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Testimony

Increasing the Effectiveness of Non-Nuclear Sanctions Against Iran

Testimony for House Financial Services Monetary Policy and Trade, and Terrorism and Illicit Finance Subcommittees
4th April 2017

Download the full testimony here. 

Our present discussion on how to push back against Iran’s enduring “non-nuclear” threats is a product of diplomatic developments from the summer of 2015, when international negotiators from the P5+1 and Iran agreed to the Joint Comprehensive Plan of Action (JCPOA) nuclear deal. Despite its name, the agreement, which provided the Islamic Republic with over $100 billion in upfront sanctions relief,[1] was anything but comprehensive. The JCPOA only temporarily deals with select aspects of the Islamic Republic’s illicit nuclear program. The agreement does not address issues relevant to delivery vehicles like ballistic missiles,[2] despite assessments from the U.S. intelligence community that ballistic missiles were Tehran’s “preferred method of delivering nuclear weapons.”[3] Compounding this problem, United Nations Security Council Resolution (UNSCR) 2231, which enshrined the accord,[4] features an Annex containing watered-down prohibitions on missile testing, further indicative of an Iranian negotiating victory.[5]

And missiles are not the only challenge that the deal overlooked. The accord does not address Iran’s illicit financial activities, support for terrorism, regional destabilization, and flagrant human rights abuses. These issues constitute Iran’s enduring non-nuclear threats. They are “enduring” because they are the same issues that have made and kept Iran an international pariah.

With the removal or waiving of nuclear sanctions pursuant to the JCPOA as well as the informal sanctions relief Iran has received, it has become considerably difficult to influence the behavior of what Secretary of Defense James Mattis has called the “biggest state sponsor of terrorism.”[6] Assuming that the nuclear accord will remain in place,[7] the immediate challenge for U.S. policy will be how to identify and erode Iran’s non-nuclear threats. Such endeavors are not impossible, but require considerable political will and commitment over a long period of time.


[1] Adam Szubin, “Written Testimony of Adam J. Szubin, Acting Under Secretary of Treasury for Terrorism and Financial Intelligence United States Senate Committee on Banking, Housing, And Urban Affairs,” Testimony before Senate Committee on Banking, Housing, and Urban Affairs, August 5, 2015. (https://www.treasury.gov/press-center/press-releases/Pages/jl0144.aspx)

[2] Behnam Ben Taleblu, “Don’t Forget Iran’s Ballistic Missiles,” War on the Rocks, August 25, 2014. (https://warontherocks.com/2014/08/dont-forget-irans-ballistic-missiles/)

[3] James R. Clapper, “Statement for the Record, Worldwide Threat Assessment of the US Intelligence Community,” Testimony before the Senate Select Committee on Intelligence, January 29, 2014, page 6. (http://online.wsj.com/public/resources/documents/DNIthreats2014.pdf)

[4] United Nations Security Council, “Resolution 2231 (2015): Ballistic missile-related transfers and activities,” accessed March 25, 2016. (http://www.un.org/en/sc/2231/restrictions-ballistic.shtml)

[5] See positions in: Parisa Hafezi and Louis Charbonneau, “Iran demands end to U.N. missile sanctions, West refuses,” Reuters, July 6, 2015. (http://www.reuters.com/article/us-iran-nuclear-idUSKCN0PF0HG20150706). In 2014, Iranian officials held the line on not including missiles in talks. “روحانی: توان موشکی ایران به هیچ وجه قابل مذاکره نیست (Rouhani: Iran’s Missile Capabilities Are By No Means Negotiable),” Kayhan (Iran) August 17, 2014. (http://kayhan.ir/fa/news/21352)

[6] Defense Secretary James Mattis quoted in: “Iran is world’s biggest state sponsor of terrorism, US says,” BBC News (UK), February 4, 2017. (http://www.bbc.com/news/world-us-canada-38868039)

[7] While it is too soon to tell what the Trump administration’s policy will be with respect to the JCPOA, there are indications that the administration desires to keep the deal in place in the short-term. Specifically, Christopher Ford of the National Security Council told a conference hosted by The Carnegie Endowment for International Peace, “Until otherwise decided, the United States will adhere to the Iran nuclear deal and ensure that Iran also does.” “White House Adviser Says Will Honor Iran Nuclear Deal, Ensure Iran Complies,” Radio Free Europe/Radio Liberty, March 22, 2017. (http://www.rferl.org/a/white-house-aide-ford-says-honor-iran-nuclear-deal-ensure-iran-complies/28383425.html