Former Acting Under Secretary for Terrorism and Financial Intelligence Adam Szubin writes to the Senate Foreign Relations Committee on Iran Sanctions

May 12, 2017

Dear Mr. Chairman and Mr. Ranking Member:

I am writing to express my concerns regarding the Countering Iran's Destablizing Activities Act of 2017 (S. 722).

In my view, the Countering Iran's Destablizing Activities Act as currently written:

a) would provoke a terrible reaction in Iran and with our allies, as it would be seen as contrary to at least the spirit of the Joint Comprehensive Plan of Action (JCPOA); and b) would contribute no benefit, as it would impose no additional pressure on Iran's malign activities outside of the nuclear space.

As such, I think it would be harmful to our interests to pass this bill.

If it is going to move forward, I would support the following amendments:

Sec (4a)(1)- Strike ", or poses a risk to materially contributing,".

Sec 8: Strike Sec 8 OR add an exception to allow for fulfilment of the U.S.'s JCPOA Transition Day obligations, such as inserting at the end of subsection (a): ", except as required by the JCPOA, provided the President submits a report no later than six months prior to Transition Day, identifying any steps to be taken to address concerns that may exist with respect to entities proposed to be removed from sanctions at that time."

Thank you for your leadership, and please let me know if I can be of assistance as you consider this important issue.


Adam Szubin
Former Acting Under Secretary, Office of Terrorism and Financial Intelligence,
U.S. Treasury Department