Senators Demand More Information from State Department on Muslim Ban

Washington, DC – Today, Senators Chris Van Hollen (D-MD), Chris Murphy (D-CT), and Richard Blumenthal (D-CT) issued a letter to the Trump administration requesting more information on the obscure case-by-case waiver process of Presidential Proclamation 9645, otherwise known as Muslim Ban 3.0. The letter comes as the Supreme Court prepares to hear oral arguments on the ban next Wednesday.

In an attempt to overcome legal challenges to the first Muslim Ban, the Trump administration included a waiver process for certain applicants in the second iteration of the ban. The waivers are something that was also included in Muslim Ban 3.0. But recently, the State Department, in a letter to Senators Jeff Flake and Chris Van Hollen on February 22, 2018, revealed that only two waivers had been granted between December 8, 2017 and February 15, 2018. Two weeks later, the State Department revised this number to 250 waivers, and most recently, they have asserted that 450 waivers have been issued.

Obtaining credible and reliable information is critical to fighting the Muslim Ban in the event that the Supreme Court upholds the ban later this summer, but it is also an important part of fighting back against all outgrowths of the Muslim Ban policy, including ‘backdoor’ administrative bans. NIAC Action has been hard at work behind the scenes drafting reporting requirement language which would provide Congressional oversight on how these case-by-case waivers are evaluated and adjudicated. If the administration is responsive to the Senators’ inquiry, we will have a window into how Muslim Ban 3.0 is being implemented, and will have more data to evaluate whether the waiver provision is more than just an sham attempt to sway the courts to rule the ban constitutional by alleviating concerns of a blanket ban that plagued the administration’s first Muslim Ban.

The letter sent today by Senators Van Hollen, Murphy and Blumenthal also seeks relevant documents and information on the reports submitted by the Department of Homeland Security to the White House every 180 days recommending changes to Muslim Ban 3.0. In addition, the Senators are requesting further information on any guidance issued to consular officers abroad on how to evaluate and adjudicate waiver requests, as well as data on how many visas applications have been received and processed from designated countries.

In addition to our efforts to establish Congressional oversight on the Ban, last week NIAC also filed a lawsuit against the Trump Administration in an effort to compel them to produce documents from a Freedom of Information Act request sent several months ago requesting relevant documents about the ‘extreme vetting’ policy. If the court rules in our favor and compels the production of these documents, we will have another opportunity to look behind the veil of secrecy draped around Muslim Ban 3.0 by this administration.

The Muslim Ban is much broader than just the travel restrictions being challenged in the Supreme Court next week. It is a highly nuanced and complicated policy which extends to administrative efforts to ban Iranians and Muslims and fulfill a campaign promise. ‘Extreme vetting’ and the case-by-case waiver process are just two examples of this much broader policy that is being implemented as the official immigration policy of the United States.

NIAC Action will continue to take the fight to Trump, because not only is there’s a lot at stake here for our community, there’s a lot at stake for the future of this country. We are an Iranian-American organization, and what follows the hyphen is just as important as what precedes it — it is who we are.

NIAC Action is extremely grateful for the engagement of Senators Van Hollen, Murphy and Blumenthal on this urgent issue, and we look forward to continuing to work with Congress to shine a light on what has been a very harmful and secretive policy.

NIAC Survey Reveals Great Concern About War and Discrimination

NIAC’s annual survey of over 1,000 of its donors and supporters reveal a community that is increasingly impacted by discrimination and which remains committed to advocating for diplomacy and preventing war and reversing Donald Trump’s Muslim ban.

Concerns of War and a Permanent Muslim Ban

Two-thirds of respondents are concerned that the U.S. may go to war with Iran under the Trump administration. Of even greater concern is the possibility that the courts may reinstate the Muslim Ban and permanently ban Iranians, with 72% of respondents indicating that they are ‘very concerned.’

Sadly, respondents reported that instances of discrimination have increased over the last year. One third of respondents reported that they know someone who has been impacted by the Muslim Ban and 42% feel they are affected by negative depictions of Iranians in U.S. media.

Advocacy and Political Priorities

Advocacy goals of NIAC Action members.

Advancing diplomacy with Iran to protect the nuclear deal and avoid armed conflict was ranked as the highest advocacy priority by supporters, followed by seeking an end to the Muslim Ban. Protecting civil rights was ranked as the third priority, followed by lifting sanctions to enable US-Iran trade, and supporting human rights in Iran. These priorities reflect those of past surveys with the notable and unfortunate addition of the Muslim Ban.  

Respondents said they would like to see NIAC Action continue to   support political candidates who are committed to advancing Iranian-American interests: 45% prioritized helping to get Iranian Americans elected to Congress; 43% prioritized helping Democrats retake Congress in 2018; and 29% would like to work with NIAC Action to donate to candidates who will work with our community on issues like protecting the Iran deal and ending the Muslim ban.

Continuing our mission

NIAC surveys its donors and supporters to set its advocacy priorities for the current year. The results of past surveys have consistently mirrored the views of the majority of Iranian Americans, as expressed in statistical surveys of the broader Iranian-American community conducted by universities and professional pollsters.

We wish to thank all those who took part in this year’s survey. Your participation ensures that our community is unified as we move forward to tackle the most pressing issues confronting Iranian Americans. We look forward to working together to accomplish our goals and increase our community’s political influence in the years to come.

Memo: Standing in Solidarity with the Iranian People

As Iranians protest in the largest numbers since the disputed 2009 Iranian Presidential election that sparked the Green Movement, many lawmakers are wondering how to stand with Iranians as they bravely make their voices heard. To do so, it is important to recognize that policymakers in Washington will have limited ability to positively impact the ultimate outcome of protests that are Iranian in origin and will ultimately be decided by Iranians. Outside of expressions of moral support, Iranians have not asked for U.S. assistance and many believe that calls for regime change or revolution from the U.S. or other states will hurt the people’s cause and assist in the government’s ability to crack down.

With this in mind, we encourage Congress to take the following practical steps to stand with the Iranian people:

  1. Take immediate action to rescind the Muslim ban, which bars Iranians from traveling to the United States; in order to take a stand in solidarity with the Iranian people, the U.S. must address the enormous trust deficit that Donald Trump has with Iranians. The Muslim Ban that primarily targets Iranians and, combined with antagonistic rhetoric such as his blaming Iran for an ISIS terror attack in the country, Iranians do not believe that Trump or his administration have their best interests in mind. In order to credibly stand with the Iranian people, it is important that policies like the Muslim Ban are rescinded. 
  2. Condemn violence and human rights abuses perpetrated by Iran’s government and call on the Iranian government to honor its human rights obligations, including the right to free speech and peaceful assembly;  
  3. Encourage the Administration to responsibly implement targeted human rights sanctions against violators in Iran’s government under the authorities Congress granted to the President in the Comprehensive Iran Sanctions and Divestment Act of 2010 and the Iran Threat Reduction and Syria Human Rights Act of 2012;
  4. Ensure that communications technology is available to Iranians, including by encouraging applications to continue operating inside Iran and also taking necessary steps to ensure U.S. sanctions do not prevent other helpful tools from being utilized by Iranians; between 2009 and 2016, the U.S. took steps to lift sanctions on important tools that have helped enable Iranians to communicate freely – including applications, smartphones, and services. Further steps can be taken to ensure tech companies make these tools available to Iranians.
  5. Uphold the Iran nuclear deal and highlight the sanctions relief granted under the agreement that should benefit ordinary Iranians. President Trump and his administration will face key decisions in the weeks ahead on whether or not to extend sanctions waivers under the Iran nuclear deal and on whether to certify the accord under the Iran Nuclear Agreement Review Act. Congress must warn Trump against callously shredding the deal, which would threaten to empower hardline elements in Iran and undermine U.S. security interests.


H.R. 3364 Endangers U.S. Troops and Pushes Trump to Violate the Iran Nuclear Deal

Congress is considering passage of H.R. 3364, “Countering America’s Adversaries Through Sanctions Act.”  This bill, the Iran-related parts of which passed the Senate in June (S. 722), would pose a risk of sparking military conflict with Iran and encouraging President Trump to act in breach of U.S. commitments under the Joint Comprehensive Plan of Action (JCPOA), the nuclear deal between the U.S., other major world powers, and Iran.  Congress should avoid voting for passage of this bill absent legislative changes to ensure the U.S.’s sustained compliance with the nuclear accord.

By designating the IRGC a terrorist organization, H.R. 3364 undermines the safety of American troops stationed in Iraq and risks provoking an open military conflict between the U.S. and Iran.

Section 105 of the bill effectively directs President Trump to designate the Islamic Revolutionary Guard Corps (IRGC) – Iran’s main military force – a Specially Designated Global Terrorist (SDGT) pursuant to Executive Order 13224.  Multiple administrations, including that of Presidents Bush, Obama, and even Trump – have declined to take this aggressive and unprecedented step, as the Pentagon has warned that designating the IRGC a terrorist group could endanger the safety of American troops in Iraq by provoking retaliation from Iranian-backed proxy forces, all the while exposing the U.S. military to reciprocal designation in Iran.  Designating the IRGC a terrorist group thus risks endangering U.S. troops, undermining the fight against ISIS, and provoking open confrontation between the U.S. and Iran that could result in a war.

The bill interferes with the U.S.’s JCPOA obligation to lift additional sanctions on Transition Day.

Section 108 of the bill, as amended, does not resolve concerns that the provision could prevent the President from de-listing Iranian parties scheduled to be removed from U.S. sanctions lists on Transition Day, thus placing the United States in non-compliance with its JCPOA obligations. If, for instance, an Iranian person scheduled for removal from U.S. sanctions lists on Transition Day engages in activities that contribute to Iran’s ballistic missile program, the President is required to designate that person under Executive Order 13382 (or, if already designated under that Order, to add such legal basis for designation to the person’s evidentiary record). In doing so, the President may be precluded from removing the person from U.S. sanctions lists on Transition Day, as the person will now be the subject of a non-nuclear sanction imposed following the implementation of the JCPOA. Such an occurrence would place the U.S. in clear violation of the nuclear accord.

The bill gives the Trump administration new sanctions authorities to undermine the deal.

Section 104 of the bill mandates the President to impose sanctions on any individual that “knowingly engages in any activity that materially contributes to the activities of the Government of Iran with respect to its ballistic missile program.” It remains unclear how the Trump administration will utilize this mandatory sanctions authority to impose additional on Iran for its missile program, and the Trump administration could fairly interpret the provision in a broad manner that threatens U.S. compliance under the JCPOA. Given the President’s withdrawal from the Paris climate accord and his partial reversal of Obama’s Cuba opening, Congress should act with restraint amid expectation that President Trump intends to reverse the JCPOA.

New sanctions would backfire by empowering Iranian hardliners.

Iran has re-elected Hassan Rouhani over a hardliner after he campaigned for openness at home and further negotiations with the West. New Congressional sanctions threaten to negate his mandate. Escalating sanctions will only serve to empower those hardliners that thrive under sanctions and the threat of war, like the IRGC, while undermining Rouhani as he seeks to cooperate with the West and to rein in provocative hardline forces.

Iranian grandparents are now banned from the U.S.

NIAC Policy Director Jamal Abdi and his grandmother

I was nine years old when I finally met my grandparents. After years of only seeing them in old photos and hearing about them in my dad’s stories about growing up in Tehran, they finally were able to make the trip to America and meet their grandchildren for the first time.

Donald Trump just announced that my grandparents are now banned from this country.

Beginning today, a new version of Trump’s Muslim ban will go back into effect. The Supreme Court ordered that Trump’s travel ban could go forward – but could not apply to people who have a “bonafide relationship” with an American. In response, Trump has released a directive that Iranians and other “banned” nationals would have to prove their “bona fide relationship” in order to apply for a visa.

Trump’s directive establishes the categories of relationships that are allowed in, and those who are not: Grandparents, grandchildren, aunts, uncles, nieces, nephews, cousins, fiancees and other extended family members are not serious enough relationships to enter the U.S., according to Trump’s new ban.

The bottom line: if your extended family member is Iranian, they are now banned from entering the U.S.

We are going to fight this with everything we’ve got. But we need your financial support in order to have the staff and resources necessary to seriously challenge this assault against our community and our country’s values.

DONATE to defeat Trump’s ban!

We are confronting this ban from every angle:

  1. NIAC volunteers and staff associates are continuously meeting with allies in Congress and their home districts to try to force a vote on legislation that will rescind and defund the Muslim Ban. We can no longer rely solely on the courts to fight this ban for us. We must rally our lawmakers to take a stand on this un-American ban.
  2. We organized our members in New Mexico to meet with Rep. Pearce and voice their concerns and USA Today ran a story about it. After hearing from our community Rep. Pearce – a Republican – publicly criticized Trump’s ban.
  3. We have a plan in Congress to force those who refuse to take our concerns seriously to finally take a public stand on the ban and be judged by their voters. NO MORE HIDING.
  4. NIAC has already requested documents and statistics from the Trump administration to build the foundation for a second wave of litigation against the ban.

NIAC staff and volunteers  are deployed across the country to defeat the Muslim Ban. But we need your financial support to continue representing the interests of our community. With your support we will remain ready to advocate for you.

Will you donate $50, $100, $1000 or an amount that’s right for you so that we can redouble our efforts to defeat Trump’s ban and make our Iranian grandparents welcome again?

Take Action: Rep. Rohrabacher Must Apologize!

Republican congressman Dana Rohrabacher (CA-48), who represents more Iranian Americans than nearly any other lawmaker in the House of Representatives, suggested on Thursday that the recent ISIS terror attacks in Tehran were a positive development during a House Foreign Affairs Committee hearing on Hezbollah:

“We have recently seen an attack on Iran, and the Iranian government – the mullahs, I believe that Sunni forces have attacked them,” stated Rohrabacher. He then asked the panel, “Isn’t it a good thing for us to have the United States finally backing up Sunnis who will attack Hezbollah and the Shiite threat to us, isn’t that a good thing? And if so, maybe…this is a Trump strategy of actually supporting one group against another.”

As a voter in or near Rohrabacher’s district, you must make your voice heard. Take action using the tool on this page to email Rohrabacher. 

Follow up action: Call 1-844-ACT-NIAC (1-844-228-6422) to be connected to Rohrabacher’s office to call for him to retract and apologize for his remarks

See our write-up on the shocking exchange, and then let Rep. Rohrabacher know that this is unacceptable and that he should immediately apologize for his outrageous cheerleading of terror!


Tell Your Senators: Protect diplomacy with Iran!

Iranians dancing in celebration! A win for moderation: Rouhani beats hardliner candidates in landslide election

Don’t let Congress pass new sanctions!

Donald Trump is taking this country down a very dangerous path by following the Saudis back down the perilous path to war with Iran. Please take action today before it is too late: use the below link to email and, even better, call your Senators today. 
Iran is no democracy, but millions of Iranians inside the country and around the world made their voices heard at the ballot box. They are working for peace, human rights, and positive change. The least the United States government can do is to not get in the way. 
Contact Congress today – and share this petition with 5 friends to do the same!


NIAC Action Statement on Passage of Iran Sanctions Act

Washington, DC – NIAC Action released a statement regarding the Senate vote to reauthorize the Iran Sanctions Act (H.R. 6297): 

We are disappointed that Congress has decided to renew the Iran Sanctions Act (ISA). We strongly oppose broad unilateral sanctions because they are ineffective, they punish the wrong people, and they pose barriers to far more effective tools to accomplish our interest – namely engagement. This extension is largely symbolic, given the President already has the authority to impose these sanctions and these sanctions are being waived under the nuclear deal. However, the ISA renewal could pose real consequences. 

Some argue renewing ISA is necessary to send a message that the U.S. will impose sanctions if Iran violates the nuclear deal, but this was never up for question. The real uncertainty that threatens the nuclear deal is the open question as to whether the U.S. will fully implement its sanctions relief obligations as required under the deal. It is a question being asked by U.S. partners in Europe and elsewhere, inside Iran, and among commercial interests who have not engaged Iran as anticipated because of political uncertainty and challenges posed by sanctions. Especially considering the current political situation in the US, passing ISA exacerbates that uncertainty. 

Lawmakers and the Obama Administration, as well as the incoming Administration, must now make it clear that – even if ISA is renewed – the U.S. will uphold the terms of the nuclear agreement. This includes lifting all nuclear-related sanctions by October 2023 and taking necessary steps to address lingering obstacles to sanctions relief. 
There were concerns that Congress would attach new sanctions to the ISA renewal in violation of the deal, which has been avoided. Unfortunately, we are now still faced with a situation in which Iran is likely to retaliate against what it perceives to be a U.S. violation of the JCPOA. By agreeing to a clean extension of the Iran Sanctions Act, some may have believed Iran could be baited into taking responsive action putting at risk the nuclear accord. They may not be wrong. Iran has long signaled that it would impose counter-measures against the United States should ISA be re-authorized. It wouldn’t be surprising if Iran does take certain measures that could be in violation of the spirit of the nuclear deal. Those interested in protecting the Iran nuclear deal and preventing war and the spread of nuclear weapons must now redouble their efforts to ensure that the deal is fully implemented on all sides, including by avoiding a tit for tat escalation and by taking necessary action to ensure sanctions relief moves forward as required.

Time to Fight

Dear Iranian American,

We have taken time to assess the impact of the election, and it is clear that President-Elect Donald Trump puts everything we have achieved in jeopardy.

The nightmare scenario on civil rights that many feared under a Trump Administration is rapidly moving forward.

A “Muslim registry” proposal – requiring people from Muslim-majority countries to register with the U.S. government, submit fingerprints, undergo interrogation, and regularly check in with authorities – is now being developed by top Trump official Kris Kobach, who masterminded the post-9/11 program to register immigrants from Iran and other countries.

A Trump surrogate justified these efforts on Fox News last night by citing Japanese internment camps and efforts to track Iranian students during the hostage crisis.

Now is not the time for fear, it is the time for action. I still believe we can stop this, but only if every single one of us is invested in this battle.

We are fighting these proposals as I write this. And we are preparing for a major public battle in the coming days and weeks to block these unimaginable scenarios from becoming reality. We are working with ACLU and other organizations since we cannot win this alone.

In addition, the nuclear deal with Iran is in grave danger and the potential for war is something we cannot dismiss.

People with deep ties to the Mujahedin-e Khalq who have explicitly called for bombing Iran, like Rudy Giuliani and John Bolton, are being considered for Secretary of State in the Trump Administration.

Senator Tom Cotton, who wants to rip up the Iran deal and says we can bomb Iran’s nuclear program “back to day zero,” is in the running for Secretary of Defense.

And Trump is consulting with and considering top jobs for conspiracy-theorists like Clare Lopez and Frank Gaffney, who promoted the “Obama is a Muslim” myth and who have promoted dark conspiracy theories against NIAC and senior Obama administration officials on the basis of their ethnicity.

This is not a drill. This is dead serious. We have never faced a threat to the future as grave as this.

We have one ask of you right now – donate. We need the resources from our community today and the biggest impact you can make is by ensuring our organization has the funding necessary to win.

We are mobilizing to stop these nominations and block pro-war efforts before it is too late. We are already involved in efforts to protect our civil rights. But we can’t do it without funding from our community.

We have raised more than half of the $400,000 we had as our end-of-the-year goal. But we need to go beyond that now mindful of the dramatic new challenges at hand.

Please contribute $100 or an amount that is right for you so that we can win the battles to come and become a stronger community as a result.

We are counting on you.


Trita Parsi
Board Member

Support the Equal Protection in Travel Act (S. 2449 / H.R. 4380)


Click to view PDF

In the aftermath of terrorist attacks in Paris and San Bernardino, Congress aimed to close loopholes in the Visa Waiver Program (VWP) so that people who had recently traveled to areas where ISIS operates could not travel to the U.S. without a visa. But behind closed doors, Congressional negotiators added Iran to the list and restricted anyone who is a dual national of Iran, Iraq, Sudan or Syria from participating in the VWP. The legislation was included in a must-pass spending bill and now restricts visa-free travel to the U.S. for Europeans of Iranian descent.

These restrictions discriminate on the basis of family heritage

Because Iran, Iraq and Sudan pass citizenship automatically through the father, individuals can be restricted from the VWP based on their family heritage and not on any decision they have made.

The discriminatory restrictions do not make America safer

The dual-nationals restrictions automatically punish individuals who have never even set foot in Syria, Iraq, or other territories where ISIS operates.

These restrictions would not have applied to the San Bernardino attackers – an American and a Pakistani who studied in Saudi Arabia; nor to the 9/11 hijackers – fifteen Saudi nationals, two UAE nationals, and one Egyptian national.

Americans could be targeted based on their heritage

The VWP is reciprocal, meaning Congress is inviting similar restrictions to be imposed on American citizens. Iranian Americans could be barred from traveling visa-free to the EU, Japan, Australia or any number of VWP countries simply because of their heritage.

Who supports repealing the provisions?

Iranian-American, Arab-American and civil liberties organizations including the ACLU have sought the repeal of the restrictions.

35 CEOs and tech leaders sent a letter urging Congress to repeal the restrictions, including Dallas Mavericks owner Mark Cuban and Twitter CEO Jack Dorsey.

The Equal Protection in Travel Act of 2016 is a bipartisan solution

The Equal Protection of Travel Act narrowly repeals the restrictions against dual nationals.

  • House sponsors: Reps. Amash (R-MI), Massie (R-KY), Conyers (D-MI) and Dingell (D-MI).
  • Senate sponsors: Sens. Flake (R-AZ), Durbin (D-IL) and Booker (D-NJ).

10 Reasons to Beshkan the Vote!

The 2016 election has been unlike any recent election and many of us don’t know what to expect next. Now more than ever, the Iranian-American community’s rights and interests are at stake. Attempts to kill the Iran nuclear deal and return us to the path of war continue. Threats to discriminate against people based on their heritage are real, as we saw with the passage of visa discrimination. Voting in this election is crucial: to protect our values, prevent discrimination, and advance peace and diplomacy. Here are the top 10 reasons to Beshkan the Vote. Your vote is your voice. Let it be heard!

1. Protect the nuclear deal

You wouldn’t believe it, but Congress is still trying to kill a deal that avoided a war.


The nuclear deal is working, Iran is complying with its obligations, and yet it continues to come under attack by opponents of diplomacy. Help ensure that the deal will last by electing a president who will protect the deal and a Congress that will stop the stream of poison pill legislation to kill it.

2. Help the Iranian people get the tangible benefits they were promised by the deal.


The remaining U.S. embargo and secondary sanctions on Iran continue to undermine the success of the deal and deny ordinary Iranians the benefits. But as long as Congress is dominated by hawks, it will be extremely difficult to fix these issues. Use your voice to shift the political landscape so that we can make sure all sides uphold the agreement and the deal is sustainable.

3. Ensure the diplomatic opening between the U.S. and Iran doesn’t disappear.


The success of nuclear negotiations had a lot to do with the personalities involved. Unfortunately, Obama and Kerry will not be in office much longer. Help elect a President and Congress that want to sustain the deal, improve relations, and use diplomacy to address remaining challenges like human rights.

4. Oppose discriminatory travel laws targeting Middle Easterners.


The current Republican-controlled Congress won’t allow a vote to repeal visa discrimination and instead continues to introduce legislation that would require DNA tests for visas, bar Iranians from studying in the U.S., and pose unnecessary obstacles for Iranians to travel.  Make sure our next Congress commits to opposing and repealing discriminatory laws.

5. Fight for your mamanjoon’s right to travel visa-free like other dual nationals, so she can visit and cook ghormeh sabzi for you.


As a result of the passage of H.R.158, numerous Iranian dual nationals from Europe have been denied visa-free travel to the U.S. because of their Iranian heritage. The European Union recently decided against imposing the discriminatory law on Iranian Americans – but we are still fighting for other dual-nationals, many of whom have family in the United States.

6. To put it simply: because your vote is your voice.


No matter your beliefs or opinions, your vote matters on election day. 

7. Be like Iranian-American actress Yara Shahidi and make sure you’re represented.


As racial tensions, Islamophobia, and anti-Iranian sentiments grow, Iranian Americans face new issues of discrimination and racism. Now, it is even more important to make sure the politicians who represent you understand your concerns and experiences.

8. Get informed on the issues you care about.


Educate yourself about where candidates stand and promote your values.

9. Register yourself and your family to vote.


If you’re already registered, register your maman, baba, abji, dadash, khale, amoo and everyone you know! You can register here.

10. And Beshkan the Vote on election day!


Visit to learn how and why Iranian Americans are going to #BeshkanTheVote this year!

Memo: Iran Accountability Act (H.R. 5631) Would Fatally Undermine Iran Deal

The Iran Accountability Act of 2016 (H.R. 5631) – sponsored by House Majority Leader Kevin McCarthy (R-CA) – would breach US commitments under the Iran nuclear accord and thus fatally undermine the historic agreement. Introduced ahead of the Iran nuclear accord’s first anniversary, the bill evidences the fact that – despite a now-proven track record of reversing and limiting Iran’s nuclear program – Congressional opponents of the nuclear accord remain hell-bent on upending the historic agreement and returning us to the path of conflict and confrontation with Iran.

By imposing sanctions on large swathes of Iran’s economy, the bill would violate U.S. obligations to “refrain from any policy specifically intended to directly and adversely affect the normalization of trade and economic relations with Iran…” Certain provisions of the bill could also mandate the President to impose new nuclear-related sanctions on Iran or re-impose sanctions on Iran that had been lifted under the nuclear accord. Despite its pretensions to the contrary, the bill would thus be a clear and unmistakable violation of the Iran nuclear accord.
The bill would, amongst other things:

  • Require the President to impose broad sectoral sanctions on Iran’s economy, particularly those that facilitate, support, or are involved in the development of or transfer to Iran of ballistic missiles or technology, parts, components, or information relating to ballistic missiles. This could include sanctions on all persons involved or operating in the chemical, computer science, construction, electronic, metallurgy, mining, research (including Iranian universities and research institutes), and telecommunications sectors of Iran. As such, all Iranian persons and entities involved in Iran’s research sector, including its universities, could be subject to blocking and secondary sanctions under this far-reaching provision.
  • Effectively designate the Iranian Revolutionary Guards Corps (IRGC), its agents or affiliates, and any entity that is owned or controlled by the IRGC as a Foreign Terrorist Organization, and all IRGC officials, agents, or persons controlled by the latter as Specially Designated Global Terrorists. For purposes of this provision, the bill would lower the threshold on what constitutes ownership or control so that an entity is deemed owned or controlled by the IRGC if the IRGC holds more than 25% of the equity interest in the entity; holds any seats on the board of directors of the entity; or otherwise controls the actions, policies, or personnel decisions of the entity. This provision is intended to cause major compliance headaches for foreign companies interested in re-engaging Iran, thereby dissuading firms from re-entering the Iranian market.
  • Mandate the President to impose sanctions on European companies providing services for flights routing to Europe and flown by Mahan Air. This would include companies providing fuel, ramp assistance, baggage and cargo handling services, catering, refueling, ticketing and check-in services, crew handling, and other services related to flight operations. In mandating the President to impose sanctions on such European entities, this bill would needlessly provoke a diplomatic crisis with our close European allies and partners in a manner that will reduce the U.S.’s ability to effectively utilize sanctions in the future.
  • Risk re-imposing sanctions on Iranian persons and entities whose inclusion in the Annexes to United Nations Security Council Resolutions 1737, 1747, and 1929 had been lifted pursuant to the nuclear accord. In imposing such sanctions, the U.S. would put in doubt its compliance with its commitments under the Iran nuclear accord. Doing so could also provoke Iranian counter-measures that would put at risk Iran’s nuclear-related obligations.
  • Require the President to impose sanctions on Iran’s entire governing infrastructure, including President Rouhani, members of Iran’s parliament, and other officials, regardless of their involvement in Iran’s human rights abuses. This would be a significant escalation in the use of U.S. sanctions against Iranian government officials and would ignore the considerable progress that Iranian moderates have made in recent parliamentary elections.

In sum, passage of this bill would contradict U.S. obligations under the nuclear accord and place at risk the nuclear accord as a whole. In doing so, Congressional opponents of the nuclear accord would undermine vital U.S. national security interests to ensure Iran’s nuclear program is placed under strict decades-long limitations and rigorous inspections.