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1. Let's be clear about what this report by @nwadhams + @SalehaMohsin describes.
Only a few of the 14 Iranian banks that may be targeted conduct a meaningful volume of international transactions. These payments are almost exclusively for food + medicine. https://www.bloomberg.com/news/articles/2020-09-28/trump-team-weighs-tough-new-sanctions-on-iran-s-financial-sector?sref=KhY5gfAd
Only a few of the 14 Iranian banks that may be targeted conduct a meaningful volume of international transactions. These payments are almost exclusively for food + medicine. https://www.bloomberg.com/news/articles/2020-09-28/trump-team-weighs-tough-new-sanctions-on-iran-s-financial-sector?sref=KhY5gfAd
2. @FDD is trying to push the Trump administration towards the ultimate scorched earth policy on Iran, precipitating food insecurity and a health crisis by directly interfering with Iran's ability to pay for food and medicine.
They have already targeted these imports indirectly.
They have already targeted these imports indirectly.
3. As Jonathan Saul reported for Reuters in July, the Trump admin has contributed to significant logjams in food imports by preventing Iran from using FX reserves for humanitarian trade, even though US sanctions have long had carveouts for this purpose. https://www.nasdaq.com/articles/insight-iran-struggles-to-buy-food-in-a-world-wary-of-touching-its-money-2020-07-30
4. The "maximum pressure" sanctions policy put forward by @mdubowitz is *expressly intended* to short circuit the humanitarian exemptions and licenses in US sanctions regulations.
5. In February, the @USTreasury made the unprecedented move to issue a comfort letter to a Swiss bank in order to launch SHTA, a humanitarian channel of its *own design.* They did so b/c previous designations had made exemptions impossible to interpret. https://www.bourseandbazaar.com/articles/2020/2/5/treasury-department-makes-unprecedented-iran-sanctions-move
6. Here is one thing the public should know and that journalists should be able to confirm. Many, if not most, of the civil servants at @USTreasury + @StateDept consider the Trump admin's sanctions policy to be misguided and harmful.
7. New sanctions designations are also increasingly spurious.
The idea that it is critical and urgent to suddenly target these 14 banks under a new terrorism-related designation makes little sense.
Have they become conduits for terrorist financing overnight? Of course not.
The idea that it is critical and urgent to suddenly target these 14 banks under a new terrorism-related designation makes little sense.
Have they become conduits for terrorist financing overnight? Of course not.
8. For the small number of banks among those 14 that do play a critical role in maintaining correspondent banking links with foreign financial institutions, staying "clean and compliant" has been an imperative since the Obama admin first levied financial sanctions in 2012.
9. The world's largest food commodities and pharmaceutical companies have continued transacting with these banks because they have been able to reliably conduct due diligence to ensure transactions are consistent with sanctions exemptions.
That doesn't change overnight.
That doesn't change overnight.
10. So why preview your plan to @nwadhams + @SalehaMohsin if it makes the designations seem flimsy?
One one hand it undermines the civil servants who can't push back in public.
On the other hand, it is likely intended to exacerbate the weakening of Iran's currency.
One one hand it undermines the civil servants who can't push back in public.
On the other hand, it is likely intended to exacerbate the weakening of Iran's currency.
11. A small group of political appointees and outside advisors have conspired to apply sanctions without regard for humanitarian consequences in Iran or damage to our relationships with transatlantic partners.
12. The only discernible goal has been to cause suffering.
Three years on and the Trump administration has *nothing* to show for its "maximum pressure" policy other than a marked increase in human misery in Iran.
Why are we pretending that is not the goal?
Three years on and the Trump administration has *nothing* to show for its "maximum pressure" policy other than a marked increase in human misery in Iran.
Why are we pretending that is not the goal?
