May 13, 2013 | Memo
Iran’s Golden Loophole
Iran's Golden Loophole is a research paper, co-authored by Mark Dubowitz of the Foundation for Defense of Democracies and Gary Clark and Rachel Ziemba from Roubini Global Economics. The paper discusses how Iran is exploiting loopholes in U.S. sanctions laws to obtain gold to replenish its FX reserves. These foreign exchange reserves are Iran's principal hedge against a severe balance of payments crisis, and help Iran withstand international pressure over its nuclear program. Since July 30, 2012, when the Obama administration issued an executive order prohibiting gold exports to the government of Iran, Iran has received over $6 billion in payment in gold for its energy exports—the value of the lack of enforcement of the golden loophole—mainly as gold payments to the Central Bank of Iran. These gold exports to the Central Bank of Iran already are a sanctionable activity under existing U.S. law; gold exports to any entity in Iran will become sanctionable as of July 1, 2013. This report estimates that, unless gold sanctions are enforced, Iran could receive up to $20 billion a year, representing around thirty percent of Iran’s projected 2013 energy exports.