The Pak Banker

Using financial sticks to control Iran

- Juan Zarate & Chip Poncy

As Congress considers the Iranian nuclear deal, it should also prepare a strategy to use U.S. financial and economic power aggressive­ly against a broad array of Iranian threats. If the deal is adopted, the risks from an enriched, emboldened Iran will only grow. These risks should not be accepted as an unavoidabl­e cost of the deal.

Any unwinding of sanctions and reintegrat­ion of the Iranian economy will provide Iran's Revolution­ary Guard Corps , and its overseas Quds Force - the defenders of the regime and exponents of the revolution, with greater resources and access to global financial and commercial systems.

The Revolution­ary Guard and the ruling mullahs control strategic elements of the Iranian economy - the largest constructi­on company, much of its telecommun­ications sector and a large portion of the Tehran stock exchange. They use the nation's banks, oil industry and other nodes of the economy to profit personally, support terrorism and preserve the regime. They exert control through bonyads, or parastatal financial entities, and Supreme Leader Ayatollah Ali Khamenei's vast financial network, EIKO (set to be delist- ed), worth tens of billions of dollars.

There is serious concern regarding the infusion of billions of dollars into Iran immediatel­y, with more sanctions relief and investment to follow. Funding is likely to flow from Tehran to terrorist proxies from Beirut to Yemen.

The deal's allowance for a nuclear infrastruc­ture and research will certainly not decrease proliferat­ion risks. Proliferat­ion concerns, especially given Iran's trade with rogue third countries like North Korea and Syria, will actually increase. And the threat is likely to be exacerbate­d with the lifting of the arms and ballistic missile embargoes, after five and eight years, respective­ly. With more capital and better technology, Iran will continue to harass its enemies with cyber attacks, as it has against Western banks, the Sands Casino and Saudi Aramco.

The regime will use its economic control to brutally suppress internal opposition, and concerns over humanright­s abuses and regime kleptocrac­y will grow. Iranian money laundering and illicit financing - specifical­ly called out internatio­nally and subjected to U.S. regulatory action - will persist. It will be harder to identify sanctions evasion and even more difficult to enforce with greater market enthusiasm for doing business with Iran.

These risks must all be confronted using the financial power that has dominated the post-9/11 period, especially when military options are not available. The United States cannot watch these risks grow without "pushing back" against Iran. Congress should put in place a new strategy, preserving and strengthen­ing our ability to confront Iran's rogue activity through the use of financial power. The strategy will succeed if focused on underlying Iranian conduct and accepted internatio­nal principles.

We should adopt an economic constricti­on campaign focusing on the Revolution­ary Guard and core elements of the regime engaged in terrorist financing, proliferat­ion and providing support to destabiliz­ing proxies. This should include secondary sanctions against those doing business with designated Iranian players. We should tighten export-control enforcemen­t, interdicti­ons and financial restrictio­ns - including against relevant Iranian banks - and target those engaged in proliferat­ion finance or sanctions evasion under Executive Orders 13382 and 13608, respective­ly.

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