Mark Dubowitz

Sanctions alert

Iran’s new financial channel with Europe is linked to sanctioned entities

 

The following is an excerpt:

In April, Tehran created the Special Trade and Finance Instrument (STFI) as a counterpart to the European SPV, formally known as the Instrument for Supporting Trade Exchanges (INSTEX). Set up by Germany, France, and the UK, INSTEX would avoid U.S. sanctions by enabling trade without using the U.S. dollar or going through U.S. banks. STFI was registered in April in Tehran’s Davudieh near the CBI’s headquarters.

[…]

The EU would be wise not to enter into any transaction with the STFI given its connection to sanctioned entities. Non-U.S. firms that are involved in legitimate trade with Iran can conduct it through Iranian banks that are not on the SDN list or not subject to secondary sanctions. Treasury can clarify the risks of dealing with the STFI by adding it to the SDN list, and issuing guidance related to the risks of doing business with proliferators and terrorist sponsors through the STFI. If the EU persists, Treasury could go a step further by threatening to apply secondary sanctions to the STFI.

Read Mark and Saeed‘s policy brief on FDD’s website here.

Gigot: The Trump administration this week deployed USS Abraham Lincoln Carrier Strike Group along with the USS Arlington and a Patriot surface-to-air missile battery to the Persian Gulf. A response to what Secretary of State Mike Pompeo called a number of troubling and escalatory warnings from Tehran. The deployment comes as the U.S. announces fresh sanctions targeting Iran’s copper, or iron, steel, and aluminum industries and as Tehran warns European leaders that it will stop complying with key parts of the 2015 nuclear deal setting a 60-day deadline for the parties to negotiate new terms. Mark Dubowitz is Chief Executive of the Foundation For Defense of Democracies where he leads the Iran program. So, Mark thanks for coming in good to have you back.

Dubowitz: Thanks, Paul.

Gigot: So, in my experience the U.S. doesn’t deploy this kind of military force as quickly as it has unless there’s really good intelligence saying there’s something to worry about. Is that how you read it?

Dubowitz: Paul, certainly there’s really good intelligence that the regime in Iran was threatening US interests and US allies and so the deployment of these assets is obviously sent as a message to the regime to be careful in that these the carrier group the b-52 bombers that went back they were part of a regularly scheduled redeployment. But certainly I think it sounds like things were expedited to send a message over the past couple of weeks that they had real intelligence of real threats

Gigot: Yeah, now Qasem Soleimani the head of the Kurds force and of the Islamic Revolutionary Guard Corps, his tactics do include the use of force and striking back usually through proxies like Hezbollah and militias. Is that how you think this would happen if it did from an Iranian point, if it does, from an Iranian point of view?

Dubowitz: Yeah, Soleimani’s playbook and has been for years. And he’s you know he’s killed hundreds of Americans and maimed thousands of Americans over the years and so I think that probably was the Intel that the U.S government was picking up that Soleimani was going to be using Shiite militias potentially against US troops in in Iraq or in Syria and certainly against US allies and US interests throughout the Gulf

Gigot: Yeah, maybe your American diplomats and embassies, I think they’re also worried about that. Do you think that the Iranian government could actually want some kind of skirmish with the United States militarily? Is that just to help themselves domestically at home?

Dubowitz: Look, it’s always possible. I mean, I think it would be suicidal for the regime to confront the United States certainly given overwhelming American conventional power. And I think it’s also the reason that you hear from President Trump, Secretary Pompeo, Ambassador John Bolton as well as the commander of U.S. forces in in the Middle East, that if they if Soleimani tries this indirectly through proxies as he has in the past they will hold the regime in Iran accountable.

Gigot: Alright, let’s turn to the nuclear agreement and the threat the to the Europeans from Iran that if they don’t do something to fulfill the economic terms of the agreement beyond US sanctions they will withdraw in 60 days. You take that seriously?

Dubowitz: I don’t take it that seriously. I mean, I think the regime in Iran understands that if they do withdraw the Europeans will actually join the United States in reimposing EU sanctions and UN sanctions. So, Iran has to be careful, but I think what you will see is again the Iranian playbook tends to be they expand their nuclear program incrementally, not egregiously, though overtime the sum total of those incremental expansions are egregious. So, I think they will try to blackmail the Europeans and get the Europeans to try to force businesses and banks to start returning to Iran. I think it’ll be wholly unsuccessful.

Gigot: Yeah, it hasn’t been successful so far. But what about the threat what the policy they’re already imposed they’re going to keep their excess enriched uranium and heavy water that they’ve been sending overseas as part of the agreement. Now, they’re going to keep that how serious important is that?

Dubowitz: Look, it is important I mean that would be an incremental breach of the agreement and a serious breach of the agreement because it lowers the breakout time for Iran to weaponize uranium and develop nuclear weapons. So I think they will start to dial up on the nuclear side and again use nuclear blackmail against Europeans on the assumption that the Europeans will then freak out and start to put immense pressure either on Washington or start to breach sanctions. So, this is part of the Iranian playbook it has been for years and it’s something that we’ve expected.

Gigot: Is all of this acting out here by the Iranians a sign that the US tighter sanctions, particularly sanctioning the IRGC there in the Revolutionary Guard Corps and then now tighter sanctions on oil exports, that those are really starting to hurt?

Dubowitz: There’s no doubt about it, I mean I think the sanctions that President Trump has reimposed the new sanctions that have come on board and past couple of weeks against the IRGC and against oil exports are really beginning to put a severe amount of pressure on the economy in Iran and I think that the regime war is at this point that they may see state facing a severe economic crisis but as well a political crisis as thousands of Iranians are still on the streets every day yelling death to the Ayatollah, death to the regime. Why are you spending your money supporting Assad and Hezbollah instead of supporting Iranian’s? And so they’re worried about an economic crisis and a political crisis and they’re really being squeezed between a, I guess, a Trumpian rock and a Bolton hard place

Gigot: All right, Mark Dubowitz thanks for being here appreciate it.

No one in the sun- and gas-soaked Middle East needs nuclear power

The following is an excerpt:

Wednesday’s decision by the Islamic Republic of Iran to break the restrictions of the Iran nuclear deal is a further reminder that neither Iran, nor for that matter Saudi Arabia, needs nuclear power. Nor, for that matter, does any other state in the gas-soaked, sun-drenched Middle East, where civil nuclear programs are simply nuclear bomb starter kits.

Instead of straining to control these programs, or even facilitating them, the U.S. should encourage less risky, cheaper, clean non-nuclear alternatives.

Read Mark and Henry’s piece on FDD’s website here and on Washington Examiner’s website here. 

Up for Debate: U.S.-Iran policy

So far, US policy seems to be working, albeit unevenly.

 

The following is an excerpt:

With the designation of the IRGC as a foreign terrorist organization, the push to drive Iranian oil exports to zero, and other planned steps, the Trump administration, with support from Republicans in Congress, is moving to build a wall of deterrence to keep companies out of Iran even if a new president tries to lift sanctions as part of a reentry into the JCPOA.

Iranian Supreme Leader Ali Khamenei may decide to play for time, hoping for Trump’s defeat in 2020. But with sanctions biting and the economy in turmoil, Tehran may now welcome a diplomatic process whose purpose is to blunt the “maximum pressure” campaign.

Read all of Mark’s argument on FDD’s website here and on Middle East Institute‘s website here.

Gigot: Iran’s Revolutionary Guard Corps controls much of Iran’s national economy, including construction, banking and telecommunications.  It also oversees the regime’s ballistic missile program. So what does the terrorist designation mean for the IRGC and for the future of U.S.-Iran relations? Let’s ask Mark Dubowitz, the chief executive of the Foundation for Defense of Democracies, where he heads up the Iran program. So welcome, good to see you.

Dubowitz: Thanks Paul.

Gigot: Do you agree with the designation of the IRGC?

Dubowitz: I do, I have long supported it. It’s been under discussion for about 11 years in this town and I think it’s long past the time to finally recognize the IRGC as the terrorists they are, they’ve been killing and maiming thousands of Americans for years and the argument against it, which is, we shouldn’t call the terrorists terrorists because they might act like terrorists I think is a ridiculous argument.

Gigot: So what does the designation mean in practical terms? What does it allow us to do to the IRGC and how does it constrict their behavior in ways that weren’t possible before?  

Dubowitz: So we are adding the IRGC to the Foreign Terrorist Organization list, there are about 60 terrorist organizations on that list, which include Al-Qaeda and ISIS and Hezbollah, Hamas, so again recognizing this as a leading terrorist organization, one of the leading terrorist organizations in the world. It has huge practical implications for anybody who wants to do business with Iran because 20-40% of the total economy is controlled by the IRGC, so if you do business with key strategic sectors of Iran’s economy, you’re doing business with a terrorist organization, and that’s a huge risk: legal, civil and reputational for companies.  

Gigot: So if you are a, let’s say a German or a British bank and you want to finance something that the IRGC has a big stake in, in Iran, you would then risk punishment by the United States if you do that. Is that right?  

Dubowitz:  That’s right, you would risk criminal prosecution, being denied visas to enter the United States for you, potentially your family, and even though the IRGC has been designated before, this new designation under the Foreign Terrorist Organization State Department law means that if you’re providing any kind of material support at any level: financial, technical, advisory, any kind of training to the IRGC, in any capacity, you can be designated. And not only if there’s a U.S. person, but a foreign person, and not only if there’s a nexus with the U.S. financial system or a U.S. market, but even if there’s no nexus, if you’re providing any kind of support, you can find yourself in a U.S. jail.

Gigot: What’s been the reaction over the world? We know what the Iranian reaction is, but what about Europe and elsewhere, and China or Asia, where there are some people who do business in Iran? What’s been their reaction?

Dubowitz: Their reaction has been interesting, Paul. On the one hand, everybody says this is kind of earth-shattering and the IRGC is going to retaliate and they’re going to you know kill Americans, and this is a terrible decision by the Trump administration. But in the same breath they’ll tell you this is unnecessary and redundant and we already have laws that actually prohibit business with the IRGC. So you can’t really have it both ways. I think the reality is that the reaction is what it should be, and that is it makes key strategic sectors of Iran’s economy radioactive, and for anybody who continues to do business with the Islamic Republic of Iran, they should be thinking twice about that decision.

Gigot: Well you’ve raised the problem, a potential problem of retaliation and look, Iran has retaliated before, even if they try to keep their fingerprints off it through terrorism. Is there a risk to U.S. diplomats or U.S. soldiers in the Middle-East, or say Iraq, where Shiite militias that answer to Iran are in relative close proximity to U.S. troops?

Dubowitz: There has always been a risk to U.S. individuals, U.S. assets because the Islamic Republic of Iran has been at war with the United States for 40 years. So I mean the causal relationship, many people get this backwards: they’re provoking, they’re aggressive, they’re killing, they’re maiming, and the United States needs to react to that, and the worst way that we can react to that is by doing nothing, by showing that there will be no consequences for this kind of aggressive behavior. So I think it’s long past the time for the United States to finally be drawing a clear line for the IRGC that any kind of action, any kind of damage to the United States, our people and our assets will be met with all instruments of American power.

Gigot: Ok, so we have all these policies that the administration has put forward on Iran, try to isolate and pressure the regime, they call it the maximum pressure campaign. Is there any evidence that it in fact is working in a way that would change Iran’s behavior?

Dubowitz: So there was an interesting article about two weeks ago by Ben Hubbard from the New York Times who actually wrote a very detailed article, showing that as a result of this maximum pressure campaign, the regime in Iran is having to make a fundamental choice between guns and butter. And by having to make that choice they’re cutting payments and credit lines and support to Shiite militias, to Hezbollah fighters, and there’s a real financial squeeze now for these terrorist organizations and proxies that Iran has long supported. The nuclear deal, Paul gave Iran, it didn’t have to make that fundamental choice, it could have guns and butter and now that it’s having to make that choice its economy is struggling, people are on the streets protesting, and at the same time it’s having to cut these transfer payments to these dangerous regimes and surrogates, so it is making that kind of difference.

Gigot: So it’s making a difference on having them pull back from some of their promotion of terror activities and militias, but not necessarily in the nuclear program. And you’ve got about ten seconds here.

Dubowitz: Yeah they haven’t made that fundamental decision to come back to the table to negotiate, which is why I think the Trump administration needs to take the maximum pressure campaign from six where it is on the sanctions dial, all the way to eleven.  

Gigot: Alright, thank you Mark Dubowitz, appreciate it.

Dubowitz: Thanks so much.