14 Items

Secretary of State Mike Pompeo and Secretary of the Treasury Steve Mnuchin provide an update on the Trump administration's Iran policy at the Foreign Press Center in Washington, D.C., on November 5, 2018 (State Department via Flickr).

State Department via Flickr

Analysis & Opinions - Bulletin of the Atomic Scientists

Not very SWIFT

| Nov. 06, 2018

Not only would sanctioning SWIFT be a major escalation in U.S. sanctions policy, but an entirely reckless decision. Realistically, enforcing sanctions against SWIFT would have significant consequences for both the U.S. and global financial system—upending decades of international norms.

A stack of Iranian rials and a stack of Euros (Ivar Husevåg Døskeland via Flickr/Creative Commons).

Ivar Husevåg Døskeland via Flickr/Creative Commons

Analysis & Opinions - Bulletin of the Atomic Scientists

International Anti-Money Laundering Reforms and Iran

| Nov. 06, 2018

Although it remains to be seen whether or not the Iran nuclear deal is salvageable, there are few incentives left for Iran to implement anti-money laundering reforms. For better or worse, the Financial Action Task Force and the future of the JCPOA have become politically intertwined as a consequence of US unilateral sanctions.

Blogtrepreneur/Flickr

Blogtrepreneur/Flickr

Journal Article - Nonproliferation Review

Solving the Jurisdictional Conundrum: How U.S. Enforcement Agencies Target Overseas Illicit Procurement Networks Using Civil Courts

| September 2018

Over the past two decades, the United States has increasingly turned to targeted sanctions and export restrictions, such as those imposed against Iran and North Korea, in order to curb the spread of weapons of mass destruction. One vexing problem, however, is how to contend with jurisdictional hurdles when the violations occur overseas, in countries that are unable or unwilling to assist US enforcement efforts. To solve this problem, US prosecutors are turning to strategies with significant extraterritorial implications—that is, exercising legal authority beyond national borders. One such tool is to use civil legal procedures to seize assets linked to sanctions or export-control violations in jurisdictions that lack cooperative arrangements with US enforcement agencies. While this may be an attractive strategy to bolster enforcement efforts against overseas illicit procurement, using such tools is not without consequence. This article explores the political, legal, and technical implications of enforcing extraterritorial controls against overseas non-state actors by exploring the recent uses of civil-asset forfeiture against Iranian and North Korean procurement networks.

Two-thousand rials

DAVID HOLT/Flickr

Analysis & Opinions - Bulletin of the Atomic Scientists

Will Anti-Money Laundering Reform in Iran Matter?

| Sep. 14, 2018

Next month, the Financial Action Task Force (FATF)—an intergovernmental body that sets and promotes worldwide anti-money laundering standards—will make a key decision on whether or not to lift Iran’s probationary status or place the country back on its blacklist. If put back onto the blacklist, member states would be asked to employ financial countermeasures that range from requiring extra scrutiny of Iranian-linked accounts to shutting down certain types of banking networks.

Secretary of State Mike Pompeo speaks at the Heritage Foundation, a conservative public policy think tank, in Washington on May 21, 2018. Pompeo issued a steep list of demands Monday that he said should be included in a nuclear treaty with Iran to replace the Obama-era deal, threatening "the strongest sanctions in history" if Iran doesn't change course (J. Scott Applewhite/Associated Press).

J. Scott Applewhite/Associated Press

Analysis & Opinions - The Hill

Congress Must Manage the Consequences of the Withdrawal From the Iran Nuclear Deal

| May 22, 2018

President Trump’s decision to withdraw from the nuclear agreement with Iran will undermine U.S. power and influence around the world. Congress must closely monitor the reinstatement of sanctions on Iran to reduce the blowback on U.S economic interests, and provide strict oversight of the Trump administration’s evolving strategy toward Iran.

From left, European Union foreign policy chief Federica Mogherini, Iranian Foreign Minister Javad Zarif, French Foreign Minister Jean-Yves Le Drian, German Foreign Minister Heiko Maas and British Foreign Secretary Boris Johnson pose for a photo during a meeting at the Europa building in Brussels. May 15, 2018 (Olivier Matthys/Associated Press, Pool).

Olivier Matthys/Associated Press, Pool

Analysis & Opinions - Bulletin of the Atomic Scientists

The Iran Deal is a Done Deal

| May 16, 2018

So far, there seems to be a strong lobby in favor of protecting EU business interests in Iran by proposing sanctions-blocking measures to guard against US secondary sanctions. Ultimately, however, it will be business, not political decisions, that will spell the end of the JCPOA— a lesson almost learned in 1982.

President Donald Trump makes a statement on Iran policy in the Diplomatic Reception Room of the White House in Washington. October 13, 2017 (Evan Vucci/Associated Press, File).

Evan Vucci/Associated Press, File

Analysis & Opinions - The Boston Globe

How Trump Can Fix the Iran Nuclear Deal

| May 07, 2018

President Trump faces a fateful deadline on May 12: to decide whether to keep waiving nuclear-related sanctions on Iran or to rip up the Iran nuclear deal. Fortunately, there is a path that would allow him to fix many of the problems he sees with the deal while keeping Iran hemmed in by the deal’s restraints.

President Donald Trump and French President Emmanuel Macron hold hands during a State Arrival Ceremony on the South Lawn of the White House. April 24, 2018 (Andrew Harnik/Associated Press).

Andrew Harnik/Associated Press

Analysis & Opinions - Al-Monitor

Why Europe Could End Up Being Blamed for Nuclear Deal Collapse

| May 07, 2018

The recent visits to Washington by French President Emmanuel Macron and German Chancellor Angela Merkel were in all likelihood the last chance for Europeans to convince President Donald Trump not to withdraw from the Iran nuclear deal. With prospects for winning over Trump fading as the May 12 deadline for sanctions waivers approaches, one might argue that US allies in Europe have lost sight of the prize in the process of appeasing him. Indeed, rather than exclusively focusing on addressing Trump’s stated concerns about the deal, which probably cannot be satisfied anyway, France, Germany and the UK, known as the E3, would serve their interests better by laying out alternative strategies for protecting trade between Iran and the European Union should the United States withdraw.