Key Points

Mr. Trump and many Republicans have been reluctant to promote democracy and civil society overseas. They would be wise to overcome this hesitation and play every card they have against the regime to build the broader base of support, at home and abroad. The clock is ticking.

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The U.S. has successfully pressured Tehran until now. Key indicators such as projected GDP growth and inflation testify to the strength of U.S. sanctions up to this point. Yet the decelerating rate of inflation and appreciation of the rial may be a sign that the markets doubt whether U.S pressure will be forceful enough in the coming months. As such, the United States must increase pressure on the clerical regime by significantly cutting Tehran’s oil exports, limiting its access to hard currency, and sanctioning additional entities that ensure the stability of Iran’s economy and Tehran’s grip on power.

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Every hiccup in establishing the SPV benefits Washington, which has held up a public posture of indifference to the effort.

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This resource guide is not meant to offer legal advice, which should be provided by general counsel. However, it will provide governments, risk managers, and compliance officers with data sets to support enhanced and comprehensive due diligence before doing business with Iran.

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Washington should have a zero tolerance policy on abuses of the humanitarian channel. SWIFT should automatically and permanently expel any Iranian bank using the humanitarian channel for illegal purposes. Any non-Iranian bank or company caught engaging in money laundering, corruption, and illicit financial transactions should face the full weight of Treasury’s sanctions and the Justice Department’s law enforcement capabilities.

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Projects