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Banking. Insurance and Reinsurance. Disclosure and Debarment. Shipping.
Sanctions and public pressure are working to economically isolate the Iranian regime. Two factors have led to Iran’s increasing economic isolation: 1) laws that sever Iran from international trade and financial markets, and legally prohibit investment and business by entities in Iran; and 2) private advocacy campaigns that stigmatize Iran business to the point where the reputational and financial risks of such business become too great to continue.
UANI’s ongoing strategy to further isolate Iran economically focuses on the continued use of sanctions law and private advocacy campaigns to deny Iran access to crucial international financial services and international trade.
Four areas will be of particular importance as UANI focuses on developing and implementing comprehensive sanctions to economically isolate Iran, namely Banking, Insurance and Reinsurance Services, Disclosure and Debarment and Shipping (BIDS). Click to learn more about each area of BIDS as well as UANI's complementary Auto Campaign.
Through an international banking blockade, the Iranian regime must be denied access to the international banking system via the adoption of measures to punish entities, groups, institutions and countries that facilitate financial transactions between Iranian banks and the world’s global financial institutions. All Iranian financial institutions should be the focus of new sanctions, especially since not all Iranian banks are currently designated. Further, there should be no limit on the areas of prohibited banking activity (i.e. in the case of non-private foreign financial institutions including central banks or foreign state-owned or controlled banks should not be limited to petroleum-related transactions). Any financial institution participating in, transacting in any way, holding or transmitting funds, arising out of or related in any way to a “barter” transaction should be penalized. Absent access to the international financial system, Iran’s ability to sell and receive revenue for its oil sales would be severely impeded, denying the regime the financing necessary for its illicit activities. By imposing a sweeping international banking blockade against the Iran, the global community can stymie efforts by the Iranian regime to utilize non-sanctioned banks to circumvent efforts to sever Iran from the international financial system.
UANI Corporate Campaigns – Banking
- Standard Chartered Bank (“UANI Applauds Standard Chartered Bank for Pulling Out of Iran,” 5/10/12)
- International Monetary Fund (“UANI Calls on IMF to Cease its Business with Iran's Central Bank,” 5/1/12)
- SWIFT ( “UANI Launches SWIFT Campaign Calls on SWIFT to Terminate Its Relationships with Iran's Banks and Financial Institutions,” 2/1/12; “UANI Issues Statement Following SWIFT’s Announcement to Discontinue Services to EU-Sanctioned Iranian Financial Institutions,” 3/15/12)
- AEG, Banque du Liban (“UANI Calls on Allied Engineering Group, Lebanese Central Bank to Close Lebanese Electronic Gateway for Iranian Funds,” 2/21/12)
- Banque de Commerce et de Placements (“UANI Applauds BCP, Swiss Bank, for Pulling Out of Iran,” 11/22/11)
- All Iranian banks should be the focus of new sanctions and there should be no limit on the areas of prohibited activity. Sanctions against Bank Markazi, Iran’s central bank, should be comprehensive and not limited. Any financial institution participating in, transacting in any way, holding or transmitting funds, arising out of or related in any way to a “barter” transaction shall be subject to sanctions.
- Banks should represent and certify that they do not facilitate, directly or indirectly, the transfer of hard currency into and out of Iran, and, in particular, banks should certify that they do not, directly or indirectly, facilitate transactions on behalf of any Iranian financial institution, including the Central Bank of Iran. Click here to learn more about UANI Banking Legislation.
- Legislation introduced in Congress regarding SWIFT access. (Reuters, “U.S. Pushes EU, SWIFT to Eject Iran Banks,” 2/15/12 )
- H.R. 4179: Iran Financial Sanctions Improvement Act of 2012 The bill would sanction the SWIFT network as long as it conducts services on behalf of any Iranian bank.
- On March 15, 2012, UANI CEO Ambassador Mark D. Wallace “call[ed] on U.S. lawmakers to sanction all Iranian banks. In order to implement the most robust sanctions in history, Iran should be cut off from the international banking system. Responsible countries and institutions must comply with the international banking blockade on Iran.” (See UANI Press Release, “UANI Issues Statement Following SWIFT’s Announcement to Discontinue Services to EU-Sanctioned Iranian Financial Institutions,” 3/15/2012)
- H.R. 3880: SWIFT Sanctions (Introduced 2/2/12 by Ileana Ros-Lehtinen)
- S. 2101: Iran Sanctions, Accountability, and Human Rights Act of 2012 (Introduced 2/15/12 by Tim Johnson)
Insurance and reinsurance companies that offer products or services in Iran and/or invest in any entity in Iran should be prohibited from doing business in the U.S., and be barred from entering into reinsurance agreements with any insurance or reinsurance company located in the U.S.
Insurance companies are the largest source of investment in the global economy after banks, representing an overall investment of approximately five trillion U.S. dollars. Irresponsible entities that continue to do business in or with Iran should not be the recipients of this lucrative investment. In addition, there are inherent risks associated with doing business in Iran. If companies, and the entities that insure them, are forced to assume the full and unmitigated ramifications of these risks, the appeal of doing business in Iran will disappear entirely.
The insurance industry is regulated at both the Federal and state levels. Accordingly, individual state insurance regulatory entities should require insurers to certify that they do not provide directly, through a foreign subsidiary or affiliate, any products or services in Iran and/or invest in any entity in Iran.
- Insurance and reinsurance companies that operate in the U.S. should represent and certify to the U.S. government that they do not offer products or services in Iran and/or invest in any Iranian entity directly or through a foreign subsidiary or affiliate. Absent such certification, companies may not enter into reinsurance or other service agreements with insurance or reinsurance companies in the U.S.
- State insurance regulatory entities should require insurers to certify they do not offer products or services in Iran or invest in an Iranian entity directly or through a foreign subsidiary or affiliate. Click here to learn more about UANI Insurance Legislation.
- Legislation in Congress (Bloomberg, “Global Insurers Targeted in Latest U.S. Bid to Expand Sanctions on Iran,” 3/8/12)
- H.R. 4179: Iran Financial Sanctions Improvement Act of 2012 Penalizes underwriters of insurance or reinsurance for any activity that is currently sanctionable under CISADA or other existing U.S. sanctions laws.
- S. 2101: Iran Sanctions, Accountability, and Human Rights Act of 2012 Penalizes those that provide insurance or reinsurance for shipping services to or from Iran that contributes to the proliferation of WMD or international terrorism.
Companies should be required to disclose any and all investments and business transactions in Iran and with Iranian entities. This can be accomplished via changes in the rules of the Securities and Exchange Commission (SEC), the UK Financial Services Authority (FSA) and similar regulatory counterparts. The moment companies are required to disclose their irresponsible business activities in Iran is the same moment companies will begin to end such Iran business for risk of reputational and financial harm.
In addition, companies that avail themselves of U.S. markets that wish to continue “business as usual” in Iran will be subject to debarment from government, state and municipal contracts. The prospect of debarment is one of the most effective ways to compel corporations to end their Iran business. Collectively, the Federal and state governments offer billions of dollars in contracts every year. No responsible and profit-driven company would jeopardize millions if not billions of dollars of government contracts by continuing to do business in Iran.
UANI Corporate Campaigns
- List of UANI Ongoing Campaigns
- List of UANI Campaign Successes
- Thematic Campaigns
UANI Model Legislation – Disclosure
UANI Model Legislation – Federal Debarment
UANI Model Legislation – State Debarment
- UANI has previously proposed regulations and legislation for adoption by the Securities and Exchange Commission (SEC) and U.S. Congress, respectively, which would require companies to fully disclose all Iran business to investors and the public—not just sanctionable business in Iran’s energy sector. UANI disclosure requirements were incorporated in the Iran Threat Reduction Act of 2011 (H.R. 1905, passed in the House on December 14, 2011) Click here to learn more about UANI Disclosure Legislation.
- UANI has proposed Iran contracting legislation for adoption by the Federal government and U.S. states that would compel companies to certify they have no business in Iran before receiving government contracts. UANI’s proposed legislation was signed into law in 2010. Click here to learn more about UANI Debarment Legislation.
- UANI proposed legislation was also adopted by U.S. states including California, Florida, New York, Indiana and Maryland in 2011-2012. U.S. states with existing Iran contracting legislation that bars companies investing over $20 million in Iran’s energy sector from receiving government funds should be explicitly authorized to lower the threshold for allowable investment in Iran to correspond with the latest Federal government legislation. Click here to learn more about UANI State Debarment Legislation.
International cargo and crude shippers that service Iranian ports should be barred from docking in the ports of the U.S. and EU for 10 years. Specifically, all tankers and general cargo vessels arriving in U.S. or EU ports should certify that they have not docked at an Iranian port or carried Iranian crude oil or downstream petrochemical products in the previous 36 months. Any vessel that has evaded or concealed such activity (e.g. by disabling a vessel’s tracking or GPS device) would be barred from U.S. and EU ports permanently.
The U.S. and EU should also debar shipping certification firms and classification societies that provide seals of approval to Iranian vessels and drilling rigs. Governments throughout the world rely on these certification firms and classification societies to ensure that vessels comply with national regulations and also meet recognized safety and maritime standards. A shipper needs certification by a classification society in order to secure insurance for its operations and gain entry to all major international ports.
- International Association of Classification Societies (UANI Launches Shipping Certification Campaign, Calls on IACS to Stop Certifying Iranian, IRISL Vessels,” 5/11/12)
- CMA-CGM (“UANI Calls on French Shipping Giant CMA CGM to End Its Business in Iran,” 3/10/11)
- Maersk (“UANI Calls on Maersk and Komatsu to Comply with Sanctions and End Their Business in Iran,” 6/30/10)
- KGL Holding Company (“UANI Applauds KGL for Ending Its Business in Iran,” 12/1/10)
- • Legislation requiring all tankers and general cargo vessels arriving in U.S. ports to certify that they have not docked at an Iranian port or carried Iranian crude oil or downstream petrochemical products in the previous 36 months with a 10 year bar. Click here to learn more about UANI Shipping Legislation, SSHIP Act of 2012.
- The Ethical Shipping and Inspections Act of 2011 (S. 1496/H.R. 2998): Legislation prohibiting the U.S. from delegating representative authority to classification societies that conduct related services for Iran. (Christian Science Monitor, “Shipping Industry Must Choose between Iran and the U.S,” Lieberman and Collins, 12/15/11)
Other UANI Initiatives
Complementary to the BIDS doctrine, UANI develops additional initiatives to isolate Iran economically and diplomatically.
Any automobile company that receives U.S. government contracts should be prohibited from exporting or manufacturing passenger and commercial vehicles in Iran directly or through a foreign subsidiary or affiliate. Automakers have been reported to produce different types of vehicles and key components (including military and internal security-related products) in Iran. Further, no automobile company that sells to U.S. consumers should take on significant ownership positions in entities that do business in Iran.
- Nissan-Renault (“UANI Calls on Nissan, Renault to Account for Renault's Business in Iran,” 4/4/12)
- Hyundai Motor Company (The New York Times, “Iran: Hyundai Motor Ends Operations,” 4/3/12)
- Mazda (“UANI Calls on Mazda to End Iran Business as Part of IRGC Campaign,” 3/19/12)
- General Motors and PSA Peugeot Citroen (“UANI Calls on Peugeot to End Iran Business, Calls on General Motors to End Partnership with Peugeot if Peugeot Fails to Withdraw from Iran,” 3/12/12; “UANI Statement on Peugeot’s Business in Iran,” 5/3/12)
- Fiat (“UANI Renews Campaign Against Fiat, Calls on Jennifer Lopez to Renounce Fiat Ties,” 1/12/12)
- Taxi of Tomorrow Campaign: Nissan and Karsan (“UANI Calls on Mayor Bloomberg to Refuse to Award Taxi of Tomorrow Contract to Companies that Conduct Business in Iran,” 1/6/11)
- Karsan (“UANI Applauds Turkish Company Karsan For Ending its Business in Iran,” 3/9/11)
- Automakers that receive federal government contracts must certify with the U.S. Department of Transportation that they are not engaged in business in Iran, or engaged in the implementation of any agreement with Iranian entities. Click here to learn more about UANI Automobile Legislation, DRIVE Act of 2012.