Pressure Begins on Iran

Pressure Begins on Iran (The Art of Sanctions – Part 7)

The Art of Sanctions – Pressure Begins on Iran: In 2007, the united states sought to increase the pressure on Iran dramatically by convincing the rest of the world that the Iranian nuclear program was accelerating in direct violation of Iran’s international obligations and in a manner that was likely to grant Iran a nuclear weapons option. The Iranians gave us plenty of ammunition, starting with the decision to restart uranium enrichment at the underground facility at Natanz. This decision permitted the United States to articulate clearly the decreasing opportunity to arrest Iran’s nuclear program before it would be necessary to decide between preemptive military action and acquiescence to a de facto Iranian nuclear weapons capability.

Our argument simplified quickly from “if the Iranians were to restart their uranium enrichment work, then…” to “every month Iran enriches uranium and expands its program, they get closer to nuclear weapons.” In diplomacy, simplicity works.

Mauood’s Introduction: The author of the present book (The Art of Sanctions) is Richard Nephew. Richard Nephew was in charge of the sanctions team against Iran during Obama’s second term. He supported the nuclear negotiators in the matter of sanctions in Vienna. Richard Nephew has previously served for ten years as an Iran member of the National Security Council at the White House and as Deputy Secretary of State for Coordination of Sanctions at the State Department. The book is also translated into Persian by the Iranian Parliamentary Research Center (IPRC).

Note: The content of this book is not approved by us and is published solely to familiarize policymakers with the views, approaches, and methods of the designers of sanctions against Iran.

Continuing Pressure Under President George W. Bush

That said, the specter of Iraq haunted U.S. efforts and complicated our ability to galvanize international cooperation early on. First, there was the prevailing (and, to some, open) question of whether our understanding of Iran’s nuclear intentions was flat wrong. In early 2007, there were isolated, public references in IAEA reports about past Iranian nuclear weapons work but hardly anything conclusive. Moreover, uranium enrichment—like so many other sensitive nuclear activities—is not only permitted under the NPT but is also a guaranteed right in the opinion of some international readers.

The United States did not share this interpretation and felt convinced that Iran’s intentions were military in nature, but winning this argument was undoubtedly complicated by the legacy of Iraq, the discredited nature of U.S. intelligence on WMD, and the absence of clear proof that Iran was in fact developing a nuclear warhead.

Consequently, the strategy that evolved in 2007 was one that can be said to have loosely centered on three assumptions: r There is enough evidence that Iran’s nuclear program could be used to support nuclear weapons rather than nuclear power to create uncertainty in the minds of Iran’s erstwhile international trading partners. Moreover, Iran’s long legacy of bad acts and continuing support for terrorism and violations of human rights at home help create reputational risk in doing business with Iran.

  • The reputational risk that foreign partners perceive is insufficient to prompt a wholesale departure from the Iranian economy, particularly given the number of contractual entanglements that might exist. Crude oil exports, natural gas purchases, and major investments will be hard to sever absent more compelling indications of bad acts. The resources they supply are too valuable, as are the profits of the third-party companies involved (many of which are state owned or have strong ties to governments).
  • Although a head-on approach to Iran’s key national assets—such as its oil and gas industry—will be difficult to engineer, there are other ways of undermining those assets. Put another way, while going after the muscles of the Iranian body economic would be difficult, the tendons, ligaments, and joints were fair game and more susceptible to damage.

The United States spent 2007 and 2008, in particular, identifying all of that connective tissue.

The most obvious targets were Iran’s links to international banking and its involvement in the international financial sector. In 2007, Iran was—by and large—a “normal” country for international finance. Of all the world’s significant economies in 2007, only the United States had imposed direct limitations on Iran’s ability to access its financial sector. Other countries had transaction- and issue-specific prohibitions; involvement in support for terrorism, money laundering, corruption, and similar such financial crimes were precluded on their own, separate substantive basis. But other countries did not see Iran itself as pervasively riddled with illicit activity and deserving of sanctions in its own right.

Consequently, the first U.S. task was to demonstrate the degree to which any business with Iran’s banks ran the risk of contributing to its illicit activities. UNSCR 1737 provided significant support in this regard, as it prohibited (in operative paragraph 6) any service that might facilitate Iran’s proliferation-sensitive nuclear activities or development of a nuclear weapon delivery system.

Financial services were particularly called out. The United States used this to its advantage by highlighting the degree to which Iran’s state-owned banks were involved in providing such financial services. In part on this basis (as well as specific information about its involvement in nuclear proliferation), the UNSC designated Iran’s Bank Sepah in its next resolution, UNSCR 1747, adopted in March 2007.

This designation—as well as the accompanying designations of six members of the IRGC—allowed the United States to connect dots for international firms and ask a question that—to this point—was missing in the business discourse:

Can you prove that you’re not providing support to Bank Sepah or to the IRGC, including these officers? Banks around the world added Bank Sepah to their screening lists, as well as all of the rest of the UN-designated individuals and entities. More importantly, they started to probe into the extent of their knowledge of Iran’s economy and their ties to it. They did not like what they found, particularly when the United States provided information (and imposed further sanctions) that outlined the degree to which other Iranian banks were taking up Sepah’s slack and providing financial services to the IRGC and other actors in Iran.

One of the most significant U.S. actions in this regard was the imposition of sanctions on the IRGC itself, Iran’s Ministry of Defense and Armed Forces Logistics, Banks Melli and Mellat, and many other entities on October 25, 2007.[1] The press release outlined the degree to which Iran’s banks were not only participating in but also complicit with the illicit activities of Iranian security services.

The United States government took this declassified information and lobbied governments—and, more important—banks and companies to curtail their association with these entities and individuals.

Additionally, the United States saw other potential targets for the same strategy, essentially any other service provider that could not guarantee its noninvolvement in illicit Iranian activity. The next sector vulnerable to such pressure was transportation.

Throughout 2007, the United States looked for opportunities to deny Iran access to shipping and transportation services that could facilitate illicit cargo. The argument sintered down to: Iran has spent the past twenty years exploiting the international economy and its transportation links to support its proliferation efforts. Can you prove that you’re not involved?

The argument got boosts along the way, starting with the continuing IAEA exploration of Iran’s nuclear procurement efforts beginning in the 1980s. During the fall of 2007, the IAEA worked with Iran to try to close lingering issues of past noncompliance, setting aside the insurmountable problem of Iran’s continuing violations of its UNSC obligation to suspend enrichment and other nuclear activities. The IAEA’s investigation demonstrated that Iran purposefully evaded international export controls for its own purposes and took advantage of its integration in the global economy to do so.

Iran’s defense was that international sanctions precluded its ability to engage in normal commerce, requiring it to enlist the services of at least one university to obtain necessary components.[2] Iran essentially admitted to widespread sanctions evasion, proving—from the U.S. perspective—that evasion was not only happening but also that a sanctions compliance approach dependent on avoiding links to explicitly designated entities could be insufficient. And, true to form, Iran continued with this practice, finding new intermediaries to purchase items that sanctions had precluded.

In this way, the Iranian government ensnared ever-larger parts of its economy in illegitimate acts, essentially opening itself up to a wider range of sanctions targeting; in struggling against the sanctions regime, Iran made it easier to intensify the pressure on its economy.

All the while, the United States sought to delegitimize otherwise normal commerce with Iran. UNSCR 1747 was helpful in this regard, calling for “states and international financial institutions not to enter into new commitments for grants, financial assistance, and concessional loans, to the government of the Islamic Republic of Iran, except for humanitarian and developmental purposes.”[3]

The international financial institutions—the IMF and World Bank, in particular—were already essentially walled off from Iran programs on the basis of the U.S. voting strength and ability to stop any projects from going forward. But by signaling to states that extending support for trade and investment deals in Iran was frowned upon, the UNSC accelerated Iran’s separation from normal economic life.

UNSCR 1803—adopted in March 2008—amplified this problem for Iran, which was intentional on the part of the United States. We knew that obtaining UNSC support for major economic sanctions remained impossible. But we could see that our efforts to target the interconnections between Iran and the global economy were starting to complicate Iranian life—even if the Iranian economy had seen no significant drop in performance along the major economic indicators.

Iranian GDP growth remained healthy, around 6.2–6.6 percent, and although inflation and unemployment were high, the IMF in 2008 predicted continued strong performance so long as oil prices remained high.[4] The IMF expressed concern that structural reforms were insufficient and that divestment by the state of its interest in various companies and entities was limited, in that they were mainly going into the hands of quasi-state actors (which subsequently appear likely to have been mostly IRGC-related enterprises). But the IMF saw no indication that imminent trouble was on the horizon for Iran.

The United States, however, saw things differently because Iran’s access to the normal currents of international commerce was becoming constrained. As then Undersecretary of the Treasury Stuart Levey testified before the Senate Finance Committee on April 1, 2008:

“the world’s leading financial institutions have largely stopped dealing with Iran, and especially Iranian banks, in any currency. Foreign-based branches and subsidiaries of Iran’s state-owned banks are becoming financial pariahs—threatening their viability—as banks and companies around the world resist dealing with them.”[5]

In UNSCR 1803, the United States saw an opportunity to magnify these problems by focusing on three areas: financial services; shipping and transportation; and export credits and guarantees. The first two elements involved new language and authorities such as an option for states to inspect shipping conducted by the Islamic Republic of Iran Shipping Lines (IRISL) and Iran Air Cargo—but their overall mindset was much in keeping with a two-year-old strategy: to undermine Iran’s claim of normalcy and legitimacy, and to increase the sense of risk in international businesses and banks.

By targeting export credits and guarantees, however, we looked to undermine the economic basis whereby business with Iran could be profitable within normal risk tolerances. Here, we took advantage of some knowledge of Iran and business practices with and within it.

It is no surprise to anyone with even a modicum of knowledge about Iran that, following the Iranian revolution, there was widespread concern among business operators that government actors could expropriate assets in Iran without warning; the fact that Prime Minister Mossadegh nationalized Iran’s oil industry in 1953 was not lost on anyone operating in Iran’s oil and gas sector, and of course Iran went even further in the aftermath of the Iranian Revolution.

The Iranian Constitution explicitly conveys ownership of all oil and gas resources to the state. Oil and gas companies that did invest in Iran after the Revolution found their greatest difficulty was navigating this political reality while remaining profitable, not easy in a business that has been to some degree dependent on “booked” reserves to drive investment.

Export credits and guarantees were used by governments around the world to provide some sense of protection to the companies that sought to do business in Iran anyway, essentially by putting the full faith and credit of their associated governments on the line in the event of an adverse political event in Iran. Even prior to the adoption of UN Security Council Resolution 1803, the German government had limited its willingness to extend export credits to businesses trading with Iran sharply.[6]

After UNSCR 1803, this trend intensified even though the resolution did not legally prohibit credits or guarantees and merely called for vigilance. The European Union adopted a Common Position on August 7, 2008, that required restraint on the part of EU member states with respect to such credits and guarantees. Others noticed the shift and took similar steps, as the then chief economist of Australia’s export credit agency also noted in August 2008.[7]

This came on top of banks being unwilling to lend to Iran or to businesses interested in operating in Iran. The result was that Iran had to find companies prepared to absorb the risk of business in Iran on their own, companies capable of obtaining other forms of risk insurance or self-finance. Levey later testified on October 6, 2009, that:

Iran’s foreign borrowing has sharply declined since 2006, a significant change from 2002 to 2005, when foreign credit growth to Iran outpaced that of the wider Middle East. External credit to Iran fell 18 percent between September 2006 and September 2008, in stark contrast to the 86 percent rise in external credit to the Middle East region during the same period. And, to the extent that Iranian firms have been able to replace lost credit with domestic credit, they are likely doing so at a much higher cost.[8]

Of course, this was not the end of the U.S. national sanctions campaign, which expanded to target insurance providers as well.[9] The United States sought to tie all types of services to the underlying potential illicit acts. In so doing, it spread the burden and risks of business with Iran to wider circles of the global economy. And to this point, the United States had acted without having actually impeded the sale of Iranian crude oil, still Iran’s most vital natural resource and export revenue generator.

One key mechanism for achieving these new sanctions pressure was the enlistment of what we called the “Likeminded” in the development of their own sanctions regimes, which we dubbed “coordinated national measures.” This project began small and in the shadow of Russia’s invasion of Georgia in the summer of 2008, which ended negotiations around a successor UNSC resolution to UNSCR 1803.

Though some of the main elements of this successor resolution would find their way into resolution 1929 (adopted during the Obama administration), at the time, prospects were not high that the United States and Russia would work again on a substantive resolution that targeted Iran. UNSCR 1835 was adopted in September 2008, but it was largely rhetorical, serving as a capstone to the Bush administration’s efforts and handing the ball off to the next administration.

But, through coordinated national measures, the United States sought to obtain some of the benefits of a UNSCR without having to go through the Russians and Chinese. At first, this effort largely resulted in a “démarche club,” in which the United States and key partners—Germany, France, and the United Kingdom to start—would prepare messages for particular targets, pressing them to stop business in one area or another.

Over time, the group expanded to include Italy, Japan, South Korea, Saudi Arabia, the United Arab Emirates, Canada, and Australia, as well as work to develop specific sanctions measures. During a series of senior-level meetings held in Rome, Ottawa, and Washington, the United States laid the groundwork for a sanctions onslaught to come under President Obama.

The Beginning of the Obama Administration

Most of what has been written about the early Obama administration’s Iran policy fixates on the renewed offer of engagement made by President Obama both publicly and in a letter conveyed to Supreme Leader Khamenei in the spring of 2009. This effort was important, as it helped set the context for Iranian-American relations over the next eight years. It was a means of persuading the international community that the United States was taking the engagement track of P5+1 Iran policy seriously. Doing so had merit on its own, but it also served as a crucial component of the sanctions track that, if Iran refused to take advantage of Obama’s kind offers for negotiations, would be even more important.

In fact, throughout the spring and summer of 2009, sanctions experts at the Departments of State and Energy were working away at developing further ideas for sanctions against Iran. As noted above, some of this work was already done: I had a list of sanctions ideas that I perpetually checked off as UNSCRs were adopted and national measures were imposed, and that I added to as new ideas occurred to us.

In fact, over the summer of 2009, the direction of the National Security Council and Secretary of State Clinton, the State Department began to develop specific baskets of sanctions measures, refining the options within them into one-page, simple proposals that described the sanctions measure, offered context about its value, advantages, and disadvantages, and conveyed a sense of how it could best be executed.

This work was conducted under the direction of Ambassador Steve Mull, then serving as an at-large senior advisor of Under Secretary of State Bill Burns; I served as a deputy of sorts to Ambassador Mull, working with the rest of the State Department as well as with Treasury to flesh out these baskets of options.

Our sanctions baskets covered Iran’s energy, transportation, and financial sectors, as well as its nuclear program, arms industry, and diplomatic access to the outside world. These proposals were briefed to the NSC’s Deputies Committee in September 2009, simultaneous with efforts to develop confidence-building measures that could be offered to Iran as part of a renewed diplomatic strategy.

This latter effort included the Tehran Research Reactor (TRR) project, which was formally proposed to Iran in October 2009 (and which I also worked on). This project offered to provide nuclear fuel for the TRR in exchange for the removal from the country most of Iran’s enriched uranium stockpile. From the U.S. perspective, this trade made good sense, as Iran would receive nuclear fuel that could not be easily used in nuclear weapons, while its creeping stock of more easily diverted material left the country.

Moreover, Iran would lose another reason to enrich uranium and the concept of foreign supply of nuclear fuel would be reaffirmed, damaging Iran’s narrative that it could not count on international markets and had to have an indigenous capability.

Unfortunately, Iranian politics damned this offer. Iran’s lead negotiator, Saeed Jalili, originally expressed interest in this proposal when tabled by the IAEA and Bill Burns. In fact, Jalili indicated provisional acceptance of the deal, along with an agreement to grant access to the newly public Iranian enrichment facility at Fordow—which the United States had known about for some time, but kept secret in order to suss out Iran’s intent—and to meet again with technical experts later in October.

Two weeks later, under the auspices of the IAEA, Iran, the United States, France, and Russia provisionally agreed to a TRR proposal (though some questions about how it would be orchestrated remained open and unresolved), sending it back to their respective governments for approval.

Quickly, it became clear that there was no political support in Tehran for the deal and that a renewed sanctions push might be necessary. At the end of October, anticipating a possible Iranian “no” answer, I led a small team to Brussels and Madrid to brief the EU and Spanish governments (which, at the time, served as the EU’s president) on our sanctions work. We went through each of our sanctions ideas, laying the groundwork for future EU sanctions deliberations in anticipation that they would be needed but all the while hoping Iran would see the sense of the TRR deal.

Politics intervened in Tehran, involving even reform-minded politicians who opposed President Ahmadinejad’s effort to cut a deal with the United States. Ahmadinejad had been badly damaged in Iranian politics with his disastrous reelection in June 2009, one marked with protests and widespread allegations of electoral fraud. Ahmadinejad did not have the ability to deliver Iran’s agreement. In November 2009, President Obama authorized UN Ambassador Rice, Secretary Clinton, and Secretary Geithner to have their teams move forward with sanctions.

This took three forms, all of which proceeded together as part of an integrated, cohesive strategy: United Nations sanctions; informal multilateral measures; and U.S. domestic pressure on foreign corporations and banks.

First and foremost, there was the UN track. Though expectations for major UN sanctions were appropriately held in check, there was acknowledgment within the administration that the imprimatur of the UNSC would go a long way in convincing states to both implement the measures adopted by the UNSC (which, though a legal requirement, is far from assured in practice) and build upon those measures with national steps.

Ambassador Rice and her team began working directly with their UN mission counterparts on the outlines of a sanctions resolution, drawing from ideas held since mid-2008’s aborted attempt. Soon the interagency team was holding frequent videoconferences to develop concepts, back-up approaches, and notional language.

The administration identified critical concepts, as well as “good to have” options. Our focus settled on four key elements, all of which found their way into resolution 1929, adopted on June 10, 2010.

PROVIDING A HOOK FOR FURTHER ENERGY SANCTIONS. It was clear from the start that the UNSC would not adopt specific, legally binding prohibitions on Iranian energy exports, even though the United States had identified them as a crucial pathway for creating sustained economic pressure on Iran due to Iran’s reliance on oil exports for hard-currency earnings. We therefore asked our partners in Europe and Asia what they would need in order to push through their own national sanctions against Iranian energy supplies.

We learned that preambular language in the resolution that identified Iran’s energy sector as a problem would be sufficient. We crafted language that spoke to two elements of the notional threat: first, that Iran’s energy sector provides Iran the wherewithal to evade the pressure of sanctions; and, second, that it could serve as a cover for Iran’s procurement of nuclear and missile-related dual-use goods. The resulting UNSC language did just that:

Recognizing that access to diverse, reliable energy is critical for sustainable growth and development, while noting the potential connection between Iran’s revenues derived from its energy sector and the funding of Iran’s proliferation-sensitive nuclear activities, and further noting that chemical process equipment and materials required for the petrochemical industry have much in common with those required for certain sensitive nuclear fuel cycle activities.[10]

CONTINUING TO TAR IRAN’S FINANCIAL SECTOR AS RIDDLED WITH ILLICIT ACTIVITY AND TO BE AVOIDED. Just as with the previous three resolutions imposing sanctions on Iran, the administration wanted to deepen Iran’s financial isolation and make it easier for foreign governments to impose their own restrictions on Iran-related finance. This includes direct banking as well as export assistance, insurance, and all manner of finance-related services.

The resulting UNSC resolution did that in multiple places in the main text and, crucially, also required the freezing of assets for one named Iranian bank—First East Export Bank—and the Iranian Revolutionary Guard Corps (IRGC) main legitimate business front, Khatam al-Anbia.

AUGMENTING UNSC AUTHORITIES FOR THE INSPECTION AND INTERDICTION OF CARGO. Even though states were permitted to inspect cargo and prevent the onward passage of sensitive goods to Iran from the start of the UNSC sanctions regime in 2006, many did not appreciate the sweep of their authorities. The administration prioritized giving states greater clarity about their ability to inspect, seize, and dispose of illicit cargo, ranging from sensitive nuclear and missile goods to conventional arms.

INTENSIFYING THE EFFORT TO IDENTIFY AND REPORT VIOLATIONS OF THE UNSC SANCTIONS REGIME. The administration sought and secured language in the resolution that provided for the creation of a “Panel of Experts” to aid the UNSC and member states with the implementation of their obligations.

This panel soon became an invaluable part of the international community’s effort to track and identify for public awareness Iran’s attempts to evade sanctions, resulting in the formulation of guidance and advice on best practices for states to use in their own implementation of the resolution. The panel’s inspection reports of illicit cargo identified and seized were particularly useful in stigmatizing Iranian cargo shipments, particularly when entities and individuals affiliated with the IRGC were caught breaking the embargo in West Africa in 2010.[11]

As noted, the UNSC track was not the only one of significance in 2009–2010. The United States also sought to encourage national measures by our partners, and we worked with Congress on a new piece of U.S. sanctions legislation.

Partner sanctions were seen as a necessary, complementary element of UNSCR 1929 from the start. The United States worked closely with the European Union, Japan, South Korea, Australia, Canada, and others to develop sanctions options that would track the measures included in the UN resolution and augment their impact. Two particular elements stand out.

First, partners—particularly in the EU, Japan, and South Korea—agreed to forgo investments in Iran’s oil and gas sector, as well as to withdraw any residual financial and technical support. Although these governments did not prohibit the purchase of Iranian oil and gas, this decision had two important, damaging effects on Iran: it deprived the Iranian government of the resources needed to maintain, improve, and expand existing production facilities; and it signaled that Iran’s energy resources were legitimate, acceptable targets for sanctions pressure.

A concomitant U.S. announcement that it would begin investigations under the Iran Sanctions Act of companies involved in Iranian oil and gas investments helped to create impetus for this measure, as did a newly adopted “Special Rule” that would grant leniency for those entities that exited the Iranian market swiftly.[12]

Second, partners agreed to treat Iran’s financial sector like a pariah, requiring preauthorization for a variety of transactions falling above certain financial thresholds (e.g., valued at over 40,000 euro) or involving certain parties. Iran’s ability to engage in normal business was compromised as a result. But, perhaps more important, the sense of normalcy around Iran’s economy was badly damaged. Iran was seen as being “special,” and not in a good way. Iran business would be complex, difficult to manage, and potentially costly. The result was that, although some large companies persevered and some small companies took the risk, there was a flood of institutions out of Iran in 2010.

The U.S. sanctions legislation accelerated this exodus. In June 2010, just after the UNSCR was adopted, President Obama signed into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA). CISADA was comprised of many different forms of sanctions measures, some of which intensified existing U.S. sanctions on oil and gas investment in Iran or the penalties associated with breach of the U.S. sanctions regime. But by far the most important provision of CISADA was to be found in Section 104, which created the basis for essentially a financial embargo of Iran.

In this provision—which had been negotiated laboriously by executive branch and legislative branch representatives starting in 2009—the United States acquired the power to turn off foreign bank access to the United States if those foreign banks were found to be processing transactions either for U.S.-designated Iranian financial institutions or the IRGC.

With the expansion of the U.S. designation list of Iranian banks, the international financial system found that any transaction with Iran risked the possibility of losing access to the United States. Even though some financial institutions without a U.S. link might survive such a sanction with little difficulty, multinational banks feared this provision and joined the rush of entities abandoning business with Iran. The plain truth was that Iran was a lucrative market, but the United States was more so. It simply made no economic sense to risk U.S. access for the opportunities that existed in Iran.

These three levels of sanctions—UN, multinational, and corporate (enforced by U.S. coercion)—hammered Iran from a variety of different angles starting in June 2010 with UNSCR 1929’s adoption. By the end of the summer of 2010, Iran faced similar bad news nearly every week, with U.S., EU, Japanese, Korean, Australian, and Canadian legislation all being adopted and enforced. The pressure was intense, unrelenting, and sustained. Unfortunately, it did not generate any meaningful Iranian negotiation concessions, despite being increased steadily over the next two years.



1. U.S. Department of the Treasury, “Fact Sheet: Designation of Iranian Entities and Individuals for Proliferation Activities and Support for Terrorism,” October 25, 2007,

2. IAEA Report to the Board of Governors, “Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737 (2006) and 1747 (2007) in the Islamic Republic of Iran,” February 22, 2008,

3. UN Security Council Resolution 1747, Adopted March 24, 2007,

4. International Monetary Fund, “Public Information Notice No 08/86: IMF Executive Board Concludes 2008 Article IV Consultation with the Islamic Republic of Iran,” July 18, 2008,

5. U.S. Department of the Treasury, “Under Secretary for Terrorism and Financial Intelligence Stuart Levey Testimony,” April 1, 2008,

6. Bertrand Benoit, “Berlin Hardens Trade Stance with Iran,” Financial Times, February 11, 2008,

7. Export Finance and Insurance Corporation, “Escalating Sanctions Are Squeezing Iran’s Economy: EFIC,” August 4, 2008,

8. U.S. Department of the Treasury, “Testimony of Stuart Levey, Under Secretary Office of Terrorism and Financial Intelligence,” October 6, 2009, A699FF535D59925 B69836A6E068FD0.leveytestimony10609.pdf.

9. Daniel Dombey, “U.S. Imposes Fresh Sanctions on Iran,” Financial Times, September 11, 2008,

10. Text of UNSCR 1929, June 10, 2010,

11. Treasury Department Press Release, “Treasury Targets Iranian Arms Shipments,” March 27, 2012.

12. The successor to ILSA, which had the Libya-related prongs removed following Libya’s 2003 decision to give up its WMD programs and support for terrorism.


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