UANI Statement on Implementation Day, Release of American Hostages, and Risks of Iran Business

FOR IMMEDIATE RELEASE
January 21, 2016
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UANI Statement on Implementation Day, Release of American Hostages, and Risks of Iran Business

Additional Fact Sheets on Iranian Aggression since JCPOA, Pardoned Iran Sanctions Violators, and Ballistic Missile Sanctions

New York, NY - Leaders of United Against Nuclear Iran (UANI) today released a statement and related fact sheets concerning the implementation of the Iran nuclear deal, sanctions relief, and the return of American hostages. UANI Chairman Senator Joseph I. Lieberman and CEO Ambassador Mark D. Wallace said:

The implementation of the nuclear deal with Iran and the resulting sanctions relief windfall come at a time of increasingly extreme and bellicose Iranian behavior.

A scant few days prior to Implementation Day and the lifting of nuclear-related sanctions, Iran seized U.S. naval vessels and held their crewmembers at gunpoint. In the preceding months Iran also test-fired long-range ballistic missiles in violation of UN Security Council Resolutions, orchestrated the ransacking and burning of the Saudi embassy in Tehran, and ramped up its military campaign to preserve the Assad regime in Syria in coordination with Russia.

In recent days, Americans were also reminded of the regime's longstanding practice of hostage-taking and arbitrary detention. We congratulate the American hostages on their overdue freedom and applaud the Obama Administration's efforts to secure their return. We continue to be deeply concerned about Bob Levinson and Siamak Namazi, two Americans who remain unjustly detained in Iran, and call for their immediate, unconditional release. Clearly, Iran remains an extremely risky destination for travelers and businesspeople as firms cannot guarantee that their employees-American, European, Iranian, or otherwise-will not be subject to arbitrary arrest and detention.

It is regretful however that in exchange for American hostages held in deplorable prison conditions, the Administration agreed to release a much larger number of sanctions-violators either charged or convicted under U.S. law while also dropping international arrest warrants for arms traffickers and persons linked to terrorism-related activities on behalf of the Iranian regime. Unsurprisingly, not a single incarcerated or charged individual of Iranian origin in the United States chose to board the U.S. government plane to return to Iran. All chose to stay in the United States.

The pardoning of these Iran-related sanctions violators is a blow to sanctions enforcement efforts. Unless and until Iran changes its behavior for the better, additional and sustained enforcement action is needed, such as U.S. Treasury's recent step to sanction Iran for the illicit long-range ballistic missile tests it carried out in October and November. It is essential for businesses and entities worldwide to understand clearly that the U.S. will continue to pursue action to pressure and isolate sanctioned entities including Iran's Islamic Revolutionary Guard Corps (IRGC), which has a ubiquitous presence in Iran's national economy, and also take action to end Iran's human rights abuses, terrorist activity, and ballistic missile program. Given Iran's track record of illicit behavior, the enforcement and likely prospect of further punitive, extraterritorial U.S. sanctions will remain a powerful impediment and risk factor for businesses worldwide that may be considering working in Iran.

Nonetheless, the disparity between the massive sanctions relief provided to Iran on Implementation Day and the temporary limitations placed on both Iran's nuclear capabilities and its capacity for destructive behavior remains troubling. In addition to the $100 billion Iran is estimated to receive from the lifting of nuclear-related sanctions, the Obama Administration agreed to pay Iran $1.7 billion in debt and interest even as American victims of Iranian terror continue to be denied their long-overdue restitution from Tehran. Those victims of Iranian terror should have received the $1.7 billion.

The provision of such substantial sanctions relief at a time when overwhelming evidence indicates that the JCPOA process has failed to "moderate" Iran is deeply concerning. On the contrary, the hardline figures committed to the revolutionary principles of the Islamic Republic remain firmly in charge. And now that Iran has pocketed its most prized concessions and primary goals throughout negotiations - large-scale sanctions relief and unfreezing of funds - the international community should expect only more and intensified aggression and repression from an emboldened Tehran. For example, on Implementation Day, the Iranian regime's Guardian Council carried out a massive disqualification of candidates for the February 26 Iranian parliamentary elections. Approximately 60 percent of all candidates were disqualified, and more than 99% of reformist candidates were barred.

It is disturbing to contemplate that now that the Supreme Leader has secured his objectives in negotiations, emboldened hardliners will enjoy the spoils of sanctions relief and further purge the potential reformers - the very elements that analysts argued would be empowered by this agreement.

Overall today, Iran presents grave risks to businesses contemplating doing business there. It remains a primary destabilizing influence in the region and the world. Before Iran can be welcomed back into the community of responsible nations, it must demonstrate sustained compliance with the JCPOA, fundamentally abandon its pursuit of nuclear weapons, sponsorship of terrorism, human rights violations, and destabilizing aggression in the region.

Fact Sheet: Iran's Renewed Aggression and Repression

Since the signing of the Iran nuclear deal on July 14, 2015, Iran's aggression, particularly against the United States, has only intensified.

• Iran seized two U.S. naval vessels in the Persian Gulf and mistreated its American crew members, in contravention of the Third Geneva Convention.
• Iranian vessels recklessly fired rockets within 1,500 yards of U.S. naval vessels in international waters of the Persian Gulf.
• Iran test-fired long-range ballistic missiles, in violation of UN Security Council Resolutions.
• Iranian rioters ransacked and set fire to the Saudi Arabian embassy in Tehran.
• Iran has bolstered its armed intervention in Syria in alliance with Russia, and continues its intervention via violent, extremist Shiite proxies in Iraq, Yemen, and Lebanon.
• Iran's Supreme Leader, Ayatollah Khamenei, has renewed Tehran's commitment to anti-Americanism and opposition to the "Great Satan," which he says is attempting to "infiltrate" Iran with its corrupt culture. He has pledged to retain "Death to America" as the Islamic Revolution's slogan.
• Iran detained two additional American civilians-Iranian-American businessman Siamak Namazi and Nizar Zakka, a U.S. permanent resident from Lebanon and global communications technology expert.
• Iran executed more than 1,000 people in 2015, a 25-year high.
• Iranian authorities have launched a renewed crackdown on civil society, arresting journalists, artists, and activists.

Fact Sheet: Pardoned Iran Sanctions Violators and Suspended Criminal Prosecutions

As part of the swap to free the American hostages, President Obama granted full pardons "to seven men of Iranian origin either facing criminal charges in U.S. courts or already serving time in U.S. prison." This included "rare, pre-trial pardons to three men awaiting trial in Houston for violating U.S. export laws by shipping high-tech equipment to Iran."

Until now, President Obama had never granted a pre-trial pardon (nor did his immediate predecessor, George W. Bush). As opposed to simply dismissing the charges, the pardons prevent U.S. authorities from refiling the charges in the future.

1. Nader Modanlo
   
   Crime: "conspiracy to illegally provide satellite related services to Iran in violation of the International Emergency Economic Powers Act, money laundering and obstruction of bankruptcy proceedings."
   
   "Nader Modanlo violated the law by helping Iran launch communications satellites," said U.S. Attorney Rod J. Rosenstein. "The Iran Trade Embargo prohibits Americans from supplying goods, technology and services to Iran directly or indirectly."
   
   Sentence: "eight years in prison followed by three years of supervised release."
    
2. Bahram Mechanic
3. Khosrow Afghahi
4. Tooraj Faridi
   
   Alleged Crime: "Mechanic and the others engaged in a conspiracy to obtain various commodities, including controlled United States-origin microelectronics. They then allegedly exported these to Iran, while carefully evading the government licensing system set up to control such exports. The microelectronics shipped to Iran allegedly included microcontrollers and digital signal processors. According to the indictment, these commodities have various applications and are frequently used in a wide range of military systems, including surface-air and cruise missiles. Between July 2010 and the present, Mechanic's network allegedly sent at least $24 million worth of commodities to Iran... The individual defendants each face up to 20 years in federal prison."
    
5. Arash Ghahreman
   
   Crime: "violations of U.S. export and money laundering laws, arising from his involvement in a scheme to purchase marine navigation equipment and military electronic equipment for illegal export to, and end-use in, Iran."
   
   "The defendants used a front company to illegally send U.S. goods and technologies - including those used in military applications - to Iran," said Assistant Attorney General Carlin. "These violations of the Iran Trade Embargo have the potential to harm U.S. national security objectives, and we will continue to hold accountable those who seek to circumvent its restrictions. I would like to thank the agents and prosecutors for their hard work in obtaining this conviction."
   
   Sentence: "six and a half years in prison and three years' post-release supervision."
    
6. Nima Golestaneh
   
   Crime: "wire fraud and unauthorized access to computers related to his involvement in the October 2012 hacking of a Vermont-based engineering consulting and software company."
    
7. Ali Saboonchi
   
   Crime: "conspiracy and seven counts of exporting American manufactured industrial products and services to Iran... Saboonchi conspired with others to evade the Iran Trade Embargo by exporting American manufactured industrial goods and services to Iranian businesses."
   
   Sentence: "two years in prison, followed by one year of supervised release."

In addition to pardoning the seven sanctions violators held in the U.S., the Obama Administration also "removed any Interpol red notices and dismissed any charges against 14 Iranians for whom it was assessed that extradition requests were unlikely to be successful."

Two of the individuals no longer being prosecuted are executives of Iran's Mahan Air, which "has been using its planes to bring soldiers and arms directly to the Syrian military and the Lebanese terrorist group Hezbollah by flying them from Tehran to Damascus."

1. Hamid Arabnejad
   
   Crime: "Hamid Arabnejad was designated pursuant to E.O. 13224 for acting for or on behalf of Mahan Air as the Managing Director of the airline. Arabnejad oversees Mahan Air's efforts to evade U.S. and international sanctions. Arabnejad has a close working relationship with IRGC-QF personnel and coordinates Mahan Air's support and services to the paramilitary group. He has also been instrumental in facilitating the shipment of illicit cargo to Syria on Mahan Air aircraft."
    
2. Gholamreza Mahmoudi
   
   Crime: "Gholamreza Mahmoudi acts for or on behalf of Mahan Air as a senior official and corporate director at Mahan Air. Mahmoudi has worked closely with Mahan Air Managing Director Hamid Arabnejad on sanctions evasion strategies to acquire U.S. aircraft."
    
3. Behrouz Dolatzadeh
   
   Alleged Crime: "An Iranian businessman linked to a sprawling conglomerate controlled by Iran's supreme leader is wanted by the United States for allegedly trying to purchase hundreds of American-made assault rifles to smuggle into Iran."
    
4. Seyed Abolfazl Shahab Jamili
   
   Alleged Crime: "conspiring to export, and exporting, highly sensitive U.S. manufactured goods with nuclear applications to Iran."
    
5. Matin Sadeghi
   
   Alleged Crime: "Matin Sadeghi is wanted for conspiring with others to illegally transfer at least $24 million of micro-electronics and other components to Faratel-Iran, since July 2010."
    
6. Alireza Moazami Goudarzi
   
   Alleged Crime: Manhattan U.S. Attorney Preet Bharara stated: "As alleged, Alireza Moazami Goudarzi aggressively sought to purchase and export military-grade aircraft parts and other materials to Iran in violation of multiple statutes and regulations. Goudarzi brazenly discussed his willingness to pay higher prices in order to circumvent the embargo, and used multiple aliases and an international network of co-conspirators in his attempts to trans-ship materials to Iran, as is detailed in the allegations."
    
7. Koorush Taherkhani
   
   Alleged Crime: "accused in 2014 of using a Dubai front company to buy U.S.-made marine navigation equipment for use in Iran, in violation of sanctions."
    
8. Mohammed A. Sharbaf
   
   Alleged Crime: "Sharbaf collaborated to export forklift truck parts from the United States to Iran, via the United Arab Emirates."
    
9. Amin Ravan
   
   Alleged Crime: "charged in an indictment unsealed today with conspiracy to defraud the United States, smuggling, and violating the Arms Export Control Act (AECA) in connection with the unlawful export of 55 military antennas from the United States to Singapore and Hong Kong."
    
10. Jalal Salami
11. Mohammad Abbas Mohammadi
12. Sajjad Farhadi
13. Seyed Ahmad Abtahi
14. Ali Moattar

Fact Sheet: New Sanctions Designations on Iran's Ballistic Missile Program

After delaying sanctions that were originally to be imposed on Iran on December 30, 2015 for its illicit long-range ballistic missile tests carried out in October and November, the Obama Administration finally imposed them on January 17, 2016. Reuters reported that the White House had postponed the sanctions based on threats from Iran that such a move could undermine the prisoner swap being negotiated between the U.S. and Iran.

The U.S. Department of Treasury "designated 11 entities and individuals involved in procurement on behalf of Iran's ballistic missile program." Adam J. Szubin, acting Under Secretary for Terrorism and Financial Intelligence said, "Iran's ballistic missile program poses a significant threat to regional and global security, and it will continue to be subject to international sanctions... We have consistently made clear that the United States will vigorously press sanctions against Iranian activities outside of the Joint Comprehensive Plan of Action - including those related to Iran's support for terrorism, regional destabilization, human rights abuses, and ballistic missile program."

One of the individuals designated is Sayyed Javad Musavi, commercial director of the Shahid Hemmat Industrial Group (SHIG). According to the Treasury Department, Musavi "has worked directly with North Korean officials in Iran from UN- and U.S.-designated Korea Mining Development Trading Corporation (KOMID)... Within the past several years, Iranian missile technicians from SHIG traveled to North Korea to work on an 80-ton rocket booster being developed by the North Korean government."

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