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All in Policy
Since 1988, the Berman Amendment has limited the authority of the President to restrict the exchange of information as part of American sanctions policy. But the new sanctions designation of the IRGC and recent voluntary actions by American companies suggest that the long standing protection for the free trade of ideas is under threat.
◢ Later today, President Trump will decertify Iran's compliance with the JCPOA on national security grounds. However, early reporting based on background briefings provided to European officials makes clear that administration does not intend to walk away from the Iran Deal.
◢ Instead, Trump is pushing the issue of Iran policy to Congress, recommending new actions to counteract Iran, but not going so far as to recommend the full "snapback" of sanctions.
◢ With new U.S. sanctions on Russia and Iran set to come into force, the French Foreign Ministry issued a firm statement suggesting new U.S. sanctions could contravene international law.
◢ While Germany is likely to lead on the push back against additional Russia sanctions, the importance of the Iranian market to French enterprise may mean that Macron is best positioned to intervene with Trump to help preserve the JCPOA.
◢ The JCPOA has now persisted for two years, and Iran is beginning to see post-sanctions benefits. But American support for the deal is wavering, and deal supporters in Washington have upped their advocacy.
◢ But deal supporters often describe the JCPOA as an unusual concession from an otherwise threatening Iran, a characterization that undermines much of what the Iran Deal has achieved so far.
◢ Behind every successful multinational deal in Iran is a country manager. These executives seek to balance the commercial goals of their companies with the needs of Iran's post-sanctions economy.
◢ Country managers are a critical link in what is essentially a bureaucratic system. Policymakers need to help make this bureaucracy work better with better rules and systems so that country managers can succeed.
◢ A resounding election victory has renewed Rouhani's popular mandate, but following President Trump's speech in Riyadh, the prospects for improved US-Iran ties remain remote.
◢ But by taking the high road, Iran can still make progress in its international relations, especially if it aims to forge deeper ties with Europe.
◢ In a letter to House Speaker Paul Ryan, Secretary of State Rex Tillerson has confirmed Iran's compliance with its obligations under the JCPOA, or Iran Deal.
◢ This letter reflects an important shift in the Trump administration's view on Iran, publicly confirming faith in verification processes and indicating an intention to craft policy through formal mechanisms.
◢ Lake Urmia was once the second largest salt-water lake in the world. But years of environmental mismanagement saw the surface area of the lake shrink by 90%.
◢ After a decade-long initiative led by the United Nations, and supported by the Iranian and Japanese governments, water levels in the lake are finally beginning to rebound.
◢ A new survey presented the main terms of the Iran Deal to nearly 3,000 Americans and asked them to evaluate arguments for keeping or withdrawing from the deal.
◢ A majority of those surveyed thought any attempt to withdraw and renegotiate the Iran Deal was likely to fail, and most gave a "final recommendation" to support the deal in its current form.
◢ ExxonMobil CEO Rex Tillerson will reportedly be named Trump's new Secretary of State, ending speculation about the critical role for US policy on Iran.
◢ Tillerson's public comments on sanctions and Iran give some indication that he will take a pragmatic view of the Iran Deal.
◢ Donald Trump recently underscored his intention to protect American jobs by making an extraordinary intervention at a Carrier factory in Indiana.
◢ A look at Carrier and Indiana's other top employers illustrates how across the United States, major businesses have traded with Iran. Trump should use Iran policy as leverage to either boost US exports, or incentivize multinationals to keep American jobs.
◢ The Obama administration is weighing its final possible measures to strengthen the Iran Deal before President Trump has a chance to make his mark.
◢ Improving transparency in the Iranian economy would have the most immediate impact on the continued viability of sanctions relief. US policy must make it easier for global consulting and auditing firms to work in Iran.
◢ The Trump presidency poses considerable risks to the full implementation of the Iran Deal, but is unlikely to threaten the deal's survival as some have suggested.
◢ Trump's interference in the deal will be constrained by domestic politics, Russian strategic interests, and European lobbying.
◢ A move to introduce personal liability for compliance officers is changing AML/CTF practices in banking and finance.
◢ New policies and new technologies are raising the bar for post-sanctions banking reforms and Iran may be left out the effort to establish new global best practices.
◢ New guidance from the Office of Foreign Assets Control has provided more clarity on U.S. dollar processing by non-U.S. financial institutions
◢ The updated FAQs also provide more detail about OFAC's expectations regarding due diligence efforts
◢ Think tanks played a crucial role in both sides of the debate surrounding the Iran Deal.
◢ The success of the Iran Deal continues to depend on the influence of think tanks, particularly in Washington D.C.
◢ Brexit is disrupting the key coordinating bodies responsible for implementation of the Iran Deal.
◢ Trade and investment in Iran will not be a priority for key European companies during Brexit volatility.
◢ Limitations on the activities of advisors and consultants keeps banks and businesses wary of engaging Iran.
◢ American regulators should offer a sanctions general license to help knowledge transfer take place.
◢ "Business diplomacy" has become a key skillset for multinational corporations operating in markets around the world.
◢ In Iran, the worlds of politics and business often collide making these skills part of the formula for succesful management.
◢ There is a vibrant but largely overlooked community of social entrepreneurs in Iran doing innovative work for the social good.
◢ A recent survey of 100 social entrepreneurs completed with the support of George Mason University concluded that while the sector is growing, more support and funding is needed.
