Testimony of Mark Dubowitz before the Senate Committee on Banking, Housing, and Urban Affairs

Understanding the Role of Sanctions Under the Iran Deal
May 24, 2016

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Iran is engaged in a robust effort to legitimize its financial sector despite a decades-long rap sheet of financial crimes and illicit financial activities that it shows no sign of curbing. Since the conclusion of the JPCOA, the Obama administration has missed numerous opportunities to push back against Iran’s legitimization campaign. Instead of insisting on an end to Iran’s continuing malign activities (terrorism, human rights violations, and other destabilizing activities in Syria, Iraq, Yemen, Lebanon, and other countries across the Middle East), and using non-nuclear sanctions to deter and punish these activities, the administration is now effectively acting as Iran’s trade promotion and business development authority. Indeed, the administration may be departing from its original JCPOA negotiating position that it would only suspend or lift socalled U.S. “nuclear sanctions” under its executive authority. Rather, the administration is allowing Iran to hold the U.S. responsible for delivering financial and economic outcomes.

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