Iran’s Deceptive Financial Practices

FDD’s Center on Sanctions and Illicit Finance (CSIF) hosted a by-invitation-only lunch event on Iran’s Deceptive Financial Practices, featuring remarks by Sigal Mandelker, Under Secretary of the Treasury for Terrorism and Financial Intelligence on Tuesday, June 5, 2018. Her remarks were followed by an expert panel discussion featuring Mark Dubowitz, chief executive of FDD; Richard Goldberg, Senior Advisor at FDD; Carlton Greene, Partner at Crowell & Moring; and Elizabeth Rosenberg, Senior Fellow at CNAS.

Following the president’s announcement of U.S. withdrawal from the JCPOA, Under Secretary Mandelker and her team at Treasury have been tasked with applying “the strongest sanctions in history” by rebuilding the financial pressure architecture against the Iranian regime and its financiers. What actions have been taken thus far and what additional measures should the policy community, compliance officials, and the private sector expect to see in the coming weeks and months? How is Treasury working with our European, Gulf, Asian, and Latin American allies to promote a productive and effective approach in deterring Iran’s illicit financial activities? As the Iranian people have taken to the streets decrying the failures of their government, what role can Washington play in combating the corrupt Iranian regime and supporting a prosperous future for the Iranian people?

Sigal P. Mandelker serves as Under Secretary of the Treasury for Terrorism and Financial Intelligence. In her role, Ms. Mandelker is charged with developing and implementing U.S. government strategies to combat terrorist financing and money laundering, as well as other policies and programs to fight financial crime. She is responsible for leveraging the department’s unique regulatory and enforcement functions to help safeguard the financial system from illicit use and combat terrorist financiers, weapons of mass destruction proliferators, money launderers, drug kingpins, and other national security threats. Most recently, Under Secretary Mandelker served in senior law enforcement and national security positions at the U.S. Department of Justice and Department of Homeland Security. As Deputy Assistant Attorney General in the Criminal Division of the Department of Justice, Ms. Mandelker oversaw four major prosecutorial sections and a number of significant cross-border prosecutions involving cybersecurity, human rights, money laundering, and other national security and law enforcement priorities. Previously, she served as Counselor to the Secretary of Homeland Security, Counsel to the Deputy Attorney General, as an Assistant United States Attorney in the U.S. Attorney’s Office for the Southern District of New York, and as a Special Assistant to the Assistant Attorney General for the Criminal Division. Prior to her confirmation, Under Secretary Mandelker was a partner at Proskauer Rose LLP.  She also served as a law clerk to the Honorable Clarence Thomas, U.S. Supreme Court, and to the Honorable Edith H. Jones, U.S. Court of Appeals for the Fifth Circuit.

Mark Dubowitz is chief executive of the Foundation for Defense of Democracies, where he leads projects on Iran, sanctions, countering threat finance, and nonproliferation. He is an expert on Iran’s nuclear program and global threat network, and is widely recognized as one of the key influencers in shaping sanctions policies to counter the threats from the Iranian regime. Mr. Dubowitz was featured as one of the key “financial warriors” in the book “The Iran Wars.” Mr. Dubowitz has advised the Trump, Obama, and Bush administrations and lawmakers on both sides of the aisle on Iran issues and testified more than twenty times before the U.S. Congress and foreign legislatures. A former venture capitalist and technology executive, Mark heads FDD’s Center on Sanctions and Illicit Finance and is the author or co-author of over twenty studies on economic sanctions and Iran’s nuclear program.

Richard Goldberg is a senior advisor at the Foundation for Defense of Democracies. From 2004-2014, he worked on Capitol Hill, serving as deputy chief of staff and senior foreign policy adviser to former U.S. Sen. Mark Kirk of Illinois. From 2015-2017, he served as deputy chief of staff for legislative affairs and later chief of staff for Illinois Gov. Bruce Rauner. In the Senate, Mr. Goldberg emerged as a leading architect of the toughest sanctions imposed on the Islamic Republic of Iran. He was the lead Republican negotiator for three rounds of sanctions targeting the Central Bank of Iran, the SWIFT financial messaging service and entire sectors of the Iranian economy. Mr. Goldberg also drafted and negotiated legislation promoting human rights and democracy in Iran, including sanctions targeting entities that provide the Iranian regime with the tools of repression. His Iran sanctions work was featured in the book “The Iran Wars.”

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Mr. Greene is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act. Before joining FinCEN, he previously served as the assistant director for transnational threats with the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), where he directed targeting and investigations for more than 15 U.S. economic sanction programs, including those related to Iran and North Korea. Carlton also served as legal counsel to OFAC on counterterrorism sanctions. Previously, he was appointed by the United Nations Secretary-General to advise the UN Security Council on international sanctions against Al-Qaida and the Taliban and to lead member state visits to assess compliance. Mr. Greene also previously served as a trial attorney at the U.S. Department of Justice, where his practice included representing OFAC on sanctions issues.

Elizabeth Rosenberg is a Senior Fellow and Director of the Energy, Economics and Security Program at the Center for a New American Security. In this capacity, she publishes and speaks on the national security and foreign policy implications of energy market shifts and the use of sanctions and economic statecraft. She has testified before Congress on energy and financial issues and been quoted widely by leading media outlets in the United States and abroad. From May 2009 through September 2013, Ms. Rosenberg served as a Senior Advisor at the U.S. Department of the Treasury, to the Assistant Secretary for Terrorist Financing and Financial Crimes, and then to the Under Secretary for Terrorism and Financial Intelligence. In these senior roles she helped to develop and implement financial and energy sanctions. From 2005 to 2009 Ms. Rosenberg was an energy policy correspondent at Argus Media in Washington D.C., analyzing U.S and Middle Eastern energy policy, regulation and trading.