On July 14, 2015 the Joint Comprehensive Plan of Action (JCPOA) was announced between the P5 + 1 and the Islamic Republic of Iran. The document outlined the terms of the deal, which included some incremental dismantling of Iran’s nuclear program, and in return provided billions in released frozen funding to Iran and a waiver of many international sanctions on its nuclear program. This 159-page document contained a “Specially Designated Nationals” (SDN) list of pages and pages of individuals and entities that will be relieved from previously instituted nuclear sanctions. A majority of those listed on the SDN list will be delisted after Implementation Day. Most disturbingly, among those that will be delisted are a number of entities that are instrumental to the development of the Iranian ballistic missile program, and involved in the two recent ballistic missile tests that Iran conducted which violated international law.
One of the entities that will be receiving sanctions relief is Bank Sepah – translated into English as “Army Bank.” Bank Sepah is a state-owned, Iranian financial institution. In 2007 Bank Sepah was added to the SDN list maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) for “facilitating Iran’s weapons program” and providing “support and services to designated Iranian proliferation firms.” This action froze its assets and prohibited transactions with U.S. parties, pursuant to Executive Order 13382. E.O. 13382 was signed by President George W. Bush, who authorized the use of “strong financial sanctions against not only WMD proliferators, but also entities and individuals providing support or services to them.” In addition to being designated by the U.S. Treasury Department, Bank Sepah was also listed as an entity “involved in nuclear or ballistic missile activities” in U.N. Security Council Resolution 1747. According to Stuart Levey, former Under Secretary for Terrorism and Financial Intelligence within the U.S. Treasury Department, “Bank Sepah is the financial linchpin of Iran’s missile procurement network and has actively assisted Iran’s pursuit of missiles capable of carrying weapons of mass destruction.”
This Treasury designation was applied to Bank Sepah because they were providing financial support and services to Iran’s Aerospace Industries Organization (AIO), Shahid Hemmat Industrial Group (SHIG), and the Shahid Bagheri Industries Group (SBIG) which were all designated by President George W. Bush in 2005 in the Annex to E.O. 13382. The AIO is the leading industrial and military subsidiary of the Iranian Ministry of Defense and Armed Forces Logistics. The AIO oversees Iran’s missile production, and is most likely controlled by the Islamic Revolutionary Guard Corps (IRGC.) The SHIG is responsible to Iran’s ballistic missile programs. One of the main missiles it produces is the Shahab-3 medium range missile. This missile was developed with help from China and North Korea, and is capable of carrying chemical, nuclear, and biological warheads. Naser Maleki is the head of the SHIG and was designated under E.O. 13382 for his involvement in proliferation of weapons of mass destruction (WMDs) and their delivery systems. The SBIG is also involved in Iran’s missile programs, and one of the main weapons they produce is the Fateh-110 missile. These three entities will all be delisted as a direct result of the Iran Nuclear Deal.
This is why the ballistic missile tests conducted by Iran are so egregious. All four of these entities, which are about to be delisted by the JCPOA, have recently participated in international law violations. In fact, the October missile test was “completely designed and manufactured by experts of Iran’s Aerospace Industries Organization.” Yet President Obama seems unwilling to rethink the JCPOA, or impose any punishments on Iran or these Iranian entities.
Does the President of the United States truly believe that Bank Sepah, AIO, SHIG, and SBIG, if they are rewarded by the JCPOA by being removed from international sanctions, will not return back to their nefarious activities, working with dangerous individuals who have vowed “death to America?” Because these two ballistic missile tests indicate that these entities are already continuing their prior bad behavior.
The U.S. should take strong actions against Iran for these missile tests. It should not delist any Iranian entities, including these four, which were involved in violating international law. It should follow the advice of some Democratic lawmakers who supported the JCPOA, who sent a letter to President Obama, demanding that the U.S. take “immediate, punitive action and send a clear message to Iran that violating international laws, treaties, and agreements will have serious consequences.” And it should do so now, as the sanctions relief for many of these individuals and entities could come as early as this week.