The Scope of Iran's Commitments and Expectations from the JCPOA

Ali Akbar Salehi, the head of Iran's Atomic Energy Organization, who traveled to London to participate in the annual meeting of the World Nuclear Association, emphasized in an interview with The Guardian that all of Tehran's "nuclear commitments" under the JCPOA are being fulfilled. He reiterated the frequent complaints of the Iranian leadership and political-military officials about the West's "broken promises," while a significant part of Iran's commitments lies outside the realm of "nuclear actions." Since the implementation of the JCPOA, sanctions preventing the purchase of Iranian oil have been lifted, and according to government confirmation, the export of crude oil has increased by more than one million barrels per day compared to last year. Additionally, barriers related to the insurance of oil shipments have been removed, and European markets, along with the lifting of purchase restrictions from Asian countries, have opened up to Iranian crude oil. Iran's foreign trade, despite ongoing banking transfer issues, enjoys similar facilities to the pre-2012 sanctions situation. So far, dozens of trade-political delegations have traveled to Iran to develop trade, and from East to West (Russia, China, and Italy) have expressed readiness to provide financial facilities and credit purchases to Iran. Despite this, Iran's economic stagnation remains at a pre-lifting sanctions level, and government officials, instead of addressing the crisis's roots internally, only criticize the "broken promises of the West." Mr. Salehi, as the former deputy president and foreign minister, is well aware of the problems of the state economy, the business environment, the broken banking system, the extent of smuggling trade, the significant share of institutions and organizations outside the government's management in money laundering, and the impact of continued money laundering in keeping large banks away from the Iranian market. Mr. Salehi raises expectations that their fulfillment is related to Iran's proportional and positive movement and cooperation. For example, one of Iran's expectations, likely raised during Salehi's stay in London in side discussions with BP officials and the new British government, is receiving its share from the "Ram" gas field in the North Sea, of which 50% belongs to Iran. Since production in the mentioned field resumed two years ago, about $200 million in gas sales profit has been kept in a special account named after BP, Iran's partner, and major European banks have refrained from accepting responsibility for opening a special account for Iran and transferring Iran's share until favorable conditions are met. To exit the blacklist of money laundering, last year the Iranian government undertook commitments to the "Financial Action Task Force" (FATF). This group was established in 1989 as an intergovernmental organization to effectively combat money laundering, block financing channels for terrorism, and address other threats to the health of the international monetary system, and it drafted a document containing 40 recommendations that member countries are committed to implementing. In executing part of these commitments, Sepah Bank and Mellat Bank announced last month that they would refrain from providing financial services to the Khatam headquarters and IRGC institutions; a decision that provoked sharp criticisms from hardliners and military officials, directing their attacks towards the government. Iran has not joined the task force, but the Central Bank of the Islamic Republic has committed, on behalf of the government, to implementing the group's 40 recommendations. During this year's meeting in Seoul, South Korea's capital, the FATF welcomed President Rouhani's commitment to align with the group's recommendations and granted Iran a one-year opportunity to implement them. At the end of the one-year deadline, the state of banking in Iran and the results of the government's actions to combat money laundering will be reviewed again by the group, and granting a green light to international banks to engage in monetary transactions with Iranian institutions and individuals or to continue and even intensify sanctions against Iran will depend on the group's positive report. The situation resulting from the continued state economy in Iran, on the one hand, and the increasing power of "institutions" and "foundations" instead of strengthening the real private sector, including commercial and financial institutions affiliated with the IRGC, the "Executive Headquarters of Imam's Command" with $100 billion in assets outside the government's influence, rent-seeking, tax evasion, smuggling trade worth up to $20 billion annually, and the sending of unregistered financial aid outside the legal banking system to fund the continuation of proxy wars in Syria, Iraq, Yemen, and Hezbollah in Lebanon, has turned money laundering into a common financial practice in Iran. Apparently, to combat widespread money laundering, the parliament passed the "Anti-Money Laundering Law" in Bahman 1386 (January 2008), consisting of 12 articles and seven notes, which was approved by the Guardian Council two weeks later and communicated to the government. In implementing this law, the government established a "High Council for Combating Money Laundering" headed by the Minister of Economy and Finance and including several ministers and the head of the Central Bank. Despite this, Iran remains significantly distanced from other countries and is still at the top of the blacklist of countries accused of money laundering, and well-known banks avoid approaching Iranian banks to evade accusations of cooperating with Iran and being condemned to pay heavy financial penalties to the U.S. Treasury. To gain more advantages from the JCPOA, Iran's unconventional and revolutionary government is compelled to accept contracts and regulations that are formulated for conventional governments in the international community. The officials of the Islamic Republic, who direct their criticisms regarding the JCPOA towards foreign broken promises, will find a receptive audience among public opinion when they do not limit alignment with the expectations of the global community to the implementation of nuclear commitments (JCPOA); otherwise, the continuation of the current situation will exemplify a vicious circle where unmet expectations lead to disregard for broader commitments and irresponsible behavior in the international community results in further deprivation of benefits.