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NIAC Action Memo: IRGC Economic Exclusion Act (S. 925)

S. 925 — the Iranian Revolutionary Guard Corps (IRGC) Economic Exclusion Act — would have minimal sanctions impact on the already heavily-sanctioned IRGC, Iran’s primary military force that has historically thrived amid broad sanctions on the Iranian economy. However, S. 925 would have a deleterious impact on the Iranian people while restricting a successor administration’s ability to de-escalate tensions with Iran.

The bill seeks to preempt efforts to return the United States into compliance with the Joint Comprehensive Plan of Action (JCPOA)—the nuclear deal between the U.S., other major world powers, and Iran—by sanctioning all sectors of Iran’s economy, which would have a significant harmful impact on the livelihood of the Iranian people. In addition, the bill has the effect of undoing any benefit to Iran from adhering to the nuclear-related limitations outlined in the JCPOA, thus incentivizing Iran to halt its compliance with the accord and generating a new nuclear crisis in the Middle East. Proponents of diplomacy and the judicious but effective use of U.S. sanctions should reject this bill.

Disproportionate Harm to the Iranian People

S. 925 would have a significant deleterious impact on the livelihood of the Iranian people, as U.S. sanctions turn the Islamic Republic into an effective “hermit kingdom.” This bill:

  • Sets the groundwork for the effective closure of Iran’s airspace to civilian airlines; and
  • Cordons off Iran’s entire economy to the outside world, depriving an entire generation of Iranians social and economic opportunities

Meanwhile, the bill imposes little direct cost to the IRGC–its ostensible target. The IRGC is the most heavily-sanctioned entity in the entire world, and the U.S. has used multiple sanctions authorities to target it. Recognizing this, the bill targets Iranian parties with indirect, if not entirely attenuated, connections with the IRGC in the hopes of imposing additional costs. This includes broad sectors of the Iranian economy.

In doing so, however, this bill creates ripe opportunities for the IRGC to thrive, at the same time that its commercial competitors inside Iran are targeted for U.S. sanctions; cut off from the outside world; and forced into collapse. Sanctions have historically empowered hardline forces in Iran who use their proximity to the Iranian state to win state contracts, engage in smuggling operations, and direct sanctions evasion activities. If the U.S. wanted to impose direct costs on the IRGC, it would lift sanctions on Iran’s private sector and ensure their competitive edge, while maintaining sanctions on the IRGC.

The bill sets the stage for the effective closure of Iran’s airspace to civilian airlines.

Section 5 of the bill would add Section 315 to the Iran Threat Reduction Act so as to require the President to report on Iranian state-owned enterprises that engage in activities subject to sanctions under Executive Order 13224—the U.S.’s counter-terrorism sanctions authority. The bill notes that the Iran Airports Company—which is the holding and operating company for Iran’s civilian airports—is reported to facilitate activities for Mahan Air, an Iranian civilian airline that is sanctioned pursuant to E.O. 13224. As such, the bill argues that the Iran Airports Company is engaged in activities sanctionable under E.O. 13224 as a result of its support to Mahan Air and mandates the President to make a determination as to whether the Iran Airports Company should be designated under E.O. 13224. If designated, the effect would be the closure of Iran’s airspace to civilian air travel as foreign airlines would be at risk of sanctions for flying into civilian airports operating under the ownership or control of an entity designated pursuant to E.O. 13224.

Restraining a Successor Administration

The bill would undermine efforts for the United States to restore its credibility on the world stage by returning to compliance with the JCPOA. Specifically, the bill would impose terrorism-related authorities on broad sectors of Iran’s economy, all for the purpose of constraining a future administration from reaching diplomatic solutions with Iran.

The bill would block the President from being able to lift sanctions on certain designated Iranian parties, thereby negating the purpose of U.S. sanctions which is to effectuate a change of behavior.

Section 2 of the bill amends Section 301 of the Iran Threat Reduction Act so as to bar the President from waiving the application of sanctions with respect to a designated person unless the President makes certifications on IRGC activities. Unless the President certifies that the IRGC is reducing its material support to the Government of Syria or Hezbollah’s operations in Syria, the President would not be able to waive the sanctions. By amending the waiver provision in this manner, the bill conditions the lifting of sanctions with respect to a designated Iranian person not on the behavior of the sanctioned person itself but rather on the behavior of the IRGC. For instance, if an Iranian entity is determined to be owned or controlled by the IRGC and forces the divestment of the IRGC’s interest or control so as to remove the basis for its designation, this bill would prevent the President from lifting sanctions with respect to the Iranian entity unless the IRGC–as a whole–had reduced its material support to the Government of Syria. The likely effect of this amendment is not only to bar the President from waiving the application of sanctions but also to disincentive sanctioned parties from changing their behavior in ways that are otherwise consistent with U.S. interests.

The bill seeks to close off Iran’s telecommunications, mining, and manufacturing sector from the outside world.

Section 2 of the bill amends Section 301 of the Iran Threat Reduction Act to require the President to determine whether major operators in Iran’s telecommunications, mining, and manufacturing sectors are owned or controlled by the IRGC. If determined to be so, then such parties would be designated pursuant to multiple U.S. sanctions authorities and foreign parties and banks would be subject to U.S. secondary sanctions for dealing with them. In making such a determination, the bill permits the President to consider persons in which the IRGC has an ownership of less than 50 percent. The 50 Percent Rule—i.e., where sanctioned parties have a 50 percent or greater ownership interest—has long been OFAC’s governing standard as to whether a sanctioned party has a sanctionable interest in an entity, and adopting a new standard with respect to the IRGC threatens the judicious use of U.S. sanctions in the future.

The bill seeks to impose an effective boycott on any business—U.S. or foreign—with Iran.

Section 4 of the bill would add Section 313 of the Iran Threat Reduction Act, which requires the President to publish annual reports identifying (1) all foreign persons listed on the Tehran Stock Exchange, as well as a determination as to whether or not the IRGC or its officials, agents, or affiliates own or control the person; (2) foreign persons operating business enterprises in Iran valued at more than $100 million, as well as a determination as to whether or not the IRGC or its officials, agents, or affiliates own or control the person; and (3) Iranian financial institutions valued at more than $10 million, as well as a determination as to whether each Iranian financial institution has facilitated a significant transaction for or on behalf of the IRGC or whether the IRGC or its officials, agents, or affiliates own or control the Iranian financial institution. This bill is consistent with recent actions by the Trump administration in which Iranian parties have been designated for highly-attenuated connections with persons alleged to be affiliated with the IRGC. By requiring this report to be made public on U.S. government websites, the bill would also signal to foreign parties that all business with Iran is subject to sanctions risk, rendering Iran a no-go zone for the international business community.

New reporting requirements would limit the President’s discretion to impose sanctions in ways that undermine the Executive’s foreign policy prerogatives.

Section 3 of the bill requires the President to submit reports to Congress on a biannual basis regarding foreign persons determined to engage in transactions with designated Iranian persons. Sanctions are to be imposed with respect to any parties identified in the report. This reporting requirement is consistent with the Trump administration’s “maximum pressure” strategy under which the success of U.S. sanctions policy with respect to Iran is predicated on the total number of Iranian parties added to U.S. sanctions lists rather than whether U.S. sanctions have caused the Government of Iran to abandon policies deemed anathema to U.S. interests. This is a myopic view of U.S. sanctions that threatens the effective use of the sanctions tool in the future.

Build Iranian-American Power With Us

From Sunday, March 24th through Tuesday, March 26th, the notoriously hawkish AIPAC will be hosting at their annual conference a cohort of officials, including Israeli Prime Minister Benjamin Netanyahu, who shamelessly promote the most destructive Iran policies seen to date.

At the conference, AIPAC is expected to announce the launch of a new PAC aimed at steering political donations toward candidates that will support AIPAC’s regressive priorities: escalating the demise of the Iran deal, upholding sanctions that suffocate the same Iranian civil society they claim to support, and driving the U.S. closer to war.

But we can combat them, with your help.

NIAC is aiming to raise $10,000 to establish a PAC that will support progressive candidates who will prioritize diplomacy, equitable immigration policies, and civil rights.

We’re excited to announce that one generous individual has offered to match dollar-for-dollar the amount raised, up to $10,000. But we need your help to reach our goal. Please consider making a donation, as this match ends tomorrow night.


Congratulations to David Emami, City Councilor of Happy Valley

We are excited to announce that NIAC Action endorsee David Emami has been officially appointed as City Councilor of Happy Valley in Oregon! We were proud to endorse Oregon’s first ever Iranian-American City Councilor in this competitive race. See what David had to say on his appointment:

“I am humbled, appreciative and thankful for this opportunity to serve as Oregon’s first ever Iranian-American City Councilor. I hope to inspire others out there to achieve their dreams and It is my absolute goal to represent ALL people of Happy Valley. I want to especially thank NIAC for their support and endorsement. Without organizations like NIAC that work to promote a greater understanding between the American and Iranian Community, appointments such as mine may not have been possible. Thank you all for your support!”

We look forward to seeing all that David Emami accomplishes as City Councilor!

We’re Proud to Endorse Sepi Shyne for West Hollywood City Council

We’re excited to announce our official endorsement of Sepi Shyne for West Hollywood City Council.

Sepi Shyne is a front-running Democratic candidate for the City Council seat. She’s an Iranian American, an attorney, and runs two small businesses, including a law firm. If elected, Sepi Shyne would become the first woman of color to serve on the West Hollywood City Council.

Sepi has written, “As a lesbian, Iranian immigrant and woman of color, I was never supposed to run for office … But at a time when our most basic rights are under attack and hateful legislators chip away at the foundation of our democracy, I am running.” We think she’s the most qualified candidate for this seat and are excited to give her our support.

Our endorsement for Sepi joins other notable endorsements for Sepi’s campaign, including endorsements from Congresswoman Katie Hill and John Erickson, City of West Hollywood Planning Commissioner, as well as from over a dozen other elected officials. She’s also been endorsed by the Democratic Party of San Fernando, The National Women’s Political Caucus, Stonewall Democratic Club, Equality California, and The Unite HERE Local 11! Labor Union.

Sepi is running a grassroots campaign, and is heavily focused on canvassing, phone banking, GOTV efforts, and community events.

Sepi can’t do this without our help. She’s up against three incumbents for her election on March 5th, and she needs our support to make this happen.

Electing Iranian-American candidates is a key part of building political power for our community. We hope we can count on you.

Senator Warren and the Return to the JCPOA

At NIAC Action, we’re advocating for a return to the Iran nuclear deal to bring back diplomatic relations between the U.S. and Iran. Recently, 2020 presidential candidate Senator Elizabeth Warren has been vocal about her support for returning to the JCPOA. 

In the Senate Armed Services Committee yesterday, Senator Warren called for returning to the Iran nuclear accord and advocated for extending New START Treaty. See the full video:

Last November, NIAC released a report calling for Congress and 2020 candidates to commit to returning to the Iran Deal.  We are hard at work with allies like J Street to ensure each 2020 candidate makes a commitment to return to the JCPOA.

We’re Proud to Endorse David Emami as City Councilor of Happy Valley

We’re excited to announce our official endorsement of David Emami for City Councilor of Happy Valley!

At NIAC Action, we strive to identify and build up rising civic leaders who have the vision and leadership needed in our surrounding communities. David Emami is such a leader.

David exemplifies the kind of community leadership needed to give Happy Valley a champion of its values. Born and raised in Oregon to Iranian immigrants, David stands proud as an Iranian-American. His multifaceted identify affords him an empathy and understanding of the diverse communities he hopes to represent as part of the council. And as a father, David is committed to protecting and helping make thrive the future of Happy Valley, the place his children call home.

David is one of six finalists for this seat on Happy Valley’s City Council. David’s appointment would represent a historic breakthrough for the State of Oregon, as he would be the first Iranian-American City Councilor in the state’s history. It would further underscore Happy Valley’s commitment and dedication to making the city’s leadership more representative of the beautiful community it seeks to represent.

We enthusiastically support David’s public service ambitions and are confident he will diligently work alongside other City Councilors to make Happy Valley a stronger community.

BREAKING: DNC Adopts Resolution Calling on the U.S. to Re-Enter the Iran Nuclear Accord

FOR IMMEDIATE RELEASE: Wednesday, February 20, 2019
CONTACT: Mana Mostatabi | 202.386.6319 |

WASHINGTON, DC — Moments ago, the Democratic National Committee officially announced that it has adopted a resolution calling on the U.S. to re-enter the Iran nuclear accord, formally known as the Joint Comprehensive Plan of Action (JCPOA). The resolution, which was submitted by DNC Committeewoman Yasmine Taeb and adopted over the weekend, will ensure that re-entering the JCPOA is a key priority for the Democratic Party going forward, especially as the Party prepares its platform for the 2020 presidential election. NIAC Action, the political arm of the National Iranian American Council, endorsed Taeb in her race for the Virginia State Senate earlier this year.


“As President Trump and his warmongering advisors continue to stoke confrontation with Iran, it is vital that 2020 hopefuls push back on Trump’s reckless actions and voice support for returning to the nuclear accord. Hardly a week goes by without renewed efforts from the Trump Administration to push the nuclear accord toward collapse. If successful, Trump’s team may decimate the chances of any future administration restoring U.S. credibility by returning to the JCPOA. Worse, Trump may start a disastrous war with Iran,” explained Jamal Abdi, President of the National Iranian American Council.

“By prioritizing bringing the U.S. back into compliance with the JCPOA, the Democratic National Committee is recognizing both the danger of Trump’s approach and the urgent need to return to the accord – while signalling both to Iran and to U.S. allies that the days of this reckless foreign policy approach are numbered. Other lawmakers and 2020 hopefuls should follow the lead of the Democratic National Committee and lay out a competing vision to Trump’s bankrupt approach,” Abdi continued.

NIAC has worked to preserve the nuclear agreement by encouraging lawmakers and 2020 candidates to indicate that the U.S. will return to the deal under a new administration. The group’s first step in this effort was publishing a report last fall which outlined why Congress and 2020 Presidential candidates should commit to returning the U.S. to the Iran deal. Since then, presidential candidates Elizabeth Warren and Amy Klobuchar have both signaled that they favor returning the U.S. to the deal.

“We know saving the deal will not be easy— in fact, the Trump administration’s drive to destabilize Iran and trigger military action is already accelerating. Just this past week, the Trump Administration called on Europe to kill the nuclear agreement and Benjamin Netanyahu suggested Israel and Arab states are working towards a war with Iran. NIAC will continue working overtime to prevent war with Iran, including working with 2020 candidates and Congress,” added Abdi.

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NIAC Action is the grassroots, civic action organization committed to advancing peace and championing the priorities of the Iranian-American community. We are a nonpartisan nonprofit and the 501(c)4 sister organization of the National Iranian American Council, which works to strengthen the Iranian-American community and promote greater understanding between the U.S. and Iran.

Call Your Congressperson to Demand an end to H.R.1044/S.386

Contact your Senators and Representatives by calling 1-844-ACT-NIAC:

Here’s a sample script of what to say:

Hello, my name is (your first name). I live in (your city) [and am a member of NIAC Action]. I’m calling to ask Rep./Sen XX to oppose HR1044/S386. While HR1044/S386 may serve as a short term solution to the green card backlog for immigrants from large countries, like India and China, it will extend the wait time for those from smaller countries. Iranians, who are by in large in this country on single entry visas, will be especially impacted because we cannot see our families due to the Muslim ban. For those that wish to stay in the United States, a green card is the only opportunity we have to see our families. In addition, removing per-country caps lowers the diversity of the high skilled immigrant workforce, something that many of us here in the US take pride in. So I strongly urge the Congressman/Senator to oppose HR1044/S386.”

BREAKING: Trump Administration Forced to Turn Over Information on Muslim Ban

We have a positive update on the effort to scale back and ultimately overturn Donald Trump’s Muslim Ban. As part of the spending bill that will become law today, the Trump administration will be forced to turn over important information on the ban that will enable Congress to finally have oversight of this policy.

The Trump Administration must now report on the implementation of the sham waiver process that continues to deny spouses, sick family members, and others who are supposedly exempt from the ban. It must also explain to Congress its justification for continuing what was supposed to be a temporary policy.

This will help enable Congress to hold hearings, press the Administration to issue more waivers, and reduce the negative impact of the ban until it can be repealed.

This small victory is the culmination of efforts we coordinated last year with over fifty organizations—including the ACLU, Brennan Center, J Street, and Iranian-American organizations like PAAIA and IABA—to urge Congress to demand this information. We then worked closely with Sens. Van Hollen (D-MD) and Leahy (D-VT) to pass an amendment to turn those demands into law. While the effort was delayed over the disputes that led to the government shutdown, the amendment will become law later today. We are tremendously thankful to Sens. Van Hollen and Leahy for ensuring that these reporting requirements passed.

Even as Americans brace themselves for Trump’s pending declaration of a “national emergency” to try to build his border wall, we must also relish today’s small but significant step forward for everyone impacted by the Muslim Ban. Now, we must take the next step by passing new legislation supported by NIAC Action and over 100 organizations to hold hearings and block funding for the ban.

>> Tell Congress: Repeal the Ban

Fight for Fair Immigration