its nuclear enrichment program.

Under the law, Obama had the option of waiving penalties for national security reasons.

The White House sees sanctions as an effective method of increasing pressure on Iran and officials say the penalties have started to squeeze Iran’s economy.

In recent weeks, both the U.S. and European Union have imposed harsher sanctions on Iran’s oil sector, the lifeblood of its economy.

In Washington, the Senate Banking Committee also easily approved yet more penalties on Tehran last week. The sweeping measure, which is not yet law, would target Iran’s Revolutionary Guard Corps, require companies that trade on the U.S. stock exchanges to disclose any Iran-related business to the Securities and Exchange Commission, and expand penalties for energy and uranium mining joint ventures with Tehran.”

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Douglas McNabb – McNabb Associates, P.C.’s
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To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


Enforcing existing sanctions on Iran

November 6, 2011

The Washington Times on November 4, 2011 released the following:

By Avi Jorisch -The Washington Times

“U.S. empowered to crack down on business with regime’s central bank

In recent years, the United States has imposed a punishing sanctions regime on Iran’s banking sector. To further increase Tehran’s level of financial pain, a great number of congressional and advocacy groups have repeatedly called on the White House to blacklist the Central Bank of Iran (CBI). Doing so, the thinking goes, would seriously hamper the Islamic republic’s ability to abuse international markets in its pursuit of nuclear weapons. Yet unbeknownst to most lawmakers and Washington policymakers, the U.S. Treasury actually hasblacklisted the CBI, and not once, but twice in recent years. The real question is why the U.S. government has not enforced its own sanctions regime.

The CBI has been accused of helping fund Iran’s nuclear weapons program, facilitate money transfers to terrorist organizations and proliferate weapons of mass destruction. The Treasury Department has publicly declared that between 2001 and 2006, the CBI facilitated a $50 million payment for Hezbollah. Treasury also has disclosed that the bank engaged in “deceptive practices,” including helping Iran’s Sepah and Melli banks, two financial institutions blacklisted by the United Nations, the European Union and United States for their role in facilitating illicit international transactions.

The United States maintains a number of “blacklists” sponsored by different agencies, including but not limited to the Departments of State, Treasury and Commerce. The Specially Designated Nationals (SDN) list is a broad compilation of persons and entities – a “list of lists” – administered by Treasury’s Office of Foreign Assets Control (OFAC). Those on the SDN list include not only persons and entities involved in terrorism, but also weapons proliferators, drug traffickers and those designated under country-specific sanctions programs.

Today, the SDN list has more than 6,000 entries, includingthe Central Bank of Iran. Unless specifically exempted, all U.S. persons and entities must block any property in which an SDN has an interest and report the action to OFAC. Blocked property may not be “transferred, withdrawn, exported, paid, or otherwise dealt in” without prior authorization from OFAC. If OFAC thinks a person or institution has violated the law, it has several options at its disposal, including cease-and-desist orders, civil penalties, suspension or revocation of licenses, and criminal charges.

The Treasury Department’s Web page clearly shows that the Central Bank of Iran appears on the SDN list of June 16, 2010, under the Iran country sanctions program. Treasury’s Financial Crimes Enforcement Network also took action against the CBI; in March 2008, it issued a banking advisory that fingered the bank for the “money laundering threat involving illicit Iranian activity.”

Treasury Secretary Timothy F. Geithner recently wrote to Congressthat “all options to increase the financial pressure on Iran are on the table, including the possibility of imposing additional sanctions against the CBI.” But the United States does not need new sanctions; it just needs to implement the existing regime, which could be a very potent tool for pursuing Iranian financial activity around the globe.

At this point, concerned parties should advocate a number of measures. The United States should ask banks that provide services of any kind to the Central Bank of Iran to cease doing so immediately. If they refuse to comply, the U.S. government should take immediate legal action in accordance with the PATRIOT Act and the U.S. Code, Title 18, Section 981, freezing any U.S.-based assets they hold and blocking their access to American markets.

Moving against the Central Bank would necessitate indirect action because the bank does not appear to possess assets in America. However, the U.S. government does have the power to freeze the funds deposited in a foreign bank on behalf of the Central Bank if the foreign bank maintains an account (known as an “interbank” or “correspondent account”) at a U.S. financial institution or has actual operations or property in the United States.

Washington should begin implementing the SDN as soon as possible. At a minimum, Treasury should designate one or a number of the biggest offenders among those engaging in business transactions with Iran’s Central Bank. This would likely cause many, if not most, of the companies and banks currently doing business with, or on behalf of, the Central Bank to cut their ties.

Policymakers in Washington are now keenly interested in imposing greater financial costs on the Iranian regime in an effort to derail its nuclear program. To do so, the need to target Iran’s Central Bank should be readily apparent. So, too, should the fact that levying real pressure on Iran’s most important economic construct is simply a matter of enacting already-existing restrictions and penalties. The Obama administration should do so without delay.”

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


Written Testimony of Under Secretary for Terrorism and Financial Intelligence David Cohen before the House Committee on Foreign Affairs

October 14, 2011

U.S. Department of the Treasury on October 14, 2011 released the following:

“Chairman Ros-Lehtinen, Ranking Member Berman, and distinguished members of the Committee: Thank you for the opportunity to appear before you today to discuss the Treasury Department’s efforts to implement and enforce Iran and Syria sanctions.

The focus of my testimony today will be the progress we are making in our financial strategies to increase pressure on the Iranian and the Syrian regimes. But first, I would like to say a few words about this week’s revelation that we disrupted an Iran Qods Force plot to assassinate the Saudi Ambassador here in Washington.

This is a dramatic reminder that the urgent and serious threat we face from Iran is not limited to Iran’s nuclear ambitions. We have been working for several years to address the full spectrum of Iranian illicit conduct, including nuclear and missile proliferation, human rights abuses, misuse of the international financial system and support for terrorist groups worldwide.

This week is no different. On Tuesday, Treasury imposed financial sanctions against five individuals, including the Commander of the Qods Force and three other senior Qods Force officers connected to the assassination plot. In taking this action, Treasury exposed the Iranian government’s involvement in the plot through the Qods Force, Iran’s primary arm for exporting terror.

And Wednesday, we took another action targeting Qods Force involvement in terrorist activities, this time by imposing sanctions on Mahan Air – Iran’s second largest airline – which was secretly ferrying operatives, weapons and funds on its flights for the Qods Force.

Actions like these, along with a raft of additional sanctions we have imposed on Iran over the past several months and years, have put increasing financial pressure on Iran in recent years.

CISADA has markedly amplified this effect. As we have explained to banks and governments in nearly 50 countries around the world, CISADA offers a clear choice: a foreign bank can have access to the largest and most important financial sector in the world – the United States – or it can do business with sanctioned Iranian banks, but it cannot do both. For the overwhelming majority of foreign banks, the choice has been a simple one. Those with potentially sanctionable relationships quickly elected to stop that business. And where we learn of potentially sanctionable activity under CISADA, we have actively investigated it.

Our efforts are paying off. Iran is now facing unprecedented levels of financial and commercial isolation. The number and quality of foreign banks willing to transact with designated Iranian financial institutions has dropped precipitously over the last year. Iran’s shrinking access to financial services and trade finance has made it extremely difficult for Iran to pay for imports and receive payment for exports. Iran’s Central Bank has been unable to halt the steady erosion in the value of its currency. And Iran has been increasingly unable to attract foreign investment, especially in its oil fields, leading to a projected loss of $14 billion a year in oil revenues through 2016.

Our efforts in Syria are also yielding results. Since the uprising in Syria began in March, President Obama has issued three new Executive Orders to establish sanction programs that have systematically escalated the financial pressure on the Asad regime. These U.S. sanctions – which target human rights abusers, block the assets of the Government of Syria, impose a import ban on Syrian petroleum products, and prohibit new investment in Syria – are intended to pressure Asad to relinquish power. Our efforts have been echoed by our European partners, who have established an embargo on Syrian oil and imposed financial sanctions targeting officials responsible for Syrian repression.

Echoing action that we have taken, just this morning the EU announced sanctions on the Commercial Bank of Syria, by far the largest bank in Syria, and its key link to the international financial system.

As a result of these sanctions, the Asad regime is struggling to find buyers for its oil, to access foreign currency, and to maintain economic stability. The IMF has revised its projections for the Syrian economy this year — from three percent growth to a two percent contraction – and predicts increasing pressure on Syria’s foreign currency reserves and ability to finance imports.

We are making progress, but there is still much to be done to prevent Iran and Syria from evading sanctions already in place and to take new steps to increase the pressure on these regimes. In the case of Iran, we continue to focus on the Central Bank of Iran (“the CBI”). Although U.S. financial institutions are already generally prohibited from doing business with any bank in Iran – including the CBI – further U.S. action against the CBI, if it attained multilateral support, could further isolate the CBI, with a potentially powerful impact on Iran. I can assure the Committee, as Secretary Geithner said in his letter of August 29, “All options to increase the financial pressure on Iran are on the table, including the possibility of imposing additional sanctions against the CBI.” We will also continue to work with governments in Europe, the Gulf, and elsewhere to impose financial measures that will ratchet up the pressure on Asad to step down.

If the Iranian and Syrian regimes continue to choose the path of defiance, we will continue to develop new and innovative ways to impose additional costs on them. I look forward to continuing our work with Congress to advance our national interests.”

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


Oral Testimony by Under Secretary for Terrorism and Financial Intelligence David S. Cohen before the Senate Banking Committee

October 13, 2011

U.S. Department of the Treasury on October 13, 2011 released the following:

“As Prepared for Delivery

Chairman Johnson, Ranking Member Shelby, and distinguished members of the Committee: Thank you for the opportunity to appear here today to discuss the Treasury Department’s contribution to the Obama Administration’s integrated strategy to address the threat posed by Iran’s nuclear program and its support for terrorism.

The focus of my testimony today will be the progress we are making in our financial strategy to pressure Iran, and, in particular, the steps we are taking to implement the financial provisions of CISADA.

But first, I would like to say a few words about this week’s revelation that we disrupted an Iran Qods Force plot to assassinate the Saudi Ambassador here in Washington.

This is a dramatic reminder that the urgent and serious threat we face from Iran is not limited to Iran’s nuclear ambitions. We have been working for several years to address the full spectrum of Iranian illicit conduct, including nuclear and missile proliferation, human rights abuses, misuse of the international financial system and support for terrorist groups worldwide.

This week is no different. On Tuesday, Treasury imposed financial sanctions against five individuals, including the Commander of the Qods Force and three other senior Qods Force officers connected to the assassination plot. In taking this action, Treasury exposed the Iranian government’s involvement in the plot through the Qods Force, Iran’s primary arm for exporting terror.

And just yesterday, we took another action targeting Qods Force involvement in terrorist activities, this time by imposing sanctions on Mahan Air – Iran’s second largest airline – which was secretly ferrying operatives, weapons and funds on its flights for the Qods Force.

This week’s actions follow on a series of recent steps taken by the Treasury Department to expose Iranian illicit behavior and ratchet up the pressure on Tehran. In the last few months, we have imposed sanctions on –

  • Tidewater, a major Iranian port operator owned by the IRGC;
  • Iran Air, Iran’s national airline, for supporting the IRGC;
  • an al Qa’ida network operating in Iran under an agreement with the Iranian government;
  • and individuals and entities involved in human rights abuses, both within Iran and supporting the Syrian government’s repression of the Syrian people.

Actions like these – along with international sanctions — have put increasing financial pressure on Iran, and CISADA has markedly amplified this effect. CISADA has helped us deepen and broaden Iran’s isolation from the international financial system. Since the President signed CISADA into law last July, my colleagues in the Treasury Department and I have worked aggressively to implement it. We have met with foreign banks, regulators and government officials in nearly 50 countries. We explain to banks and governments worldwide that CISADA offers a clear choice: a foreign bank can have access to the largest and most important financial sector in the world – the United States – or it can do business with sanctioned Iranian banks, but it cannot do both.

For the overwhelming majority of foreign banks, the choice has been a simple one. Those with potentially sanctionable relationships quickly elected to stop that business. And where we learn of potentially sanctionable activity under CISADA, we have actively investigated it, engaging in particular with foreign bank’s regulator and home government.

Our efforts are paying off. Iran is now facing unprecedented levels of financial and commercial isolation. The number and quality of foreign banks willing to transact with designated Iranian financial institutions has dropped precipitously over the last year. Iran’s shrinking access to financial services and trade finance has made it extremely difficult for Iran to pay for imports and receive payment for exports. Iran’s Central Bank has been unable to halt the steady erosion in the value of its currency.

And Iran has been increasingly unable to attract foreign investment, especially in its oil fields, leading to a projected loss of $14 billion a year in oil revenues through 2016.

We are making progress, but there is still much to be done to prevent Iran from evading sanctions already in place and to apply sufficient additional pressure on Iran. In this regard, we continue to focus on the Central Bank of Iran (“the CBI”). Although U.S. financial institutions are already generally prohibited from doing business with any bank in Iran – including the CBI – further U.S. action against the CBI, if it attained multilateral support, could further isolate the CBI, with a potentially powerful impact on Iran. I can assure the Committee, as Secretary Geithner said in his letter of August 29, “All options to increase the financial pressure on Iran are on the table, including the possibility of imposing additional sanctions against the CBI.”

If Iran continues to choose its path of defiance, we will continue to develop new and innovative ways to impose additional costs on Iran. I look forward to continuing our work with Congress to advance our national interests.”

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.