Letter on New Iran Trade Vehicle

July 16, 2019


Foundation for Defense of Democracies

The Honorable Steven Mnuchin
United States Secretary of the Treasury
1500 Pennsylvania Avenue, NW
Washington, D.C. 20220

Dear Mr. Secretary:

We are writing to respectfully request that you examine whether Iran’s counterpart to a new European trade vehicle formed to evade U.S. sanctions on Iran meets the criteria either for designation for being owned or controlled by designated Iranian entities subject to U.S sanctions, or for designation under Executive Order 13846. We believe it does.

Set up by Germany, France, and the UK, the new trade vehicle, formally known as the Instrument for the Support of Trade Exchanges (INSTEX), was established to avoid U.S. sanctions by enabling trade without using the U.S. dollar or going through U.S. banks. Iran’s counterpart, the Special Trade and Finance Instrument (STFI), was registered in April in Tehran’s neighborhood of Davudieh, near the headquarters of the Central Bank of Iran (CBI). According to the French Ministry of Economy and Finance, the STFI has eight shareholders.


Read the full letter at the Foundation for Defense of Democracies.