Category Archives: Iran Israel

Jones Day Legal Counsel to European Corps, Iran Deal

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Let’s begin with Ploughshares, shall we? Make sure you check the credits at the end of the video. Those that contributed money to the effort are listed here.

Meanwhile, there is a meeting scheduled in Vienna where Germany, France, Britain, Russia and China are to discuss saving the Iran nuclear deal. It is being chaired by Helga Schmid. Will it soon be called the Vienna nuclear deal?

Impact of U.S. Withdrawal from the Iran Nuclear Deal

May 2018

In Short

The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran.

The Result: All currently suspended U.S. sanctions in respect of Iran, including sanctions applicable to non-U.S. persons, will be reimposed by November 5, 2018.

Looking Ahead: The reimposition of U.S. sanctions will have limited impact on U.S. companies. However, foreign companies majority-owned or controlled by U.S. persons must now begin winding down any Iran-related activities. In contrast, the impact of the reimposition of U.S. sanctions on non-U.S. companies is less clear, and as the international response develops, non-U.S. companies will increasingly face a complex compliance landscape.

As reported earlier this week, on May 8, 2018, President Trump announced that the United States will reimpose, after specified wind-down periods, all nuclear-related sanctions lifted under the Joint Comprehensive Plan of Action (“JCPOA”) (commonly known as the “Iran Nuclear Deal”). As a result, the U.S. sanctions regime will revert to its pre-JCPOA scope by November 5, 2018.

In light of the comprehensive U.S. primary sanctions that remained in place after implementation of the JCPOA, President Trump’s announcement will have little impact on U.S. companies. In contrast, foreign subsidiaries of U.S. organizations and their non-U.S. counterparts face a dramatically changed compliance landscape. With the reimposition of U.S. extraterritorial, or secondary, sanctions, non-U.S. companies must navigate increasingly complex terrain as they assess continued engagement with Iran, compliance with U.S. sanctions, and the pending response of the other JCPOA signatories.

Immediate Impact

The background of the JCPOA, the resulting international sanctions relief, and President Trump’s criticism of the deal are, at this point, well-known (see “Iran Nuclear Deal Reached; Sanctions Remain in Place,” “Implementation Day Triggers Significant Changes to International Sanctions Against Iran,” and “Potential Options for U.S. Sanctions on Iran Under the Trump Administration“). Although the policy implications of President’s Trump’s announcement may be subject to debate, the immediate impact is clear. In connection with the announcement, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Frequently Asked Questions setting out a staged reimposition of U.S. sanctions over the next 90 to 180 days (subject to any extension that may be put in place by the United States at a later stage).

Following a 90-day wind-down period ending on August 6, 2018, the United States will reimpose its secondary sanctions targeting activities related to:

  • Iran’s automotive sector;
  • The sale, supply, or transfer, directly or indirectly, of graphite, raw or semi-finished metals (such as aluminum and steel), coal, and software for integrating industrial processes to or from Iran; and
  • Certain financial and banking transactions related to Iranian sovereign debt, the acquisition of U.S. dollar banknotes by the Government of Iran, the purchase or sale of Iranian rials, Iranian rial-denominated funds or accounts, and trade in gold or other precious metals.

During the same period, the United States will revoke the following authorizations:

  • The general license authorizing the importation into the United States of Iranian-origin carpets and foodstuffs (as well as certain related financial transactions);
  • All specific licenses (and subsequent wind-down authorizations) issued in connection with the Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services (“JCPOA SLP”); and
  • General License I, which authorized certain transactions related to negotiating and entering contingent contracts for activities covered by the JCPOA SLP.

Following a 180-day wind-down period ending on November 4, 2018, the United States will reimpose its secondary sanctions targeting activities related to:

  • Certain transactions by foreign financial institutions with, and provision of specialized financial messaging to, the Central Bank of Iran and/or designated Iranian financial institutions;
  • Certain categories of transactions related to Iran’s energy sector, including certain investments (such as participation in joint ventures); provision of goods, services, technology or technical support; the purchase, sale, transport, or marketing of petroleum, petrochemical products, and/or natural gas to or from Iran; and transactions with certain designated persons (such as the National Iranian Oil Company, Naftiran Intertrade Company, and National Iranian Tanker Company);
  • Certain transactions involving Iran’s port operators and/or related to Iran’s shipping and shipbuilding sectors, including activities involving the Islamic Republic of Iran Shipping Lines, South Line Iran, or their affiliates; and
  • The provision of certain insurance, reinsurance, and underwriting services.

Effective November 5, 2018, the United States will also revoke General License H (and any subsequent wind-down authorizations issued in connection with that general license), which previously authorized foreign entities majority-owned or controlled by U.S. persons to engage in most transactions involving Iran. It appears all other Iran-related general and specific licenses, including licenses issued under the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”), issued by OFAC will remain unaffected.

Finally, no later than November 5, 2018, the United States will redesignate all persons who had been removed, through the JCPOA, from the List of Specially Designated Nationals and Blocked Persons and/or other U.S. sanctioned parties lists.

Consequently, by November 5, 2018, the United States is currently expected to have reimposed all sanctions that had been lifted pursuant to the JCPOA.

Near- and Long-Term Implications

As a practical matter, the reimposition of U.S. sanctions suspended under the JCPOA will have limited impact on U.S. companies. As noted in our prior Alerts and Commentaries, substantial U.S. sanctions in relation to Iran have remained in place and continued to prohibit U.S. persons from engaging, directly or indirectly, in virtually all transactions or dealings with Iran without authorization.

The reimposition of U.S. sanctions will, however, have immediate impact on non-U.S. organizations that are majority-owned or controlled by U.S. persons and on U.S.-linked aviation companies. As noted above, the United States intends to revoke all specific and general licenses issued in connection with the JCPOA “as soon as administratively feasible,” including General License H and aviation-specific licenses issued under the JCPOA SLP and General License I. In their place, OFAC intends to issue authorizations that will likely narrowly authorize only activities necessary to wind down previously authorized activities. Companies that rely on these authorizations should immediately reassess their existing Iran-related activities, including in-process and pending transactions, in order to prepare to wind down Iran-related activities and ensure compliance with U.S. sanctions during the wind-down period.

The near- and long-term implications of President’s Trump announcement for non-U.S. companies are less clear. Non-U.S. persons are not, with limited exceptions, subject to U.S. primary sanctions. However, U.S. secondary sanctions provide for an array of penalties that, in effect, foreclose access to U.S. markets—a meaningful deterrent for non-U.S. companies. The United States appears poised to rigorously enforce the renewed sanctions and has advised non-U.S. companies to begin winding up soon-to-be sanctionable activities to “avoid exposure to sanctions or an enforcement action when the applicable wind-down period ends.” Continued engagement with Iran will therefore become an increasingly fraught proposition for non-U.S. persons, and one that may be further complicated by the international community’s response to the United States’ withdrawal.

In that regard, following President Trump’s announcement, the European Union has reiterated its commitment to “the continued full and effective implementation of the JCPOA,” as long as Iran meets its nuclear-related obligations, adding that it “is determined to work with the international community” to preserve the deal. Although the European Union has not yet indicated any measures it may implement to preserve the JCPOA, it suggested earlier this year that it may expand its Blocking Regulation—Council Regulation (EC) No. 2271/96 of November 22, 1996—to protect EU-based organizations doing business in Iran following any U.S. withdrawal.

The Blocking Regulation was adopted in 1996 by the European Union (European Communities at the time) in response to the extraterritorial application of U.S. sanctions against Cuba, Iran, and Libya. It prohibits EU companies from complying with blocked sanctions “whether directly or through a subsidiary or other intermediary person, actively or by deliberate omission.” The importance of the Blocking Regulation in the last decade has been limited. This would change if the scope of its application is expanded to cover the U.S. secondary sanctions in relation to Iran, possibly protecting EU companies from enforcement of U.S. judgments or administrative decisions giving effect to the secondary sanctions.

Historically, enforcement of the Blocking Regulation has generally been very limited, but expanding its scope now has the potential to lead to increased enforcement actions across Europe. An expanded Blocking Regulation would, however, place EU companies squarely between the competing demands of U.S. sanctions and EU and national requirements. The European Union may also try to negotiate an exemption for EU companies from the reimposition of the U.S. sanctions. The prospects of relief for EU companies under either approach remains uncertain.

China and Russia have likewise consistently reaffirmed their commitment to the JCPOA, and in a joint statement last month confirmed their “unwavering support” for the deal. In light of current tensions between the United States and Russia and China, it seems unlikely that the U.S. withdrawal will lead Russia or China to alter its commitment to the JCPOA or have a substantial impact on Russian and Chinese business interests in Iran.

As the international response to the U.S. withdrawal from the JCPOA develops, non-U.S. companies should take steps to protect their interests in light of the pending reimposition of U.S. sanctions. In particular, non-U.S. companies should reassess their Iran-related activities to determine their potential liability under the soon-to-be imposed U.S. secondary sanctions and/or any potential blocking statutes; open dialogues with their financial institutions, insurers, and other service providers regarding any Iran-related activities; and, significantly, prepare to possibly wind down any potentially sanctionable Iran-related activities in order to move promptly to comply with U.S. secondary sanctions, if warranted.

Jones Day will continue to monitor developments and provide updates.

Three Key Takeaways

  1. The U.S. withdrawal from the Iran nuclear agreement will result in the reimposition of sanctions that had been lifted as part of JCPOA, or, the “Iran Nuclear Deal.”
  2. Because the comprehensive U.S. primary sanctions remained in place after implementation of JCPOA, the withdrawal and reimposition of sanctions hold few consequences for U.S. companies.
  3. However, foreign subsidiaries of U.S. organizations and their non-U.S. counterparts face a markedly altered compliance situation, and those companies affected should take decisive and deliberate measures to protect their interests.

U.S. Applies New Iran Sanctions, Hardly Enough

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We are still at war in the Middle East where Iran with proxies is the real and virtual enemy. The United States uses proxies as well, yet the United States near term and long range strategy remains fleeting.

The talks that continue between Iran and Europe on the JCPOA should include Iran’s war operation in the Middle East.

For related reading: How Iran Spreads Its Empire through Terrorist Militias, In Lebanon, Iraq, Yemen, and elsewhere, Tehran has perfected the art of gradually conquering a country without replacing its flag.

https://lh5.googleusercontent.com/_fdkmbEaLNsthfxOkoTpRxuhC2mSgPJfm2_f4IcdO9OLC8jMqBk5ambXr3ZwDw1cbXzPO0HkTEU_l5j-ZIOvKmJfUplgWyyl6COiJ7zOyS8IC7PFxOXsApqtEhf085IRRVbVd8e_ photo

Going forward for the United States:

Implications and Future Research
The unwillingness of the United States and its GCC partners to use their vast conventional military superiority has shifted the balance of power in the region from the conventional to the unconventional realm. Iran then relies on its willingness to assume more risk and its ability to better influence proxies than its adversaries, to achieve favorable foreign policy outcomes despite the opposition of the United States and its Arab allies. The use of proxy groups fundamentally decreases the physical cost a state incurs due to conflict. However, when the soldiers of a state die advising and assisting these proxies, it is more difficult to justify domestically, because using proxies signals that the objectives are not important enough to warrant decisive intervention. Therefore, states are most successful when they use proxies not as a cost-reduction mechanism alone but because proxies
are better able to achieve the desired end than conventional military forces. If the United States is unwilling to risk additional battle deaths or domestic political repercussions to prevent Iran from projecting power across the Middle East, then it must instead apply cost-imposing strategies.
Increasing the effectiveness of special operations forces from allied Arab states through intelligence sharing, kinetic strikes, training, and attached American advisors, while encouraging deployments of these elements to areas where Iranian advisors and IRGC units operate, would increase the human cost of Iranian activities. In addition to targeting Iran’s primary efforts in Iraq and Syria, these partnered operations should also confront peripheral Iranian efforts throughout the Gulf, including Yemen, in order to exploit the weakness of Iranian popular support for its presence therein. By working through Arab partners, the United States can apply the indigenous force necessary to confront Iranian proxies, while increasing the likelihood that Arab states achieve a confluence of shared ideology and objectives with their proxies, which eludes the United States
as a separate actor. Saudi and Emirati support to Yemeni military units recapturing the port of Aden and the Bab al-Mandab Strait serve as good examples of the type of effort the United States should expand.
In addition to combating Iranian proxy groups directly, targeting the ground, air, and sea logistical routes that the IRGC Quds Force uses to supply its proxies would affect Iran’s ability to support its efforts in the region. As long as Iran continues to rely on a domestically based force projection model, its network is vulnerable to air strikes, raids, and sabotage. An expanded network of friendly proxies partnered with US and allied
-Arab advisors would be ideally suited to facilitating this type of targeting.
The author is: Maj. Alex Deep is an assistant professor in the Department of Social Sciences at the United States Military Academy at West Point. He is a Special Forces officer with ten years of service and multiple deployments to Afghanistan in conventional and special operations task forces. He served as a rifle platoon leader and company executive officer in the 173rd Airborne Brigade Combat Team prior to completing Special Forces Assessment and Selection and subsequently the Special Forces Qualification Course. He then served as a Special Forces detachment commander and battalion assistant operations officer in 1st Battalion, 3rd Special Forces Group (Airborne). He currently teaches SS307: Introduction to International Relations. Deep holds a Bachelor of Science in American Politics and Arabic from the United States Military Academy at West Point and a Master of Arts in Strategic Studies and International Economics from the Johns Hopkins University School of Advanced International Studies.

$100,000 to Destroy the New US Embassy in Jerusalem

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Sheesh…the building has been there for years already. Further, there are several other countries that are moving their embassies as well.

About 800 guests attended the opening ceremony. The U.S. was represented by a formally designated “Presidential Delegation” led by Deputy Secretary of State, John. J. Sullivan, and including U.S. Ambassador to Israel, David Friedman, Treasury Secretary Steve Mnuchin, Presidential Advisor Ivanka Trump and her husband, Jared Kushner, and Jason Greenblatt, the White House’s lead negotiator. A bicameral Congressional delegation and other U.S. dignitaries were also present for the ceremony, which was also attended by top diplomats from 33 other nations.

***

The Jerusalem Embassy Act of 1995 is a public law of the United States passed by the 104th Congress on October 23, 1995.

The Act recognized Jerusalem as the capital of the State of Israel and called for Jerusalem to remain an undivided city. Its purpose was to set aside funds for the relocation of the Embassy of the United States in Israel from Tel Aviv to Jerusalem, by May 31, 1999. For this purpose it withheld 50% of the funds appropriated to the State Department specifically for “Acquisition and Maintenance of Buildings Abroad” as allocated in fiscal year 1999 until the United States Embassy in Jerusalem had officially opened. Israel’s declared capital is Jerusalem, but this is not internationally recognized, pending final status talks in the Israeli–Palestinian conflict.

Despite passage, the law allowed the President to invoke a six-month waiver of the application of the law, and reissue the waiver every six months on “national security” grounds. The waiver was repeatedly invoked by Presidents Clinton, Bush, and Obama.

Iran continues to ignore history, facts and hard tangible evidence about Jerusalem. Furthermore we were told by John Kerry and Barack Obama were to be good citizens of the world after the completion of the Iranian nuclear deal….well three things at least have surfaced since the United States withdrew.

***

  1. A hardline Iranian organization is reportedly offering a $100,000 reward to any person who bombs the newly opened U.S. embassy in Jerusalem, according to a translation of Farsi language reports.

    A group known as the Iranian Justice Seeker Student Movement is reported to have disseminated posters calling for an attack on the U.S. embassy in Jerusalem, which has been opposed by Palestinian and Iranian officials as an affront to the holy city.

    “The Student Justice Movement will support anybody who destroy the illegal American embassy in Jerusalem,” the poster states in Farsi, Arabic, and English, according to an independent translation of the propaganda poster provided to the Free Beacon.

    There will be a “$100,000 dollar prize for the person who destroys the illegal American embassy in Jerusalem,” the poster states.

    Iran poster

    The call for an attack on the new embassy is just the latest escalation by hostile Islamic states and leaders who have lashed out at the United States and President Donald Trump for making good on a campaign promise to relocate the embassy from Tel Aviv to Israel’s declared capital city of Jerusalem.

    News of the bomb threat was first reported by the University Student News Network, a regional Farsi-language site that aggregates relevant news briefs.

    “The Student Movement for Justice declared, ‘Whoever bombs the embassy’s building will receive a $100,000 award,'” the report states. “It is necessary to mention that the steps by Trump to transfer the US Embassy to Holy Qods [Jerusalem] has led to the anger and hatred of Muslims and liberators throughout the world.'”

    Michael Rubin, a former Pentagon adviser and expert on rogue regimes, told the Washington Free Beacon that terrorism of this nature is embedded in the Iranian regime’s hardline stance.

    “Unfortunately, terrorism directed toward diplomats and embassies has become a central pillar of the Islamic Republic’s culture,” Rubin said. “Terrorism is lionized in Iranian schools. This bounty is more the rule than the exception. To blame Washington or Jerusalem is to blame the victim and give terrorists a veto over U.S. policy.”

    Behnam Ben Taleblu, an research fellow at the Foundation for Defense of Democracies, described the poster as repulsive and blamed the Iranian ruling regime for fostering such an attitude.

    “This is nothing short of an invitation to a heinous act of an international terror by a student group that looks up to the world’s foremost state sponsor of terror—the Islamic Republic of Iran,” he said.

  2. TEHRAN – New freight train connections usually only have a limited potential to make global headlines, but a new service launched from China on Thursday could be different. Its cargo – 1,150 tons of sunflower seeds – may appears unremarkable, but its destination, however, is far more interesting: Tehran, the capital of Iran .

    The launch of a new rail connection between Bayannur in China ‘s Inner Mongolia Autonomous Region and Iran was announced by the official news agency Xinhua on Thursday. Its exact path was not described in the dispatch, but travel times will apparently be shortened by at least 20 days in comparison to cargo shipping. The sunflower seeds are now expected to arrive in Tehran in about two weeks.

    While the seeds are making their steady progress across Asia, there’s a growing risk of Iran and Israel <link>breaking into open conflict in the meantime. French President Emmanuel Macron has already predicted that the U.S. decision to pull out of the Iran deal would lead to war, especially after Iranian Foreign Minister Mohammad Javad Zarif warned that the country may restart its nuclear program if U.S. sanctions are imposed. Iranian rocket attacks on Wednesday and the subsequent Israeli retaliatory attacks on Thursday indicated how quickly the situation could indeed escalate.

    While the United States is now urging foreign companies to wind down their operations in Iran , China appears to be doing the opposite. Thursday’s freight train connection launch was only the latest measure Beijing has taken to intensify trade relations with Iran and there seem to be no plans so far to give in to U.S. demands.

    China has indicated it might defy US President Donald Trump’s sanctions on Iran by doing business with it.

    During a press briefing on Wednesday, Chinese Foreign Ministry spokesman Geng Shuang said that Iran and China would “maintain normal economic ties and trade.”

    “We will continue with our normal and transparent practical cooperation with Iran on the basis of not violating our international obligations,” he said. China faces the same problem U.S. allies in Europe are currently facing <link>: Even if European governments are opposed to new sanctions on Iran , European companies would have to abide by those rules or risk severe fines by the United States.

    Even though they have expressed their outrage, some high-ranking European officials have already acknowledged that they would have few options to rein in the United States if it decided to punish European companies for continuing to trade with Iran .

    China , however, appears more defiant.

    Iran ‘s Hassan Rouhani had established a track record for bridge-building in nuclear talks with European powers

    When asked whether China would order its companies to withdraw from Iran to avoid U.S. sanctions, the Chinese Foreign Ministry spokesman indicated that Beijing might defy the Trump administration. “I want to stress that the Chinese government is opposed to the imposition of unilateral sanctions and the so-called long-arm jurisdiction by any country in accordance with its domestic laws,” he said.

    China has to some extent managed to circumvent U.S. sanctions in the past and may be able to do the same again this time. Some analysts have even suggested that Chinese entities could act as intermediaries for European companies that want to continue trading with Iran , but fear violating U.S. sanctions. Such sanctions would be particularly damaging to European businesses operating in the United States, such as plane manufacturer Airbus.

    Speaking to CNBC, former U.S. diplomat Carlos Pascual said that oil sales from Iran via China or Russia to the rest of the world could circumvent U.S. measures.

  3. The Chief of Staff of the Iranian Armed Forces Major General Mohammad Hossein Baqeri has said his country seeks expansion in military cooperation with Afghanistan.

    Gen. Baqeri reportedly informed regarding his country’s intent during a meeting with the Afghan defense minister Gen. Tariq Shah Bahrami.

    “The shared backgrounds between the two countries of Iran and Afghanistan, including religion and language, have brought them together in such way that no obstacle can undermine their close relations, specially in combatting the terrorist groups,” the top Iranian General was quoted as saying by Fars News.

    He also expressed the hope that the Afghan military delegation’s visit would result in more cooperation between the two countries’ armed forces.

    The top Iranian General’s intent to expand military cooperation with Afghanistan comes as the country is accused of supporting the certain insurgent groups in Afghanistan.

    “Iran’s desire for influence in Afghanistan remains strong. Iran seeks increased influence in Afghanistan through government partnerships, bilateral trade, and cultural and religious ties,” Pentagon stated in its report regarding Afghanistan late last year.

    The report also adds that Iran provides some support to the Taliban and publicly justifies its relationship with the Taliban  as a means to combat the spread of ISIS-K in Afghanistan.

    “Iran’s support to the Taliban undermines the Afghan Government’s credibility, adds to instability in the region, and complicates strategic partnership agreements,” Pentagon had warned.

Hey, How About Assigning an IG to the JCPOA?

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There is still much dispute over the Iranian nuclear deal, the P5+1, the money, the players and the inspections. There were side deals too, do we really know all there is to know?

Iran in parallel nuclear talks in Vienna, Istanbul - Daily News Egypt photo

Perhaps it is past time that an Inspector General is assigned to the whole deal and talks. How much did the United States really pay to Iran? How many other countries participated in the deal beyond those of the P5+1? Who took bribes? Who is getting kickbacks? What is Ben Rhodes doing these days for a living? Were there really any inspections to confirm Iran’s compliance?

A little known fact is the UN’s top nuclear inspector resigned immediately when President Trump withdrew from the JCPOA.

The International Atomic Energy Agency didn’t give a reason for the sudden resignation of Tero Varjoranta, stating Saturday that it doesn’t comment on confidential personnel matters.

Varjoranta, who was in the role for almost five years, will be replaced temporarily by Massimo Aparo, an Italian nuclear engineer who was most recently the agency’s top inspector for Iran.

The move comes just days after U.S. President Donald Trump announced the United States would withdraw from the 2015 Iran nuclear accord designed to keep Tehran’s atomic weapons program in check.

The Vienna-based nuclear agency says it has no indications Iran is in breach of the accord.

*** What does Iran know now that could incriminate Western officials? If there is real evidence of international corruption by Western officials, will that affect snap-back sanctions on Iran? Will that affect relations with Britain, France or Germany? Susan Rice admitted to 2 side deals and those documents would not be published or provided.

After passing a 90-day mark on Aug. 6, the following sanctions will snap back on Iran, according to the Treasury Department:

  • Sanctions on Iran buying or acquiring U.S. dollars
  • Sanctions on Iran trading gold and other precious metals
  • Sanctions on Iran’s sale, supply or trade of metals such as aluminum and steel, as well as graphite, coal and certain software for “integrating industrial processes”
  • Sanctions on “significant” sales or purchases of Iranian rials, or the maintenance of significant funds or accounts outside the country using Iranian rials
  • Sanctions on issuing Iranian debt
  • Iranian auto sanctions

The U.S. will also revoke certain permissions, granted to Iran under the deal, on Aug. 6. These include halting Iran’s ability to export its carpets and foods into the U.S., as well as ending certain licensing-related transactions.

At the end of the 180-day interval on Nov. 4, another set of sanctions will once again be clamped down on Iran:

  • Sanctions on Iran’s ports, as well as the country’s shipping and shipping sectors
  • Sanctions on buying petroleum and petrochemical products with a number of Iranian oil companies
  • Sanctions on foreign financial institutions transacting with the Central Bank of Iran and other Iranian financial institutions
  • Sanctions on the provision of certain financial messaging services to Iran’s central bank and other Iranian financial institutions
  • Sanctions on the provision of underwriting services, insurance, or reinsurance
  • Sanctions on Iran’s energy sector

The following day, on Nov. 5, the Trump administration will disallow U.S.-owned foreign entities from being allowed to engage in certain transactions with Iran. Sanctions on certain Iranian individuals will also be re-imposed on Nov. 5.

Read the Treasury’s full guide to the re-imposition of Iran nuclear deal sanctions here.

*** Why are we only focusing on Iran regarding the nuclear deal? Why not their global reign of terror?

Iran, a State Sponsor of Terrorism, continues to invest in proxy terrorist and militant organizations that threaten the Homeland and US interests and engage in activities that impede US counterterrorism goals. This hearing will examine trends in Iran’s external operations and capabilities and consider the near-term and long-term security implications of Iranian support for Shia militants and terrorist groups operating in the Middle East, Afghanistan and Latin America.

 

Yes, it is for sure time for a full set off committee hearings and for subpoena power along with an Inspector General.

Qasem Soleimani, Marshal of Global Terror and Money Laundering

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Primer: Qasem Soleimani, the military maestro of the IRGC, commanded the base that attacked Israel earlier this week. Further, the Israelis asked permission to assassinate Soleimani during the Obama administration. They were denied and Obama officials leaked the plot to Iran. Now, that same request has apparently been asked of the Trump administration and the request was approved.

General Qassem Suleimani: The Thinker Of Our Time ...

Soleimani has a long terror history, globally.

Tower: The United States Treasury Department, working with authorities in the United Arab Emirates, broke up a money laundering scheme that provided millions of dollars to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), Reuters reported Thursday.

Treasury designated six individuals and three business entities for their role in the scheme. The UAE, where companies facilitating the money laundering were located, but the same people and entities on its list of terrorists and terror organizations that do business with the IRGC-QF.

In a statement announcing the new sanctions, Treasury Secretary Steven T. Mnuchin said, “The Iranian regime and its Central Bank have abused access to entities in the UAE to acquire U.S. dollars to fund the IRGC-QF’s malign activities, including to fund and arm its regional proxy groups, by concealing the purpose for which the U.S. dollars were acquired. As I said following the President’s announcement on Tuesday, we are intent on cutting off IRGC revenue streams wherever their source and whatever their destination. Today we are targeting Iranian individuals and front companies engaged in a large-scale currency exchange network that has procured and transferred millions to the IRGC-QF.”

Mnuchin thanked the UAE for its “close collaboration” in disrupting the money laundering and called on all nations to “be vigilant” in fighting Iranian attempts at money-laundering to “fund the nefarious actors of the IRGC-QF and the world’s largest state sponsor of terror.”

United States and United Arab Emirates disrupt large scale currency exchange network transferring millions of dollars to Iran’s Islamic Revolutionary Guard Corps-Qods Force: Exchange Network CHART:

Reuters described the IRGC as Iran’s “most powerful security entity,” with control over a large share of Iran’s economy. IRGC-QF is described as “an elite unit in charge of the IRGC’s overseas operations.”

In 2015, Reuters reported that more than $1 billion in cash had been smuggled into Iran despite sanctions, utilizing “money changers and front companies in Dubai, in the United Arab Emirates and Iraq.” Iran preferred using a network of front companies to handle the money laundering in order to conceal “the overall size of the dollar-purchasing operation.”

When he announced the United States’ withdrawal from the nuclear deal earlier this week, President Donald Trump gave companies either three month or six months to wind down their dealings with Iran.