I. EXECUTIVE SUMMARY

For 30 years, the United States and its international partners imposed a strict sanctions regime against the Government of Iran to influence Iranian policy. In 2011, the United States and other world powers implemented crippling financial sanctions on Iran in response to the country’s enrichment of uranium and development of nuclear weapons. The sanctions took a toll on the country and its people. The pressure of effective sanctions afforded the United States an opportunity to work to achieve concessions in exchange for sanctions relief.

As the United States negotiated with Iran, one important U.S. interest consistently remained off-limits: Iran would not be granted access to either the U.S. financial system or the U.S. dollar. Foreign financial institutions were free to conduct business with the government of Iran and Iranian entities, but U.S. financial institutions continued to be barred from engaging Iran. Senior U.S. government officials repeatedly testified to Congress that Iranian access to the U.S. financial system was not on the table or part of any deal. This notwithstanding, the U.S. Department of the Treasury, at the direction of the U.S. State Department, granted a specific license that authorized a conversion of Iranian assets worth billions of U.S. dollars using the U.S. financial system. Even after the specific license was issued, U.S. government officials maintained in congressional testimony that Iran would not be granted access to the U.S. financial system. 

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