3k Account STEAM.txt
There are a total of about $46 billion in court awards that have been made to victims of Iranian terrorism. These include the families of the 241 U.S. soldiers killed in the October 23, 1983, bombing of the U.S. Marine barracks in Beirut. U.S. funds equivalent to the $400 million balance in the DOD account (see above) have been used to pay a small portion of these judgments. The Algiers Accords apparently precluded compensation for the 52 U.S. diplomats held hostage by Iran from November 1979 until January 1981. The FY2016 Consolidated Appropriation (Section 404 of P.L. 114-113) set up a mechanism for paying damages to the U.S. embassy hostages and other victims of state-sponsored terrorism using settlement payments paid by various banks for concealing Iran-related transactions, and proceeds from other Iranian frozen assets.
3k Account STEAM.txt
The ability of Iran to repatriate hard currency to its Central Bank, including U.S. dollars that are the primary form of payment for oil, was impeded by Section 504 of the ITRSHRA which went into effect on February 6, 2013. The provision amended Section 1245 of the FY2012 NDAA (adding "clause ii" to Paragraph D) to require that any funds paid to Iran as a result of exempted transactions (oil purchases, for example) be credited to an account located in the country with primary jurisdiction over the foreign bank making the transaction.
This provision essentially prevents Iran from repatriating to its Central Bank any hard currency Iran held in foreign banks around the world. Most of Iran's funds held abroad are in banks located in Iran's main oil customers. The provision largely compels Iran to buy the products of the oil customer countries. Some press reports refer to this arrangement as an "escrow account," but State Department officials describe the arrangement as "restricted" accounts. In addition, because of the September 25, 2019, designation of the Central Bank as a terrorist entity under E.O. 13224, Iran's ability to draw down its Central Bank accounts abroad to pay for imports of humanitarian has been impeded because the 13224 designation does not carry a humanitarian exception.
The waiver provision that applies to the sanctions imposed under the FY2012 NDAA (P.L. 112-81) applies to this Iran foreign bank account restriction provision. A waiver period of six months is permitted.
To implement the JPA, a waiver was issued under P.L. 112-81 (Section 212 and 213) to allow Iran to receive some hard currency from ongoing oil sales in eight installments during the JPA period. Iran remained unable under the JPA to remove hard currency from existing accounts abroad. As of Implementation Day, the restriction was waived completely, enabling Iran to gain access to hard currency from ongoing purchases of its oil.
Successive Administrations have expanded sanctions, primarily by executive order, on several significant nonoil industries and sectors of Iran's economy. The targeted sectors include Iran's automotive production sector, which is Iran's second-largest industry (after energy), and its mineral exports, which account for about 10% of Iran's export earnings.
Numerous sanctions target Iran's Islamic Revolutionary Guard Corps (IRGC), and none was waived or terminated to implement the JCPOA. The IRGC plays a role in both internal and external defense, supports pro-Iranian movements in the region, and owns or controls economic entities in Iran that account for as much as 20% of Iran's economic output. Many of the IRGC's subordinate units, such as the IRGC Qods Force and the Basij militia, have been designated for sanctions under various Executive Orders, as have corporate entities owned or controlled by the IRGC, such as the large engineering firm Khatam ol-Anbia.
On November 6, 2008, the Department of the Treasury broadened restrictions on Iran's access to the U.S. financial system by barring U.S. banks from handling any transactions with foreign banks that are handling transactions on behalf of an Iranian bank ("U-turn transactions").34 This means a foreign bank or person that pays Iran for goods in U.S. dollars cannot access the U.S. financial system (through a U.S. correspondent account, which most foreign banks have) to acquire dollars for any transaction involving Iran. This ban remained in effect under the JCPOA implementation, and Iran argued that these U.S. restrictions deter European and other banks from reentering the Iran market, as discussed later in this report.
During 2010-2016, Japan and South Korea enforced sanctions on Iran similar to those imposed by the United States and the EU. Both countries cut imports of Iranian oil sharply after 2011, and banks in the two countries restricted Iran's foreign exchange assets Iran held in their banks. From 2016-2018, both countries increased importation of Iranian oil, and eased restrictions on Iran's accounts.
India's cooperation with reimposed U.S. sanctions since 2018 is mixed, in part because no U.N. sanctions have been reimposed.82In June 2018, the two countries again agreed to use rupee accounts for their bilateral trade. After India's SRE, last granted in November 2018, expired in May 2019, it was widely expected that India and Iran would work out alternative payment arrangements under which India will continue importing at least some Iranian oil. Indian officials said in May 2019 that India would comply with U.S. sanctions and find alternative suppliers, and India's import of Iranian oil have been zero since the end of April 2019.
Some of the scarcity of medicines is caused by banks' refusal to finance such sales, even though doing so is not subject to sanctions. Some observers say the Iranian government exaggerates reports of medicine shortages to generate opposition to the sanctions. Other accounts say that Iranians, particularly those with connections to the government, take advantage of medicine shortages by cornering the import market for key medicines. In late 2018, reports indicated that the reimposition of U.S. sanctions may be inhibiting the flow of humanitarian goods to the Iranian people and reportedly contributing to shortages in medicine to treat ailments such as multiple sclerosis and cancer.117 Other reports indicate that Cargill, Bunge, and other global food traders have halted supplying Iran because of the absence of trade financing, 118 or, alternately, their shipments have been held at Iranian docks until payments clear. Iranian officials and some international relief groups have complained that U.S. sanctions inhibited the ability to provide relief to flooding victims in southwestern Iran in March-April 2019.
Islamic Republic of Iran Broadcasting (IRIB) and Ezzatollah Zarghami (director and head of IRIB); Iranian Cyber Police (filters websites and hacks email accounts of political activists); Iranian Communications Regulatory Authority (filters internet content); Iran Electronics Industries (producer of electronic systems and products including those for jamming, eavesdropping
Foreign banks that do not have operations in the United States typically establish correspondent accounts or payable-through accounts with U.S. banks as a means of accessing the U.S. financial system. 041b061a72