THE VIEW FROM TEHRANS TWILIGHT ZONE human rights abuses, such as the IRGC, to the risk of being cut off from the U.S. financial 36 system. However, if CISADA were the only concern then doing business with Iran would have minimal risk; after all, there have only been two actions under CISADA ever, targeting Bank of Kunlun in China and Elaf Islamic Bank in Iraq.37 But engaging in business with Iran is not that simple. According to former deputy industry minister Mohsen Safai Farahani, “more than half of Iran’s economy is run by pseudo-private entities linked to “parastatal organisations”, including the 38 IRGC,” which poses a significant challenge to Western business investors attempting to identify exactly with whom they are engaging in business. 2. Sanctions Evasion Iran has relied upon an advanced and effective sanctions evasion network to both to obfuscate its illicit activity as well as to supplement its economy; and this continued reliance on sanctions evasion networks proves why Secretary Kerry’s strategy of instructing banks that “when in doubt, ask,” will 39 not work. Iranian officials have continued to blame the US for the lack of willingness from international banks to invest in Iran and claim that the United States “removed the sanctions in 40 paper only,” but this could not be farther from the truth. According to an economist close to Rouhani’s government, “between 5,000-10,000 people worked in the network, handling deals worth between $300 billion and $400 billion over the past decade.”41 The government of Iran will be in no great hurry to leave such a profitable sanctions sustainable for their economy. Therefore, in order to fully reintegrate into the financial world Iran will need to distance itself from the thousands of sanction evasion networks it has relied on for at least the past decade. It is because of sanctions evasion schemes and deceptive banking practices those banks and businesses alike are wary of engaging with Iran. But, insiders and economists agree, “Enough sanctions remain in place that the Iranian economy still cannot function without the network.”42 Iran’s hesitation in parting ways with these illicit financial networks only solidifies the public statement FATF made in February 2016, “The FATF remains particularly and exceptionally concerned about Iran’s failure to address the risk of terrorist financing and the serious threat this poses to the integrity of the international financial system,” and “continues to urge jurisdictions to protect again correspondent relationships being used to bypass or evade counter-measures and risk 43 mitigation practices.” 36 ‘CISADA The New US Sanctions on Iran’, US Treasury, available at: https://www.treasury.gov/resource- center/sanctions/Programs/Documents/CISADA_english.pdf, last visited: 11 May 2016. 37 ‘Treasury Sanctions Kunlun Bank in China and Elaf Bank in Iraq for Business with Designated Iranian Banks’, US Treasury, 31 July 2012, available at: https://www.treasury.gov/press-center/press-releases/Pages/tg1661.aspx, last visited: 11 May 2016. 38 Hulpachova, M., ‘Untangling Iran’s web of sanctions of the nuclear deal’, The Guardian, 13 April 2016, available at: http://www.theguardian.com/world/iran-blog/2016/apr/13/untangling-irans-web-of-sanctions-after-the-nuclear-deal, last visited: 11 May 2016. 39 Kerry, J., ‘Remarks Before Meeting with Iranian Foreign Minister Javad Zarif’, US State Department, 22 April 2016, available at: http://www.state.gov/secretary/remarks/2016/04/256536.htm, last visited: 11 May 2016. 40 Stancati, M., ‘Iran’s Supreme Leader Says Sanctions Still Affecting Country’s Economy’, The Wall Street Journal, 20 March 2016, available at: http://www.wsj.com/articles/irans-supreme-leader-says-sanctions-still-affecting-countrys-economy-1458502695, last visited: 11 May 2016. 41 Erdbrink, T., ‘Sanctions Eased, Iran Sends Black Market a Strategic Warning’, The New York Times, 19 March 2016, available at: http://www.nytimes.com/2016/03/20/world/middleeast/sanctions-eased-iran-sends-black-market-a-strategic-warning.html?_r=0, last visited: 11 May 2016. 42 Ibid. 43 ‘FATF Public Statement’, The Financial Action Task Force’, 19 February 2016, available at: http://www.fatf-gafi.org/publications/high-riskandnon- cooperativejurisdictions/documents/public-statement-february-2016.html, last visited: 11 May 2016. 5