Yes, Secretary Mattis, there IS a Land Bridge

So, all terror roads in the Middle East still lead to Tehran. At the direction of Tehran, Hezbollah, the Iranian militias and the Iranian Revolutionary Guard Corp operations is selection regions across the globe with wild abandon.

January 2018, in a question and answer session: Q: On Iran’s role in Iraq and Syria, do you believe that a land bridge exists between Iran and Syria through Iraq? And, if so, are you concerned about it? Is there anything the United States can do about it?

SEC. MATTIS: No, I don’t — I don’t think there’s a land bridge right now. There’s still enough rough times — you know, rough terrain, rough enemy units that haven’t been cleaned up, and all the usual cleanup going on, and — plus you’ve got the combination of where the people we’re fighting — advising and that sort of thing in Syria are abutting, in some cases, the Russian forces who are helping the regime, abutting the Turkish elements. There’s — I don’t think there’s a land bridge right now.

*** So, while the United States along with France and Britain delivered 105 missiles to take out three chemical weapons locations in Syria, other locations remain in addition to the Assad air assets. Russia, North Korea, and Tehran were all watching for weeks the actions of the West. Russia declares the most recent chemical weapons attack was at the hand of the White Helmets, then it was a ploy by Britain, then it was a CIA operation. Meanwhile, the chemical weapons inspection envoy arriving in Douma, the suburb of Damascus had to find cover after being fired upon.

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That brings us back to domestic threats and the strategy as developed by the Trump administration in dealing with Iran and Russia, much less Iraq. Is there one other than the threat of exiting the JCPOA? Not so far it seems. The increasing threat? Satellite land bridges perhaps….from Latin America to covert cells across our homeland.

***

Iranian-backed militants are operating across the United States mostly unfettered, raising concerns in Congress and among regional experts that these “sleeper cell” agents are poised to launch a large-scale attack on the American homeland, according to testimony before lawmakers.

Iranian agents tied to the terror group Hezbollah have already been discovered in the United States plotting attacks, giving rise to fears that Tehran could order a strike inside America should tensions between the Trump administration and Islamic Republic reach a boiling point.

Intelligence officials and former White House officials confirmed to Congress on Tuesday that such an attack is not only plausible, but relatively easy for Iran to carry out at a time when the Trump administration is considering abandoning the landmark nuclear deal and reapplying sanctions on Tehran.

There is mounting evidence that Iran poses “a direct threat to the homeland,” according to Rep. Peter King (R., N.Y.), a member of the House Homeland Security Committee and chair of its subcommittee on counterterrorism and intelligence.

A chief concern is “Iranian support for Hezbollah, which is active in the Middle East, Latin America, and here in the U.S., where Hezbollah operatives have been arrested for activities conducted in our own country,” King said, referring the recent arrest of two individuals plotting terror attacks in New York City and Michigan.

“Both individuals received significant weapons training from Hezbollah,” King said. “It is clear Hezbollah has the will and capability.”

After more than a decade of receiving intelligence briefs, King said he has concluded that “Hezbollah is probably the most experienced and professional terrorist organization in the world,” even more so than ISIS and Al Qaeda.

Asked if Iran could use Hezbollah to conduct strikes on the United States, a panel of experts including intelligence officials and former White House insiders responded in the affirmative.

“They are as good or better at explosive devices than ISIS, they are better at assassinations and developing assassination cells,” said Michael Pregent, a former intelligence officer who worked to counter Iranian influence in the region. “They’re better at targeting, better at looking at things,” and they can outsource attacks to Hezbollah.

“Hezbollah is smart,” Pregent said. “They’re very good at keeping their communications secure, keeping their operational security secure, and, again, from a high profile attack perspective, they’d be good at improvised explosive devices.”

Others testifying before Congress agreed with this assessment.

“The answer is absolutely. We do face a threat,” said Emanuele Ottolenghi, a senior fellow at the Foundation for Defense of Democracies who has long tracked Iran’s militant efforts. “Their networks are present in the Untied States.”

Iran is believed to have an auxiliary fighting force or around 200,000 militants spread across the Middle East, according to Nader Uskowi, a onetime policy adviser to U.S. Central Command and current visiting fellow at the Washington Institute for Near East Policy.

At least 50 to 60 thousand of these militants are “battle tested” in Syria and elsewhere.

“It doesn’t take many of them to penetrate this country and be a major threat,” Uskowi said. “They can pose a major threat to our homeland.”

While Iran is currently more motivated to use its proxies such as Hezbollah regionally for attacks against Israel or U.S. forces, “those sleeper cells” positioned in the United States could be used to orchestrate an attack, according to Brian Katulis, a former member of the White House National Security Council under President Bill Clinton.

“The potential is there, but the movement’s center of focus is in the region,” said Katulis, a senior fellow at the Center for American Progress.

Among the most pressing threats to the U.S. homeland is Hezbollah’s deep penetration throughout Latin America, where it finances its terror activities by teaming up with drug cartels and crime syndicates.

“Iran’s proxy terror networks in Latin America are run by Tehran’s wholly owned Lebanese franchise Hezbollah,” according to Ottolenghi. “These networks are equal part crime and terror” and have the ability to provide funding and logistics to militant fighters.

“Their presence in Latin America must be viewed as a forward operating base against America’s interest in the region and the homeland itself,” he said.

These Hezbollah operatives exploit loopholes in the U.S. immigration system to enter America under the guise of legitimate business.

Operatives working for Hezbollah and Iran use the United States “as a staging ground for trade-based and real estate-based money laundering.” They “come in through the front door with a legitimate passport and a credible business cover story,” Ottolenghi said.

The matter is further complicated by Iran’s presence in Syria, where it has established not only operating bases, but also weapons factories that have fueled Hezbollah’s and Hamas’s war on Israel.

Iran’s development of advanced ballistic missile and rocket technology—which has continued virtually unimpeded since the nuclear deal was enacted—has benefitted terror groups such as Hezbollah.

“Iran is increasing Hezbollah’s capability to target Israel with more advanced and precision guided rockets and missiles,” according to Pregent. “These missiles are being developed in Syria under the protection of Syrian and Russian air defense networks.”

In Iraq, Iranian forces “have access to U.S. funds and equipment in the Iraqi Ministry of Defense and Iraq’s Ministry of Interior,” Pregent said.

The Trump administration has offered tough talk on Iran, but failed to take adequate action to dismantle its terror networks across the Middle East, as well as in Latin American and the United States itself, according to CAP’s Katulis.

“The Trump administration has talked a good game and has had strong rhetoric, but I would categorize its approach vis-à-vis Iran as one of passive appeasement,” said Katulis. “We simply have not shown up in a meaningful way.”

How Israel Protects Schools

 

SCHOOL SECURITY IN ISRAEL

By: Michael Csere, Legislative Fellow

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What steps Israel has taken to protect its public schools and university students from terrorist attacks and gun violence? Granted, Israel is smaller and has a vast number of terror threats as compared to the United States, however security there is a duty of just about every citizen.

SUMMARY

Our research indicates that Israel has taken a number of steps to protect schools and students from terrorist attacks and gun violence, with a greater emphasis on the former.

Israeli law currently requires a guard in schools of 100 or more students. These guards are generally employed by private security companies, while the Israel Police (the country’s civilian police force) have overall responsibility for guidance, oversight, and control for the entire security system of educational institutions, from kindergartens through universities. The law permits certain individuals to carry firearms in schools.

There has been considerable controversy over the law’s funding and implementation, including criticism of the expertise and capability of the guards. While not required to have them, some schools, notably smaller ones, have experienced difficulty funding security guards.

Additionally, the Israeli Ministry of Education has provided funding to (1) construct shelters and fences, (2) add reinforced protection to school buses, (3) hire and train security guards, and (4) provide professional psychological care to treat students’ emotional reactions to terrorist attacks. Armed security guards sometimes accompany students on field trips, although it is unclear whether this is currently mandated or how frequently it occurs.

The Ministry has also collaborated with the Israel Police to provide security awareness training elementary-age students. And at least one high school has adopted its own security protocols.

ISRAELI LAW

Security Guards

According to officials at the U.S. Embassy in Jerusalem and the Israeli Embassy in Washington, D.C., Israeli law currently requires educational institutions with more than 100 students to post a guard. The Security and Emergency Department within the Israel Police has the overall responsibility to provide security for all schools and surrounding areas, while the guards actually stationed at the schools are generally employed by private security companies working with local authorities. The principal of each school oversees the specific security arrangements, and must appoint a designated security aide to assist with these arrangements.

By law, the guard must check the school site 30 minutes before school starts. He or she then checks people and vehicles entering the school and can permit or refuse entry to unauthorized people. The guard is generally stationed at the school entrance and is responsible for security outside the school (but not internal security issues, like fights between students). In the event of actual hostile activity (essentially terrorist in nature), the guard must engage with the attacker or attackers.

In the last Knesset (the Israeli legislature), a bill was introduced authorizing guards to intervene in certain cases inside schools. This was in response to a perceived rise in non-terror-related violent incidents in schools (i.e., fights between students). The proposal failed.

Authorization to Carry Firearms in Schools

The law permits the following people to carry firearms in schools:

  1. the guards (provided they are the security company’s property and not their own weapons),
  2. authorized Education Ministry personnel using ministry firearms,
  3. the police, and
  4. the army.

According to the U.S. and Israeli embassies, the lawful purposes for carrying firearms are to (1) protect school personnel and students, (2) create a sense of security, (3) deter the ill-intentioned, and (4) provide self-defense. The guard must possess a valid license to carry guns issued by the Ministry of Public Security and the Israel Police. The qualifications of the license holder normally include a high school diploma, clean record, and weapons training. Additionally, strict protocols and guidance exist regarding carrying a weapon and the types of weapons that can be carried.

IMPLEMENTATION AND CONTROVERSY

According to an Israeli Embassy official, the security apparatus for each educational institution is determined by the threat level for that particular institution. For instance, there is a difference in specific security arrangements between institutions near the Green Line (the demarcation lines set out in the 1949 Armistice agreements between Israel and its neighbors), those in cities with mixed populations, and those in cities near conflict zones (i.e., the northern and southern borders). Most of the institutions have fences, cameras, and an armed security guard stationed at the school entrance.

The Israel Police create a file for each institution, which includes the number of students and staff, phones, means of communication, and private security companies that work with the school. The Police also visit and inspect schools, and make daily contact with civilian security companies. The Police inspect and train private security companies, and provide guidance to local government security officers.

Professor Gerald Steinberg, a professor of Political Science at Bar-Ilan University in Israel and the Executive Director of NGO Monitor (an organization that provides information and analysis on the activities of non-governmental organizations), noted that the specific response to terrorist attacks and gun violence varies by school. While armed guards, police, or soldiers are stationed at some schools, in less threatened areas unarmed guards or parents are stationed at the school’s entrance to check for unauthorized people and suspicious packages. Professor Steinberg also noted that cameras are used in some schools, and in his opinion, provide only a minor deterrent. He further asserted that the greater threat of attacks in Israel comes from Palestinian and allied terrorists living outside Israel’s borders rather than domestic threats, thus schools are defended on that basis. In fact, he stated, Israelis have used weapons in domestic conflicts in very few cases.

The U.S. Embassy official noted several areas of controversy over the posting of security guards in schools. For example, the actions and competence of the guards have been criticized, and there have been arguments over funding.

As noted above, the guards are generally private security company employees. Local police refuse to guard schools themselves: for professional reasons, they regard it as a waste of manpower and prefer to use roving car patrols and intelligence activities to protect the educational institutions. The guards themselves have been criticized: they are not highly paid (frequently earning close to minimum wage), leading some to question their ability to repel a determined attacker. Also, a few guards have used their company guns to pursue inappropriate or illegal matters, which has drawn further criticism. For example, in one case, a guard was tried for manslaughter after shooting dead an electrical repair technician who tried to get into a school by climbing over a fence..

Additionally, disputes have arisen between the finance ministry, local authorities, the Ministry for Internal Security (oversees the Israel Police), and the Education Ministry as to who should pay for the guards. Because certain minimum student enrollment is required to qualify for government funding for security needs, a number of smaller schools have had difficulty paying for security guards. In response, the United Jewish Communities’ Israel Emergency Campaign and various Jewish communities abroad have raised money to provide security at smaller schools.

OTHER SECURITY MEASURES

The Ministry of Education, together with the Israel Police’s Community & Civil Guard Department, designed and implemented a preventive care program for elementary schools called “Elementary Security.” The program aims to encourage safe behavior and prevent all forms of violence through a series of classroom lessons taught by a community police officer in conjunction with the teacher. It focuses on the role of police officers, forms of violence, and safe behavior.

The Eisendrath International Exchange High School in Israel reports that it has taken the following safety and security measures to protect students:

  1. daily review of itineraries and changes as needed to provide the highest level of security,
  2. daily consultations with the security department of the Jewish Agency for Israel,
  3. no travel through Palestinian controlled areas of the West Bank or Gaza Strip,
  4. use of the school’s own chartered buses rather than public transportation,
  5. Israeli-trained security guard traveling with each group on a daily basis,
  6. orientation for staff and participants including safety and security procedures and protocols, and
  7. contingency plans to move groups to safety or bring groups home if necessary.

SOURCES

Eisendrath International Exchange High School in Israel, Safety and Securityhttp://www.nftyeie.org/experience/security/, last visited on February 4, 2013.

Israel Ministry of Education, The Israeli Education System Strives to Protect Its Schools and Students from Terrorhttp://www.education.gov.il/children/page_54.htm, last visited on February 4, 2013.

Israel Ministry of Public Security, Elementary Security: Learning About Crime Preventionhttp://mops.gov.il/Documents/Publications/InformationCenter/Innovation%20Exchange/Innovation%20Exchange%2013/ElementarycrimeStudying.pdf, last visited on February 4, 2013.

The Jewish Agency for Israel, Safety of Children a Top Priorityhttp://www.jewishagency.org/JewishAgency/English/About/Press+Room/Jewish+Agency+In+The+News/2002/expdec11.htm+1.htm, last visited on February 4, 2013.

Iran’s Supreme Leader, the Nuclear Deal, Protests and Boeing

It is the conglomerate that the Supreme Leader, the Ayatollah Khamenei owns exclusively. “Setad Ejraiye Farmane Hazrate Emam,” or Setad.

Image result for Setad Ejraiye Farmane Hazrate Emam

Setad was originally sanctioned by the U.S. Treasury in June 2013. The conglomerate “produces billions of dollars in profits for the Iranian regime each year,” said David Cohen, then the Treasury’s under secretary for terrorism and financial intelligence, at a Senate banking committee hearing that year.

Setad, Cohen said at the time, controls “massive off-the-books investments” hidden from the Iranian people and regulators.

All entities sanctioned for being part of the Iranian government are being taken off the SDN list as part of the nuclear deal, also called the Joint Comprehensive Plan of Action (JCPOA), though U.S. persons and entities will still be banned from dealing with them.

In January of 2017, a review by Reuters noted: But a Reuters review of business accords reached since then shows that the Iranian winners so far are mostly companies owned or controlled by the state, including Iran’s Supreme Leader, Ayatollah Ali Khamenei.

Of nearly 110 agreements worth at least $80 billion that have been struck since the deal was reached in July 2015, 90 have been with companies owned or controlled by Iranian state entities, the Reuters analysis shows.

In December of 2017: Treasury Department officials must publish a report chronicling the financial assets of Iran’s top leaders, under a bill that passed the House on Wednesday.

The legislation, which passed 289-135, must still clear the Senate before President Trump can sign it into law. It’s a potential boon to Iranian dissidents against the regime, who stand to gain insight into corruption by top officials.

Related:

Podcast – Upheaval in Iran: Causes and Consequences

Meanwhile, as the protests continue in Iran against the regime and rightly so, questions arise due to not only Senate votes on sanctions but staying with the Joint Comprehensive Plan of Action, meaning the Iran nuclear deal.

Image result for Setad Ejraiye Farmane Hazrate Emam photo

Why is there even a question based on additional facts surfacing in the last year? Well, the left and those that remain with John Kerry and Barack Obama are adding new pressures to stay in the JCPOA. Further, complications arise from those countries that are also part of the deal. They too want the deal sustained.

In a story titled “U.S. security experts back Iran nuclear deal, as Trump faces deadlines,” Reuters reports that a coalition of national security experts want the president to continue the Iran deal. The report claims, without any context, that all of the people who signed a letter in favor of the deal are “national security experts.” Additionally, these “experts” are from an organization called the “National Coalition to Prevent an Iranian Nuclear Weapon.”

It turns out, however, that some of those listed on the document have severe conflicts of interests, none of which were disclosed in the letter.

It also turns out that the National Coalition to Prevent an Iranian Nuclear Weapon is not an actual organization. A Google search of the group turned up nothing before Monday. The group was created this week with the apparent purpose of garnering support for the nuclear deal. None of this is reported in the Reuters article. It is only revealed through the group’s statement provided on The National Interest website.

The outfit’s title also presumes its members are national security hawks, when this is far from the case.

Members of the “National Coalition” include a who’s who of the prominent organizers of the campaign to rally support for the Obama administration’s nuclear deal with Tehran.

Included on the list is Joseph Cirincione, who served as the money man for President Obama’s Iran “echo chamber.” Cirincione has admitted to paying off a “network of 85 organizations and 200 individuals” who were “decisive in the battle for public opinion” over the Iran deal.

Gary Sick, another signee, was one of the chief organizers of the Iran echo chamber. According to the Washington Free Beacon, Sick created an invite-only listserv to distribute pro-Tehran talking points to Obama-friendly journalists and influential figures.

The coalition also includes Ambassador Thomas Pickering, who is a paid lobbyist for Boeing. The aviation company is attempting to secure a multi-billion-dollar jetliner deal with the Iranian regime. If the Iran deal falls through, so does Boeing’s deal.

Paul Pillar, a disgraced former CIA officer who was also on the letter, once drafted talking points arguing that it’s not a big deal if Iran is able to develop a nuclear weapon. “If Iran develops a nuclear weapon, the United States and the West could live with it, without important compromise to U.S. interests,” he wrote, according to Eli Lake of Bloomberg News.

It remains a mystery what President Trump will decide this time around. He has been troubled by Iran’s violent response to countrywide protests. The president has leveraged social media and several executive departments to raise awareness about the plight of Iranian protesters. He has also mulled enacting further sanctions against the regime.

As an aside, there too is pressure from Boeing, they want to protect the sale agreements of planes to Iran such that they have offered to ‘finance’ the payments, essentially layaway. Iran is looking for a method to make payments of $44B to both Air Bus and Boeing. Humm….but that Supreme leader has a major conglomerate remember?

 

 

UNRWA De-Funded by the United States, Finally, Sorta

Primer: April – August 1948: More than 700,000 Palestine refugees are displaced as a result of the Arab-Israeli War. Per the United Nations Relief and Works Agency website. So, we have a generational refugee condition, where they are refugees in essentially their own land…let that sink in.

UNRWA human development and humanitarian services encompass primary and vocational education, primary health care, relief and social services, infrastructure and camp improvement, microfinance and emergency response, including in situations of armed conflict.

Bleh…..after 70 years….it still has to be funded? Did you catch that set of words ‘armed conflict’? Even the left leaning Huffington Post agrees, the Palestinians DON’T want peace.

The Palestinians not only have rejected one offer after another for a peaceful settlement in the past nearly 70 years, but also, tragically, their misguided actions now make any chance of an accord going forward still less likely.

Friday’s UN Security Council resolution is a case in point.

If the goal was to increase the chance of Palestinian statehood alongside Israel (and not in its place!), it was an abysmal failure, despite the lopsided vote. Those diplomats who rushed to applaud the outcome – and I’ll set aside thuggish countries like Venezuela that don’t bring a shred of good will to the UN table – should think twice about what they actually achieved.

If they wanted to excoriate Israel, a longstanding vocation of too many UN member states, then they can thump their chests, even if, alas, they habitually reserve such scrutiny for the only democratic nation in the Middle East. But for those truly committed to advancing prospects for peace, they took a big step backwards, once again falling into the Palestinian trap.

*** The Palestinians have a capital it is called Ramallah. Image result for ramallah palestinians

And Israel has a capital, Jerusalem. Image result for jerusalem photo

The Palestinians want peace, just not with Jews.

So, when the United States suspended funding to UNRWA….it was not all the funding, don’t be fooled. The United States gives an estimated $390,000,000 to UNRWA each year. Add that to the collection of other nations’ contributions and UNRWA is hardly out of business.

The United States administration froze a $125 million grant to the United Nations Relief and Works Agency (UNRWA), the UN’s agency for “Palestinian refugees”, which was supposed to be delivered on January 1, Channel 10 News reported on Friday, citing three Western diplomats.

The amount frozen is one-third of the annual funding the United States provides the organization, according to the report.

The three diplomats, who asked to remain anonymous because of the political sensitivity of the issue, told Channel 10 the grant had been frozen until the end of the reexamination of U.S. aid to the Palestinians, which began in recent days. According to the diplomats, officials in the administration have informed UN officials in the past two days that President Donald Trump is considering cutting this amount completely and could even increase the cut to $180 million, which would be half the total U.S. funding for UNRWA.

The cutting in the UN funding to UNRWA is a U.S. sanction against the organization, which has come under strong criticized from both the United States and Israel, as well as against the Palestinian Arabs, in an attempt to pressure them to renew peace talks with Israel.

News of the freezing of the grant came as a meeting took place in the White House discussing the cutting of aid to the Palestinian Authority and to UNRWA.

The meeting followed Trump’s tweets earlier this week in which he expressed doubt over the usefulness of American aid to the Palestinians, given their refusal to resume peace talks with Israel.

The United States is the largest single donor to UNRWA, providing approximately a fourth of the organization’s budget.

Reports in Israel on Thursday indicated that the Israeli Foreign Ministry is opposed to Trump’s planned cut in the aid to UNRWA, but on Friday Jewish Home chairman Naftali Bennett said that cutting aid to UNRWA is the correct move.

For years, UNRWA has been a target for criticism in light of Hamas’s activity in its educational institutions and the use of its facilities by Palestinian Arab terrorist organizations in Gaza.

UNRWA was documented storing Hamas rockets and weapons “designed to kill Israeli citizens” in its schools, a fact which the UNRWA chief admitted himself.

In addition, the organization has actively taken part in inciting anti-Semitic violence.

By the way, it is called a global diaspora regarding where and how many Palestinians live across the globe.

The countries outside the Palestinian territories with significant Palestinian populations are:

Iran/Turkey Evade Sanctions Work, Guilty and DC

If you think you can describe relationships and motivations globally and the connective tissue into Washington DC….you may need to think again.

This particular legal case decided yesterday has the makings of an HBO television documentary that includes past and present political power-brokers. We have Trump, Giuliani, Flynn, Obama, FBI, Justice, Iran, Turkey, lobbyists and even some violence.

What did the Obama administration know and why did they know it, then what?

Primer:

May 2017: MIAMI — President Donald Trump’s longtime Florida lobbyist, Brian Ballard, has expanded his practice globally and just signed a $1.5 million contract with the government of Turkey, which will be represented by the firm’s new big hire, former Florida Congressman Robert Wexler.

Ballard Partners’ Turkey contract, inked Friday, comes on the heels of two other international clients signed by the firm: A March 6 $900,000 contract with the Dominican Republic and an April 1 $240,000 contract with the Socialist Party of Albania, the ruling party in the Balkan nation. More here.

For a current list of clients for Ballard Partners, go here.

***

Just the facts and the case of GOLD below, while several are still at large.

Enter the good guys, outside of government who perform remarkable and respected investigative work.

The Biggest Sanctions-Evasion Scheme in Recent History

And the swashbuckling gold trader at its center

SchanzerYesterday, Turkish banker Mehmet Hakan Atilla was found guilty in a Manhattan courtroom for a range of financial crimes. His dramatic trial revealed that tens of billions in dollars and gold moved from Turkey to Iran through a complex network of businesses, banks, and front companies.

Image result for Mehmet Hakan Atillaphoto

The trial was a long time coming. In late October of 2016, Justice Department officials paid a visit to the Foundation for Defense of Democracies, the Washington-based think tank where I serve as senior vice president. They wanted to talk about Reza Zarrab. A dual Iranian-Turkish national, Zarrab was the swashbuckling gold trader who had helped Iran evade sanctions with the help of Turkish banks in 2013 and 2014, yielding Iran an estimated $13 billion at the height of the efforts to thwart Tehran’s nuclear ambitions. A leaked report by prosecutors in Istanbul in March 2014 suggested that Zarrab spearheaded a second sanctions-busting scheme involving fake invoices for billions more in fictitious humanitarian shipments to Iran that were processed through Turkish banks.

At FDD, we’d spent considerable time digging into Zarrab’s activities. Our think tank already had an established track record of identifying and exposing Iran’s malign activities. We had also just launched a new program to explore Turkey’s recent drift into Islamist authoritarianism. The more we investigated, the more we realized that Zarrab’s schemes, which could have helped Iran pocket more than $100 billion, rank among the largest sanctions evasion episode in modern history.Despite the headlines generated by the gold trade and leaked report, the Turkish government insisted that everything was above board. The Obama administration seemed to echo this sentiment, saying that the gold trade had slipped through a legal loophole (a loophole the White House inexplicably left open for an additional six months, even after the problem was flagged). We soon learned Ankara’s political motivations: The gold trade helped boost Turkey’s flagging export numbers at a moment when those numbers might have hurt President Recep Tayyip Erdogan’s chances for reelection. Zarrab, who became fabulously wealthy by taking a percentage from every transaction (he later estimated his take at $150 million), even received a reward for his efforts from a Turkish trade association in 2015, with Erdogan applauding from the audience.

But it all came to an abrupt halt last March, when Zarrab inexplicably brought his family to America for a vacation at Disney World. With the 2015 nuclear deal in effect, he may have believed that the sanctions laws he violated before the deal were no longer in force. Some suggest that Zarrab was trying to flee Iranian justice, particularly as the regime came to grasp just how much he skimmed off the top. Either way, when he arrived in Florida, U.S. authorities arrested him for engaging in conspiracies to violate sanctions, commit bank fraud, and launder money.

It was about time. For three years, my colleagues and I had been briefing the Treasury Department, the State Department, and Congressional offices. We had tracked the export data (which, remarkably, Turkey did not hide), showing an astronomical spike in Turkish gold exports. We identified the companies and players, with the help of the 2014 prosecutor’s report. It was painstaking work, but it was all out there in open sources for a think tank like ours to document.Yet, it was an inconvenient moment to reveal unsavory truths about Iran, amid the push for the nuclear agreement. Nor did anyone, Democrat or Republican, want to touch the third rail of relations with Turkey, a NATO ally that had recently begun backing terrorist groups like Hamas (which still maintains a disturbing presence in Turkey) and a range of Sunni jihadi groups fighting the Assad regime in Syria (including al-Qaeda’s affiliate, according to senior U.S. government officials we interviewed). Stable allies in the Muslim world were scarce, and decision-makers seemed reluctant to take any chances with Ankara.

It may also have been difficult for officials to hear that the sanctions tools we have in place to prevent bad actors from moving money are just that—tools. Without intense vigilance and enforcement, there is ample opportunity for Iran and other sanctioned countries to find workarounds. But if we’re going to follow the money, we’d better be prepared to follow it to the most inconvenient places.

That’s why it was a pleasant surprise when the Justice Department came knocking on FDD’s door. It had never dawned on us that they might be interested in our work. But they were. They wanted to see what we already knew of the complex web of companies, networks, and schemes, that Zarrab employed to move money out of Turkey and into Iran. After all, even with the vast evidence they had collected, our research predated their investigation.In the weeks and months that followed, one visit begat another. Both I and Mark Dubowitz, FDD’s CEO, were asked by the assistant U.S. attorney to serve as an expert witness for the prosecution. We pored over invoices tracking the transactions that turned gold into Iranian cash. We analyzed spreadsheets detailing the dizzying trail of sales and purchases designed to obfuscate the illicit nature of the transactions. There were also photos, including one of Zarrab himself standing next to a six-foot high tower of plastic-wrapped bricks of $100 bills. The documents were privileged at the time, but will soon be made public now that the trial is over. The documents are damning, with textbook examples of  money-laundering techniques like over-invoicing (charging significantly more for a given product to yield more margin) and circular invoicing (making multiple transactions involving the same funds or goods to hide a money trail or even benefit from arbitrage). The figures themselves were astounding: hundreds of millions of dollars in transactions in every stack of papers we viewed.

The case took a wild turn on March 28, when, Justice Department officials from the Southern District of New York arrested Atilla, the deputy CEO and general manager at Turkey’s state-owned Halkbank. They accused him of conspiring with Zarrab to launder hundreds of millions of dollars through the U.S. financial system on behalf of Iran. It was Halkbank that held one of the oil escrow accounts for Iran. The escrow accounts constituted a creative method of withholding petrodollars from Iran, as mandated by the Iran Threat Reduction and Syria Human Rights Act (ITRA) of 2012. In brazen defiance of U.S. sanctions, Halkbank released those funds to buy gold, which was then shipped off to Iran. Halkbank was also accused of helping to process Zarrab’s aforementioned fictitious invoices, the ones first exposed in the 2014 prosecutor’s report.
Image result for HalkbankUranium or gold

Halkbank was clearly in trouble. In September, it hired Ballard Partners, a U.S. lobbying firm that already represented the Turkish government, for a whopping $1.5 million. Separately, Zarrab hired former New York Mayor Rudy Giuliani and former Attorney General Michael Mukasey in an attempt to derail the proceedings. But the real drama came in late November when Zarrab pled out, making him a witness for the prosecution. Atilla would stand trial alone.

Related reading: Iran’s Turkish gold rush

That’s when the Turkish government got angry. They took their anger out on me and Mark Dubowitz, who testified on the first day of Atilla trial about the Iran sanctions architecture. The state media called us terrorists, alleging we were affiliated with Turkish cleric Fethullah Gulen’s network, the group Erdogan blamed for the attempted coup in July of last year. Ankara also issued an arrest warrant for my colleague Aykan Erdemir, a former Turkish parliamentarian. Turkish authorities froze his assets and even seized the apartment that his grandfather had bequeathed to the family. They said he “destroyed paperwork relating to state security” and “stole documents with the intention of using them abroad.” They also falsely identified him as being on the witness list.

But Ankara could not stop Zarrab from delivering seven days of sensational testimony. On day one, he appeared in court wearing a beige prison jumpsuit; for the remainder, he was allowed to wear a blazer. He was a natural in front of the jury, using diagrams to coolly explain how he orchestrated the scheme. He looked like a business school professor teaching a class on corruption.Here’s what Zarrab testified: The scheme began in 2010, when Iran began to feel the squeeze from U.S. sanctions for its nuclear drive. Zarrab said that around 2012 the Iranian government gave him explicit directions to conduct these illegal transactions. Turkish officials were also on the take, Zarrab said, with its economy minister allegedly taking $50 million in bribes to help facilitate the scheme. He said other Turkish officials were on the take, too—many of whom were in Erdogan’s inner circle. According to Zarrab, other Turkish banks may have been involved at the government’s behest. All this might explain why the Turkish government, even after the prosecutor’s report was leaked in 2014, killed all inquiry into the Zarrab scheme.

Testimony from David Cohen and Adam Szubin, two former Treasury Department undersecretaries would also reveal that Halkbank officials repeatedly reassured them their gold-trader clients, including Zarrab, were in compliance with U.S. sanctions against Iran. (Zarrab testified that he continued his operations up until his arrest in March 2016, which meant that Halkbank would have been lying to U.S. officials.)

In the end, the trial ran long. With the judge calling for the prosecution to wrap things up quickly, I managed to avoid taking the stand. Atilla testified in a last-ditch self-defense, and the jury began its deliberations on December 20.Yesterday, after spending 11 days away for Christmas and New Years, the jury returned to deliberate again, and after only a few hours delivered their verdict: guilty on five out of six counts. Atilla’s rap sheep now includes four conspiracy counts, including conspiracy to defraud the United States, plus one count of bank fraud. (He was acquitted for money laundering.)

All eyes are now on the United States government and whether it issues a fine against Halkbank, particularly now that it has proven in a court of law that the bank engaged in a massive, illegal financial scheme. French Bank BNP Paribas was fined $8.9 billion for far lesser transgressions in 2015, for its violations of sanctions against Sudan, Cuba, and Iran.

Fine or no fine, it’s hard to envision tranquil U.S.-Turkish relations going forward. Erdogan, who now rivals Russia’s Vladimir Putin in autocratic style, has already instructed his spokesman to decry the trial as a “plot” against Turkey, while slamming “the scandalous verdict of a scandalous case.”

Then there is the question of Iran. In all likelihood, Tehran probably gave little thought to the Atilla verdict, given its ongoing domestic turmoil. The people are calling for better economic conditions, and a foreign policy that doesn’t squander Iran’s wealth on adventurism outside the country’s borders. One can only guess that would include complex sanctions busting schemes to enable an illicit nuclear program.

And now that Zarrab has finally clarified a few things about the Iranian role in his scheme, one troubling question lingers: Why did the U.S. government continue to negotiate the nuclear deal with Iran in 2013 and 2014 while Treasury was warning Halkbank about enormous sanctions violations? We may never know. Then again, from the documents I viewed, I wouldn’t be surprised to see other sanctions busters come in the DOJ crosshairs—creating new and uncomfortable challenges for our existing alliances and diplomatic agreements. Perhaps other future indictments will tell us more.