August 3, 2016
Mr. Dennis Muilenburg
The Boeing Company
100 North Riverside
Chicago, Illinois 60606
Dear Mr. Muilenberg,
We, as current and former national security professionals, write to express our great concern that the Boeing Company, along with its subsidiaries, is continuing to pursue a deal with the Islamic Republic of Iran to provide the country with commercial aircraft, parts, and technicians to modernize its aging aviation industry. This deal represents more than a business venture with an emerging market; it represents a legitimization of a State Sponsor of Terror and a direct benefit for a ruling regime responsible for gross human rights abuses, support for terrorism including threats against the U.S. and its allies, and continued provocations against the international community in regards to its ballistic missile program.
The reported deal with Iran would send more than a hundred planes to the Islamic Republic, while Iran attempts to finance the purchase of these aircraft through its opaque and illicit financial sector. We are aware that Boeing has secured a license from the U.S. Treasury Department’s Office of Foreign Asset Control to engage in preliminary discussions with Iran about these sales. However, the prospect of such sales remains fraught with danger for Boeing and the international community. Given Iran’s regional destabilizing activity, that danger will be even greater should this deal be finalized. We are also sending a letter to Airbus to express these same concerns.
In order to finance a deal of this magnitude with Iran, Boeing or one of its subsidiaries will have to engage Iran’s financial sector in order to receive payment. The banks that finance the deal will have to work with a country that remains a jurisdiction of primary money laundering concern, as designated by the U.S. Treasury. The 2011 designation of Iran and its entire financial sector, including its central bank, was based on “Iran’s support for terrorism; pursuit of weapons of mass destruction (WMD); reliance on state-owned or controlled agencies to facilitate WMD proliferation; and the illicit and deceptive financial activities that Iranian financial institutions – including the Central Bank of Iran – and other state-controlled entities engage in to facilitate Iran’s illicit conduct and evade sanctions.” The Financial Action Task Force (FATF) called out Iran’s financial sector as suspect, stating in June, “Until Iran implements the measures required to address the deficiencies identified in the Action Plan, the FATF will remain concerned with the terrorist financing risk emanating from Iran and the threat this poses to the international financial system.” These statements represent a joint conclusion by both the U.S. and international community that Iran has yet to significantly reform its financial sector and is still not compliant with international banking standards.
Through the terms of the Joint Comprehensive Plan of Action (JCPOA), many Iranian banks, including the Central Bank of Iran, were de-listed by the U.S. Treasury and the European Union in order to facilitate Iran agreeing to temporarily roll back its nuclear program. Unfortunately, these financial institutions have not changed their behavior and may still be facilitating the illicit financial activities that resulted in their designation in the first place. We also know from recent reports that Iran has attempted to acquire technology relevant to ballistic missiles and chemical and biological weapons. Additionally, UN Secretary General Ban Ki-moon stated that Iran is acting in ways inconsistent with the spirit of the JCPOA by conducting ballistic missile tests and left open that Iran may be violating UN Security Council resolutions. We are also concerned about reports that Iran may be attempting to acquire materials outside of the designated procurement channel to clandestinely support its nuclear program and the seizure of illegal Iranian weapons shipments intended for Houthi militants in Yemen. These incidents demonstrate that Tehran is engaged in activities contrary to international norms and security.
Lastly, we remain concerned that the aircraft themselves will be used by the Iranian regime to further the activities of its Islamic Revolutionary Guard Corps (IRGC) in support of President Bashar al-Assad’s war machine in Syria. The IRGC has flown weapons and soldiers to Syria to defend the Assad regime and provides arms to the Houthi rebels in Yemen. It has also supplied thousands of rockets and arms to Hezbollah in Lebanon, representing a direct threat to the State of Israel. Many of Iran’s airlines, including Mahan Air, remain designated by the U.S. Treasury for these activities. Iran Air, the recipient of the aircraft and parts from this deal, was only recently delisted by the U.S. Treasury as a concession in the JCPOA, and was previously designated for assisting the IRGC and Iranian Ministry of Defense’s weapons shipments. Iran Air continues to fly direct routes from Iran to Syria, and some of these flights have originated from known IRGC hubs.
The deal appears to extend beyond any practical need. Iran Air currently only operates around 40 functional aircraft. Iran’s stated goal of acquiring some 500 aircraft would vastly overtake its needs and represent a huge pool of aviation technology that could be diverted for illicit purposes. We are concerned that the true intent of Iran Air is likely to lease or resell some of its older aircraft as well as these new aircraft to other designated Iranian airlines. If diverted and used by designated entities, these aircraft would be directly supporting terrorism.
As concerned national security practitioners and professionals, we will continue to advocate limiting resources to Iran that can be utilized to continue and fortify its malign behavior. As Iran continues to violate international law through its support of global terrorism, gross human rights abuses, and aggressive behavior to destabilize the Middle East, we promise to increase pressure on Congress, the administration, and the international community to hold Iran accountable for its actions. We ask that you consider these issues before selling a significant capability to a country which remains a State Sponsor of Terror and a threat to the U.S. and our allies.
Sincerely,
Gen. Michael V. Hayden, Former Director, Central Intelligence Agency and National Security Agency
Sen. Joseph Lieberman, Former U.S. Senator from Connecticut
Judge Michael Mukasey, Former Attorney General of the United States
Hon. George P. Shultz, Former Secretary of State
Elliott Abrams, Former Deputy National Security Advisor for Global Democracy Strategy
Ilan Berman, Vice President, American Foreign Policy Council
Max Boot, Jeane J. Kirkpatrick Senior Fellow in National Security Studies, Council on Foreign Relations
John Cassara, Former Special Agent, U.S. Department of the Treasury
Hon. Irwin Cotler, Former Minister of Justice and Attorney General of Canada
Amb. Joseph DeTrani, Former Senior Advisor to the Director of National Intelligence
Michael Doran, Former Senior Director for Near East and North African Affairs, U.S. National Security Council
Mark Dubowitz, Executive Director, Foundation for Defense of Democracies
Reuel Marc Gerecht, Former Middle Eastern specialist, CIA's Directorate of Operations
Christopher J. Griffin, Executive Director, Foreign Policy Initiative
Lawrence J. Haas, Senior Fellow, American Foreign Policy Council
John Hannah, Former National Security Advisor to the Vice President of the United States
Olli Heinonen, Former Deputy Director-General for Safeguards, International Atomic Energy Agency
Jamil Jaffer, Former Chief Counsel and Senior Advisor, Senate Committee on Foreign Relations
Matthew Kroenig, Former Special Adviser, Office of the Secretary of Defense
Robert J. Lieber, Professor of Government and International Affairs, Georgetown University
Valerie Lincy, Executive Director, Wisconsin Project on Nuclear Arms Control
Mary Beth Long, Former Assistant Secretary of Defense for International Security Affairs
Michael Makovsky, President and Chief Executive Officer, Jewish Institute for National Security Affairs
Ann Marlowe, Visiting Fellow, Hudson Institute
Clifford D. May, President, Foundation for Defense of Democracies
Robert McBrien, Former Associate Director for Global Targeting, Office of Foreign Assets Control, U.S. Department of the Treasury
Scott Modell, Senior Advisor, Center for Strategic and International Studies
Emanuele Ottolenghi, Senior Fellow, Foundation for Defense of Democracies
Danielle Pletka, Senior Vice President for Foreign and Defense Policy Studies, American Enterprise Institute
John Podhoretz, Editor, Commentary Magazine
Chip Poncy, Former Director of the Office of Strategic Policy for Terrorist Financing and Financial Crimes, U.S. Department of the Treasury
Samantha Ravich, Former Deputy National Security Advisor to the Vice President of the United States
Michael Rubin, Former Staff Advisor for Iran and Iraq, Office of the Secretary of Defense
Jonathan Schanzer, Former Terrorism Finance Analyst, U.S. Department of the Treasury
John Simon, Former Executive Vice President, Overseas Private Investment Corporation
Ray Takeyh, Former Senior Advisor on Iran, U.S. Department of State
William Tobey, Former Deputy Administrator for Defense Nuclear Nonproliferation, National Nuclear Security Administration
Frances F. Townsend, Former U.S. Homeland Security and Counterterrorism Advisor
Amb. Mark Wallace, Chief Executive Officer, United Against Nuclear Iran
Kenneth R. Weinstein, President and Chief Executive Officer, Hudson Institute
Peter D. Zimmerman, Former Chief Scientist, Senate Committee on Foreign Relations
Juan C. Zarate, Former Deputy National Security Advisor for Combating Terrorism
