January 28, Dear SCANI participants,

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1 January 28, 2010 Dear SCANI participants, Thank you for your commitment to bringing a student voice to the community effort to block Iran s quest for nuclear weapons. Your participation in the Student Coalition Against a Nuclear Iran has meaning well beyond your campuses, and it will make a tangible difference in international affairs. The materials compiled here were initially compiled for and through the hard work of the National Inter- Agency Task Force on Iran. The Conference of Presidents of Major American Jewish Organizations both provides leadership to that Task Force as well as the Israel on Campus Coalition s Iran task force, and many of the organizations involved graciously agreed to update and share those materials with you to aid in your collective efforts. This Toolkit therefore represents the most up-to-date and inclusive set of resource materials available; we hope you find it useful. On behalf of the ICC Iran task force and Hillel, thank you again for your leadership and your dedication. Your voices can and should be heard to make a positive change in the world. Best, Stephen Kuperberg Executive Director Israel on Campus Coalition Wayne L. Firestone President Hillel: The Foundation for Jewish Campus Life

2 National Inter-Agency Task Force on Iran Preventing a Nuclear Iran: Information and Resources Toolkit January, 2010

3 National Inter-Agency Task Force on Iran Recognizing the growing sense of urgency as Iran races toward nuclear weapons capability, the Conference of Presidents convened the Inter-Agency Task Force on Iran, to develop a coordinated approach that would maximize cooperation and utilization of resources. We are grateful to all of our member national agencies that have contributed so much and worked diligently and intensively over the past months. We especially note the co-conveners of the Task Force: the Jewish Council for Public Affairs, the United Jewish Communities and NCSJ: Advocates on behalf of Jews in Russia, Ukraine, the Baltic States and Eurasia, who, along with the national member organizations, made possible the development of the full-scale advocacy mobilization to raise awareness about the urgency of preventing Iran from acquiring nuclear weapons. We thank the organizations who prepared the materials enclosed and others who have helped to implement these initiatives. The following information and resources have been compiled to help address the issues and concerns about a nuclear Iran and provide action items on both a communal and national level. The toolkit contents include: The Task Force Mission Statement Backgrounders for Advocacy Legislative Initiatives Action Items Additional Resources For further information, go to: Conference of Presidents, United Against a Nuclear Iran (UANI), UJC/JCPA Israel Advocacy Initiative, Member organizations web sites whose material is enclosed Additional web links included in the Resources section of this toolkit Alan P. Solow Chairman Malcolm Hoenlein Executive Vice Chairman

4 The Iranian Nuclear Threat Prepared by the Anti-Defamation League A threat to America and American interests Backgrounder I A nuclear-armed Iran poses a threat to America s closest allies in the Middle East. Beyond Israel, this list includes the Egypt, Saudi Arabia, UAE, Bahrain, and others. Iran has provided material and financial support to anti-u.s. forces in Iraq. According to U.S. State Department, Iran is already a major proliferator of conventional weapons and has exported rocket and missile technology to terrorist groups like Hezbollah and Hamas. If Iran were to acquire a nuclear arsenal, there is a threat that Tehran could then export its nuclear knowledge, technology, and material to irresponsible state and nonstate actors alike. Iran already has a conventional weapons capability to hit U.S. and allied troops stationed in the Middle East and part of Europe. If Tehran were allowed to develop nuclear weapons, this threat would increase dramatically. A nuclear-armed Iran would likely spark a nuclear arms race in the Middle East that would further destabilize this volatile and vital region, undermining the international Nuclear Non-Proliferation Treaty. Iran is one of the world s leading state sponsors of terrorism through its financial and operational support for groups such as Hamas, Hezbollah and others. Iran could potentially share its nuclear technology and know-how with extremist groups hostile to the United States and the West. While Iranian missiles can t yet reach America, Iran having a nuclear weapons capability can potentially directly threaten the United States and its inhabitants. Many analysts are concerned about the possibility of a nuclear weapon arriving in a cargo container at a major US port or the threat posed by a nuclear warhead launched off the US coast and detonated high above American air space. How we know Iran is developing nuclear weapons Iran kept its nuclear program secret for 17 years even though international assistance would have been available to a civilian program. Since 2002, when Iran's covert program was exposed, the International Atomic Energy Agency (IAEA) has reported on Iranian technical documents that concern warhead design, production of a uranium core for nuclear weapons, adaptation of missiles to

5 carry nuclear warheads, missile warhead detonation at 1800 feet of altitude (which only makes sense for a nuclear weapon), and underground nuclear test silos. The November 2007 U.S. National Intelligence Estimate (NIE) on Iran: Nuclear Intentions and Capabilities confirmed the existence of a covert Iranian program to develop nuclear weapons and missiles to deliver them. While the NIE was widely misinterpreted as claiming that Iran ended its nuclear weapons program, it only claimed that nuclear warhead design was put on hold in 2003, while all other development was continuing. The Iranian regime Since the revolution in 1979, Iran has been run by a Shia Islamist regime, which has violently suppressed internal dissent. Both President Mahmoud Ahmadinejad, who was initially elected in 2005, and Ayatollah Ali Khamenei, the country's powerful Supreme Leader, are uncompromising hardliners. Iran is the world s number-one state sponsor of terrorism, and has provided financial support and training for organizations such as Hamas, Hezbollah, Islamic Jihad, and anti- U.S. insurgents in Iraq. The Iranian regime persecutes members of a wide range of minorities, social, and religious groups, including Christians, Bahais, homosexuals, women, labor activists, and student groups. o Under Iran s strict apostasy laws, conversion to Christianity is a crime punishable by death. o Homosexuality is illegal in Iran, and gay sex is considered a capital crime. o The Iranian government is escalating its attacks against women s rights activists After the disputed 2009 Iranian presidential elections, the government s security forces cracked down on peaceful demonstrations throughout the country, leading to the deaths of at least 20 and the arrest of more than 1,000 people. Iran's regime regularly calls Israel's demise, propagates anti-semitism and denies the Holocaust.

6 Backgrounder II Prepared by the Jewish Council for Public Affairs Urgent efforts are required by the United States and the international community to prevent the Iranian regime from acquiring a nuclear weapons capability. President Obama has asserted that Iran s acquisition of a nuclear arms capacity is unacceptable. The administration and the U.S. Congress, on both sides of the aisle, have demonstrated full recognition that this would pose a grave threat to fundamental U.S. national security interests and to world peace. A nuclear-armed Iran would: Destabilize an already volatile Middle East and stimulate a nuclear arms race in the region; Create a very real risk that nuclear weapons technology might be shared with Al Qaeda, Hezbollah, Hamas and other extremist organizations with a long history of launching devastating terrorist attacks against targets in the United States, Western Europe, the Middle East and South America; Endanger the security of our allies in the region, particularly Israel, which has been threatened by Iranian leaders with annihilation, as well as moderate Sunni Arab nations, which have made their concerns known; and Undermine efforts to achieve Middle East peace, as an emboldened Iran would seek to strengthen rejectionist forces among the Palestinians and the wider Arab world and would make it less likely that moderate Arab regimes would seek to advance reconciliation with Israel. Call to Action Urge the U.S. Administration to lead a concerted and robust international effort, utilizing a combination of strong diplomatic and economic measures, to persuade Tehran to fully cooperate with the International Atomic Energy Agency and to desist from its nuclear weapons initiative. Urge Congress to adopt legislation expeditiously including the Iran Refined Petroleum Sanctions Act (IRPSA was overwhelmingly passed by the U.S. House of Representatives on December 15, 2009) and other related bills and we encourage the administration to take full advantage of these additional tools in order to advance the international effort. There is no way to know for sure when Iran might cross the nuclear arms threshold, but we do know that the time to stop it from happening is rapidly running out. We take very seriously the danger posed by a head of a government who says he wants to destroy Israel and who says the Holocaust did not occur. A government that has so little regard for human life, truth, and human rights as this one must not be entrusted to possess the most powerful weapons in the world.

7 Backgrounder III False Linkage to the Palestinian-Israeli Conflict Prepared by the World Jewish Congress There is no linkage between the Palestinian-Israeli conflict and the Iranian determination to achieve nuclear capability, regional supremacy and Tehran s stated determination to destroy Israel. The Arab Israeli dispute pre-dated the Iranian nuclear crisis, and the conflict will likely continue regardless of what happens on the Iranian issue. The Palestinian Authority continues to categorically refuse to recognize Israel as a Jewish state in any borders today, as the Arab and Palestinian leadership refused in 1947 following the UN Partition Plan, with no consideration of Iran. The Iranian regime s interests and stated declarations have been driven by a religious and ideological commitment to destroy the Jewish state. The Iranian regime rejects the very notion of a U.S.- and Israeli-backed Palestinian state in the West Bank and Gaza and is working through its local proxy terror groups to subvert the West Bank as they did Gaza. Any near-term territorial concessions Israel would be pressured to make in the West Bank would be exploited by Iranian proxies Hamas, Palestinian Islamic Jihad, Al Aksa Martyrs Brigades and cooperative Al Qaeda- inspired cells to transform the area into a second Hamastan as transpired in Gaza when the Israel withdrew its civilians and defense forces in September 2005.

8 Talking Points on Iran Prepared by The Israel Project The world does not have a lot of time to peacefully prevent Iran, the world's largest state sponsor of terror, from getting these weapons. It will take the will of key countries to stop Iran -- but America must lead by example. While the U.S. House of Representatives overwhelmingly passed the Iran Refined Petroleum Sanctions Act (H.R. 2194) recently by a vote of , it still must come to the Senate floor for a vote and be signed into law. Majority Leader Harry Reid has pledged to bring significant sanctions legislation to the Senate floor after the Senate reconvenes on January 20. There is no time to waste. It needs to be passed and put into law now while there is still time to peacefully stop Iran! The biggest stick the international community can wield remains Iran's dependence on imported gasoline. Iran has not developed enough capacity to refine its crude oil into gasoline. By stopping such imports we can help encourage the regime to either change their policies - or for the regime itself to change. In addition to cutting off gasoline sales, the international community, led by the United States, should provide incentives to foreign banks and companies to eliminate investments in Iran's energy sector and firms helping the Iranian Revolutionary Guard. America should do all it can to stop Iran without war - but to do that, the Senate and White House must act now!

9 Legislative Initiatives Prepared by AIPAC and UANI United Nations Since December 2006, the UN Security Council has unanimously passed three resolutions imposing sanctions on Iran. Resolution 1737 imposed sanctions against Iran for failing to stop its uranium enrichment program. It banned the supply of nuclear-related technology and froze the financial assets of key individuals and companies supporting its proliferation of sensitive nuclear activities or the development of nuclear-weapon delivery systems. Resolution 1747 widened the scope of the UN s previous sanctions by banning Iran s arms exports and freezing the assets and restricting the travel of additional individual s engaged in the nuclear program. Resolution 1803 required Iran to cease and desist from any and all uranium enrichment and also required Iran to stop any research and development associated with centrifuges and uranium enrichment. United States Iran Refined Petroleum Sanctions Act (H.R. 2914) The House on Dec. 15 overwhelmingly passed the Iran Refined Petroleum Sanctions Act (IRPSA) by a bipartisan vote of 412 to 12. The legislation, introduced in the House by Committee Chairman Howard Berman (D-CA) and Ranking Member Ileana Ros-Lehtinen (R-FL), would reinforce American diplomatic efforts with Iran with the threat of tougher sanctions if Iran rejects U.S. overtures and continues to enrich uranium in defiance of the international community. The bill is based on previous legislation introduced in 2007 by Reps. Mark Kirk (R-IL) and Robert Andrews (D-NJ). More than three-quarters of the House of Representatives cosponsored the legislation, which aims to reinforce American diplomacy and strengthen global efforts to prevent Iran from acquiring a nuclear weapons capability. The legislation imposes tough sanctions on Iran to persuade Tehran to suspend its uranium enrichment program and seriously engage in negotiations about its nuclear future. IRPSA will increase the pressure on Iranian leaders by restricting their ability to purchase refined petroleum products. Despite being one of the largest producers of crude oil in the world, Iran lacks adequate refining capability to meet its own domestic needs for gasoline, diesel and aviation fuel. Iran is forced to import 25 to 40 percent of its refined petroleum needs. The bill seeks to curtail those imports through the imposition of sanctions on companies providing refined petroleum to Iran or transporting, insuring, or financing refined petroleum deliveries. The legislation also targets companies helping Iran expand its own domestic refining capacity. The bill includes provisions allowing the president to waive the implementation of sanctions if he determines such a move is vital to the national security interests of the United States. During the 2008 presidential campaign, then-senator Barack Obama backed the imposition of restrictions on Iran s ability to purchase refined petroleum products, saying, If we can prevent them from importing the gasoline that they need that starts changing their cost-benefit analysis. That starts putting the squeeze on them.

10 The key provisions of the bill include: Requires the president to impose sanctions on any entity that provides Iran with refined petroleum resources, engages in activity that could contribute to Iran s ability to import such resources, or helps Iran maintain or expand its domestic refining capabilities, including: o Providing ships or shipping services to deliver refined petroleum to Iran o Providing insurance or reinsurance for such activity o Financing or brokering such activity o Providing goods, services, technology, information, or support, or to maintain or expand Iran s refining capacity o The value of such support must exceed $200,000 or a combined total of $500,000 in any 12-month period. Companies found to be in violation will effectively be barred from doing business in the United States by: o Prohibiting the entities from carrying out any financial transactions in U.S. dollars o Barring any U.S. person or financial institution from carrying out any transaction involving a sanctioned entity o Freezing any assets the entities may have under the jurisdiction of the United States o Prohibiting sanctioned entities from receiving U.S. government contracts Requires the president to initiate an investigation of possible sanctions violations upon receipt of credible information that a violation has occurred and to make a determination whether a violation occurred within 180 days of beginning the investigation. Requires the president to report within 90 days and every six months thereafter regarding any person who has: o Provided Iran with refined petroleum or engaged in activity that could contribute to Iran s ability to import refined petroleum resources o Sold, leased, or provided to Iran any goods, services, or technology that would allow Iran to maintain or expand its domestic production of refined petroleum resources o Acted as an agent, alias, front, instrumentality, representative, official, or affiliate of the Islamic Revolutionary Guard Corp o Provided material support or conducted any commercial or financial transactions with the Islamic Revolutionary Guard Corps Restricts U.S. nuclear cooperation agreements with countries whose citizens or companies provide Iran with equipment and materials that help advance its nuclear capabilities. States it is the policy of the United States to impose sanctions on the Central Bank of Iran (CBI), any Iranian financial institution engaged in proliferation or terrorist activities and any entities conducting financial transactions with those institutions. Applies sanctions to the subsidiaries and parent companies of entities found to be violating the Iran Sanctions Act. Extends the Iran Sanctions Act through The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2009 (S. 2799) The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2009 (S. 2799), introduced by Senate Banking Committee Chairman Christopher Dodd (D-CT) and Ranking Member Richard Shelby (R-AL), reinforces American diplomatic efforts with Iran with the threat of tougher

11 sanctions if Tehran rejects U.S. overtures and continues to enrich uranium in defiance of the international community. The bill, passed by the Senate Banking Committee Oct. 29 by a vote of 23 to 0, expands U.S. sanctions against Iran by requiring the president to impose penalties on companies providing refined petroleum to Iran or helping Iran expand its own refining capacity. Shipping companies that transport the refined petroleum to Iran and their insurers are also targeted by the legislation. The Dodd-Shelby legislation is based on S. 908, the Iran Refined Petroleum Sanctions Act, which enjoys broad bipartisan backing and has 76 cosponsors. IRPSA was originally introduced by Sens. Evan Bayh (D- IN) and Jon Kyl (R-AZ). The legislation also includes key elements of S. 1065, the Iran Sanctions Enabling Act, which authorizes state divestment efforts and provides a safe harbor for asset managers. S.1065 was originally introduced by Sens. Robert Casey (D-PA) and Sam Brownback (R-KS) and has 39 cosponsors. The House overwhelmingly passed its version of the bill in a vote of 414 to 6. In addition, the legislation includes provisions aimed at stopping the diversion of sensitive technologies to Iran. The key provisions of the bill include: Requires the president to impose sanctions on any entity that provides Iran with refined petroleum resources, engages in activity that could contribute to Iran s ability to import such resources, or helps Iran to maintain or expand its domestic refining capacity. (The bill includes provisions allowing the president to waive the sanctions if he determines such a move is in the national security interests of the United States.) Bans U.S. government contracts with entities meeting the criteria for sanctions related to the provision of refined petroleum to Iran or entities investing more than $20 million in Iran s energy sector. Authorizes sanctions against companies if their subsidiaries invest in Iran s energy sector or provide Iran refined petroleum resources. Bans U.S. government contracts with entities exporting sensitive technology to Iran meant to be used to restrict the free flow of unbiased information or to disrupt, monitor, or otherwise restrict speech of the people of Iran. Codifies the U.S. import and export ban on goods to and from Iran and freezes the U.S. assets held by certain Iranians. Requires the president to report every six months on certain investments in Iran s energy sector and any activity related to Iran s refined petroleum imports, since January 1, The report also must include the determination of the president as to whether each investment or activity qualifies as a sanctionable offense. Urges the president to consider sanctions on the Central Bank of Iran and any other Iranian bank engaged in proliferation activities or support of terrorist groups. Expresses the sense of Congress that the United States should continue to target Iran s Revolutionary Guard Corps with economic sanctions.

12 Authorizes states divestment efforts and provides a safe harbor for asset managers. Mandates the identification of countries of concern related to the transshipment of sensitive technologies to Iran and provides assistance to these countries to upgrade their export controls. It also subjects countries of concern to additional U.S. licensing requirements for sensitive technologies. Accountability for Business Choices in Iran Act (H.R. 3922) The Accountability for Business Choices in Iran Act (ABC Iran Act) was introduced by Representatives Ron Klein (D-FL) and John Mica (R-FL) in the U.S. House of Representatives on October 22, ABC Iran Act will preclude companies that conduct business in Iran from receiving U.S. federal taxpayer funding such as stimulus spending, bailout support or government contracts. UANI also worked with State Senator Scott Rader (FL-D) to introduce the ABC Iran Act in the Florida House of Representatives.

13 December 2009 Iran Refined Petroleum Sanctions Act of 2009 (H.R. 2194) The House on Dec. 15 overwhelmingly passed the Iran Refined Petroleum Sanctions Act (IRPSA) by a bipartisan vote of 412 to 12. The legislation, introduced in the House by Committee Chairman Howard Berman (D-CA) and Ranking Member Ileana Ros-Lehtinen (R-FL), would reinforce American diplomatic efforts with Iran with the threat of tougher sanctions if Iran rejects U.S. overtures and continues to enrich uranium in defiance of the international community. The bill is based on previous legislation introduced in 2007 by Reps. Mark Kirk (R-IL) and Robert Andrews (D-NJ). More than three-quarters of the House of Representatives cosponsored the legislation, which aims to reinforce American diplomacy and strengthen global efforts to prevent Iran from acquiring a nuclear weapons capability. The legislation imposes tough sanctions on Iran to persuade Tehran to suspend its uranium enrichment program and seriously engage in negotiations about its nuclear future. IRPSA will increase the pressure on Iranian leaders by restricting their ability to purchase refined petroleum products. Despite being one of the largest producers of crude oil in the world, Iran lacks adequate refining capability to meet its own domestic needs for gasoline, diesel and aviation fuel. Iran is forced to import 25 to 40 percent of its refined petroleum needs. The bill seeks to curtail those imports through the imposition of sanctions on companies providing refined petroleum to Iran or transporting, insuring, or financing refined petroleum deliveries. The legislation also targets companies helping Iran expand its own domestic refining capacity. The bill includes provisions allowing the president to waive the implementation of sanctions if he determines such a move is vital to the national security interests of the United States. During the 2008 presidential campaign, then-senator Barack Obama backed the imposition of restrictions on Iran s ability to purchase refined petroleum products, saying, If we can prevent them from importing the gasoline that they need that starts changing their cost-benefit analysis. That starts putting the squeeze on them. Key Provisions: Requires the president to impose sanctions on any entity that provides Iran with refined petroleum resources, engages in activity that could contribute to Iran s ability to import such resources, or helps Iran maintain or expand its domestic refining capabilities, including: o o o Providing ships or shipping services to deliver refined petroleum to Iran Providing insurance or reinsurance for such activity Financing or brokering such activity

14 o o Providing goods, services, technology, information, or support, or to maintain or expand Iran s refining capacity The value of such support must exceed $200,000 or a combined total of $500,000 in any 12-month period. Companies found to be in violation will effectively be barred from doing business in the United States by: o o o o Prohibiting the entities from carrying out any financial transactions in U.S. dollars Barring any U.S. person or financial institution from carrying out any transaction involving a sanctioned entity Freezing any assets the entities may have under the jurisdiction of the United States Prohibiting sanctioned entities from receiving U.S. government contracts Requires the president to initiate an investigation of possible sanctions violations upon receipt of credible information that a violation has occurred and to make a determination whether a violation occurred within 180 days of beginning the investigation. Requires the president to report within 90 days and every six months thereafter regarding any person who has: o o o o Provided Iran with refined petroleum or engaged in activity that could contribute to Iran s ability to import refined petroleum resources Sold, leased, or provided to Iran any goods, services, or technology that would allow Iran to maintain or expand its domestic production of refined petroleum resources Acted as an agent, alias, front, instrumentality, representative, official, or affiliate of the Islamic Revolutionary Guard Corp Provided material support or conducted any commercial or financial transactions with the Islamic Revolutionary Guard Corps, Restricts U.S. nuclear cooperation agreements with countries whose citizens or companies provide Iran with equipment and materials that help advance its nuclear capabilities. States it is the policy of the United States to impose sanctions on the Central Bank of Iran (CBI), any Iranian financial institution engaged in proliferation or terrorist activities and any entities conducting financial transactions with those institutions. Applies sanctions to the subsidiaries and parent companies of entities found to be violating the Iran Sanctions Act. Extends the Iran Sanctions Act through H Street, NW Tel Washington, DC Fax

15 November 2009 The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2009 (S. 2799) The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2009 (S. 2799), introduced by Senate Banking Committee Chairman Christopher Dodd (D-CT) and Ranking Member Richard Shelby (R-AL), reinforces American diplomatic efforts with Iran with the threat of tougher sanctions if Tehran rejects U.S. overtures and continues to enrich uranium in defiance of the international community. The bill, passed by the Senate Banking Committee Oct. 29 by a vote of 23 to 0, expands U.S. sanctions against Iran by requiring the president to impose penalties on companies providing refined petroleum to Iran or helping Iran expand its own refining capacity. Shipping companies that transport the refined petroleum to Iran and their insurers are also targeted by the legislation. The Dodd-Shelby legislation is based on S. 908, the Iran Refined Petroleum Sanctions Act, which enjoys broad bipartisan backing and has 76 cosponsors. IRPSA was originally introduced by Sens. Evan Bayh (D- IN) and Jon Kyl (R-AZ). The legislation also includes key elements of S. 1065, the Iran Sanctions Enabling Act, which authorizes state divestment efforts and provides a safe harbor for asset managers. S.1065 was originally introduced by Sens. Robert Casey (D-PA) and Sam Brownback (R-KS) and has 39 cosponsors. The House overwhelmingly passed its version of the bill in a vote of 414 to 6. In addition, the legislation includes provisions aimed at stopping the diversion of sensitive technologies to Iran. Key Provisions: Requires the president to impose sanctions on any entity that provides Iran with refined petroleum resources, engages in activity that could contribute to Iran s ability to import such resources, or helps Iran to maintain or expand its domestic refining capacity. (The bill includes provisions allowing the president to waive the sanctions if he determines such a move is in the national security interests of the United States.) Bans U.S. government contracts with entities meeting the criteria for sanctions related to the provision of refined petroleum to Iran or entities investing more than $20 million in Iran s energy sector. Authorizes sanctions against companies if their subsidiaries invest in Iran s energy sector or provide Iran refined petroleum resources.

16 Bans U.S. government contracts with entities exporting sensitive technology to Iran meant to be used to restrict the free flow of unbiased information or to disrupt, monitor, or otherwise restrict speech of the people of Iran. Codifies the U.S. import and export ban on goods to and from Iran and freezes the U.S. assets held by certain Iranians. Requires the president to report every six months on certain investments in Iran s energy sector and any activity related to Iran s refined petroleum imports, since January 1, The report also must include the determination of the president as to whether each investment or activity qualifies as a sanctionable offense. Urges the president to consider sanctions on the Central Bank of Iran and any other Iranian bank engaged in proliferation activities or support of terrorist groups. Expresses the sense of Congress that the United States should continue to target Iran s Revolutionary Guard Corps with economic sanctions. Authorizes states divestment efforts and provides a safe harbor for asset managers. Mandates the identification of countries of concern related to the transshipment of sensitive technologies to Iran and provides assistance to these countries to upgrade their export controls. It also subjects countries of concern to additional U.S. licensing requirements for sensitive technologies. 251 H Street, NW Tel Washington, DC Fax

17 Dec. 11, 2009 Continuing Iranian Defiance Demands Crippling Sanctions The United States and its allies should prepare a swift campaign of crippling sanctions in response to Iran s rejection of diplomatic overtures and Tehran s blatant threats to expand its nuclear efforts. The Obama administration is warning Iran that it has until the end of the year to demonstrate its seriousness to end its illicit nuclear pursuit. If Iran refuses, the United States and the international community must quickly move toward an overwhelming sanctions regime to persuade Iran to suspend its nuclear weapons quest. Iran has rejected American and international diplomatic overtures to solve the dispute over its illicit nuclear program. Iran s supreme leader Ayatollah Ali Khamenei has expressed opposition to holding serious negotiations with the United States, saying such a move would be naïve and perverted. Iran announced plans to build 10 uranium enrichment sites throughout the country, a dramatic expansion of its enrichment efforts and a sign of the non-civilian nature of the regime s nuclear program. The United States has one enrichment facility for 65 nuclear power plants; Iran s one nuclear power plant, Bushehr, is not even operational yet. Iran s rejection of the International Atomic Energy Agency (IAEA) proposal, backed by the United Secretary of Defense Robert Gates said he expects new Iran sanctions soon. States, France and Russia, to process for Iranian use a portion of its LEU outside the country demonstrates Iran s unwillingness or inability to conduct serious negotiations. While Iranian negotiators agreed to the proposal in principle, Tehran has rejected the deal and declared it will begin enriching its LEU to levels closer to what is needed for making weapons in direct contravention to U.N. Security Council requirement to suspend all enrichment activity. Iran has continually used talks with the international community to distract attention from the main requirement of the international community the long-overdue suspension of its enrichment of uranium, mandated by five U.N. Security Council resolutions. Top U.S. officials and the IAEA have signaled that Iran is becoming more brazen in its rejection of international cooperation. Iran s illegal actions and its unwillingness to negotiate forthrightly with the international community have pushed the IAEA s Board of Governors, including China and Russia, to issue a rare resolution of censure condemning Iran s lack of cooperation. The Board of Governors demanded that Iran halt construction at its recently revealed military enrichment facility on an Iranian Revolutionary Guard Corps (IRGC) base near Qom and freeze all uranium enrichment.

18 Outgoing IAEA chief Mohamed ElBaradei admitted that the agency has reached a dead end with Iran and said unless Tehran begins to cooperate with the Agency, it would be unable to verify that Iran s nuclear ambitions are peaceful. Secretary of Defense Robert Gates on Dec. 11 said he anticipates significant new sanctions on Iran. I think that you are going to see some significant additional sanctions imposed by the international community, assuming that the Iranians don t change course and agree to do the things they agreed to at the beginning of October, he said. Iran continues to steadily advance its nuclear weapons program. Iranian centrifuges continue to operate at the Natanz enrichment facility and construction of the Arak heavy water reactor is ongoing. Iran has now produced more than 3,300 pounds of low-enriched uranium that if further enriched to a weapons-grade level is nearly enough fuel for two nuclear weapons. If Iran has undisclosed nuclear facilities beyond the recently revealed enrichment facility near Qom, the known amount of Iran s LEU could be significantly augmented. An IAEA inspection of the facility revealed that the site s small size makes it unsuitable for any commercial purpose but is appropriate for the enrichment of uranium for nuclear weapons. Tehran also has made major advances in its medium-range ballistic missile technology, recently test-firing a series of missiles, the most advanced of which represents a technological leap in Iran s ability to target U.S. military bases in the region, European allies and Israel. Iran s rejection of negotiations and continued violation of Security Council resolutions requires the United States to impose crippling new sanctions. Iran s rejection of U.S. and international engagement efforts combined with Tehran s refusal for more than three years to meet the requirements of the U.N. Security Council leave the international community no option but to implement stringent new sanctions on the Iranian regime. While the United States should continue efforts to positively engage Iran in serious, constructive negotiations, Iran s behavior demands the U.S. seek a new resolution in the Security Council to impose additional sanctions on Tehran. Given the protracted nature of Security Council negotiations more than 20 months have passed since the Council last sanctioned Iran and the likelihood new U.N. sanctions alone will not change Iran s calculus, the United States should move quickly to impose its own sanctions. American sanctions must be overwhelming in order to change the dynamic with Iran and alter the thought process of Iranian leaders. The urgency of Iran s advanced nuclear program means that the time for incremental action has passed. A broad U.S. sanctions campaign should target the leadership of the Iranian regime with travel bans, assets freezes, and additional sanctions on IRGC-related entities. The Iranian financial sector, as well as its insurance, shipping, transportation and manufacturing industries should all be subject to harsh new penalties. Passage by Congress of legislation that sanctions the sale and export to Iran of refined petroleum products and other similar legislation is critical. With Iran forced to import up to 40 percent of its gasoline and diesel, limiting the country s access to such products would have a dramatic economic effect and could force the regime to change course. 251 H Street, NW Tel Washington, DC Fax

19 December 2009 The Iran Refined Petroleum Sanctions Act As Iran continues to defy international demands to suspend its nuclear program and refuses to hold serious negotiations with the international community, dramatic new sanctions will be needed to press Tehran to suspend its illicit enrichment of uranium. The Iran Refined Petroleum Sanctions Act (H.R in the House and incorporated into the Senate s S. 2799, the Comprehensive Iran Sanctions, Accountability and Divestment Act) seeks to increase pressure on Iran by limiting Tehran s ability to import and produce refined petroleum products such as gasoline and diesel fuel. With Iran continuing to advance its nuclear program, it must be presented with a clear and stark choice: suspend your nuclear program or face crippling sanctions. Q: What is the Iran Refined Petroleum Sanctions Act? A: The Iran Refined Petroleum Sanctions Act is an effort to reinforce American and international diplomacy by imposing tough sanctions on Iran to persuade the regime to suspend its nuclear program and seriously engage in negotiations with world powers. IRPSA will increase the pressure on Iranian leaders by restricting their ability to purchase refined petroleum products. Despite being one of the largest producers of crude oil in the world, Iran lacks adequate refining capability to meet its own domestic needs for gasoline, diesel and aviation fuel. Iran is forced to import 25 to 40 percent of its refined petroleum needs. The bill would restrict Iran s ability to purchase refined petroleum products that are critical for its production of oil and transportation. The bill seeks to curtail those imports through the imposition of sanctions on companies providing refined petroleum to Iran or transporting, insuring, or financing refined petroleum deliveries. The legislation also targets companies helping Iran expand its own domestic refining capacity. The bill includes provisions allowing the president to waive the implementation of sanctions if he determines such a move is vital to the national security interests of the United States. Q: Does the legislation punish close American allies? A: The leaders of our major allies, including France, Britain, and Germany, have all recently spoken of the need for much tougher sanctions if engagement does not succeed. On August 21, 2009, British Prime Minister Gordon Brown stated, If there is no further progress immediately, then I believe the

20 world will have to look at stepping up sanctions against Iran as a matter of priority. On the same day, German Chancellor Angela Merkel said, If Iran got atomic weapons it would [be] a dangerous situation. That is why sanctions would be justified. French President Nicolas Sarkozy echoed these sentiments, saying Aug. 26 that he would press for tougher sanctions on Iran if the Islamic Republic refuses to halt its illicit nuclear work. "It is the same leaders in Iran who say that the nuclear program is peaceful and that the elections were honest. Who can believe them?" Sarkozy said. U.S. diplomacy is aimed at imposing such sanctions with the multilateral cooperation of our allies. The sanctions in the legislation would be imposed only if current diplomatic efforts fail and foreign companies continue to provide refined petroleum to Iran. Iran poses a strategic threat not only to the United States, but to Europe and the entire world as well. With Iran continuing to defy the international community, the Europeans should continue to step up their own efforts to put economic pressure on Iran. Many European nations have already begun to cut their investments in Iran and limit their trade. Scores of European and international banks, unwilling to risk heavy fines and the possible loss of access to U.S. financial markets, have ceased or limited transactions with Iran. Past U.S. sanctions legislation has been managed by the executive branch to avoid alienating our European allies, and the current legislation provides the president with the flexibility he would require. Q. Won t additional sanctions hurt the average Iranian person? A. The average Iranian is already suffering under the corrupt and repressive clerical regime. Inflation is officially around 20 percent but is actually much higher. Unemployment and underemployment may be as high as 50 percent. Iran s petroleum and natural gas sector, which accounts for 80 percent of its hard currency earnings, is entirely state-owned and benefits primarily the elite within the clerical regime. While curtailing Iran s ability to purchase refined petroleum would impact the entire Iranian economy, it would fall most heavily on the regime elites who can afford to own and operate cars. In any event, the goal of enhanced sanctions against Iran is not to inflict long-term economic hardships on the Iranian people, but to quickly jolt the regime into meeting its obligations. Q. Won t new sanctions cause the Iranian people to rally around the regime? A. The current regime in Iran has long blamed its internal problems on outside interference from the West. There is no doubt the regime will continue to do so regardless of whether sanctions are increased or decreased. However, the people of Iran have largely ignored this argument. Attempts to blame the upheaval resulting from the Iranian presidential election on Western interference fell on deaf ears as protests continue. Opposition leaders have blamed Iran s current isolation and economic difficulties on their own leadership s ineptitude. The Iranian people, moreover, are well aware of the corruption that exists among the ruling clerics. In fact, the people of Iran especially in light of the brutal crackdown are more likely to oppose the regime, not rally around it, because they know the actions of the regime have led to Iran s isolation. The goal of the sanctions is not to hurt the Iranian people but to force the regime to decide between providing a better life for its people or continuing with its illicit nuclear weapons pursuit. Q. Why is it so important for the United States to increase sanctions on Iran now as the regime is in turmoil? A. Time is of the essence to stop Iran from acquiring a nuclear weapons capability. The world cannot wait for the political situation in Iran to unfold before dealing with the threat of a nuclear-armed Iran. Given the protracted nature of Security Council negotiations more than 20 months have passed since the Council last sanctioned Iran and the likelihood new U.N. sanctions alone will not change Iran s calculus, the United States must move quickly to impose its own sanctions.

21 Overwhelming American sanctions such as those in the Iran Refined Petroleum Sanctions Act have the potential to change the dynamic within Iran and alter the thought process of Iranian leaders. The urgency of Iran s advanced nuclear program means that the time for incremental action has passed. Deferring efforts to address the threat of a nuclear-armed Iran will only allow Iran to achieve increased capabilities, making a successful resolution of the nuclear issue that much harder. Nobody knows how long it will take for the political situation in Iran to reach a resolution. The present regime could stay in power for another six months, a year, or indefinitely, allowing it to reach its goal of a nuclear weapons capability. There is no guarantee if a new regime comes to power it will end Iran s nuclear program. A crippling sanctions regime would force Iran s leaders to confront a real choice: continue the nuclear program or face the collapse of Iran s economy and possibly the loss of their own power. Q. Iran has undertaken a massive campaign to upgrade its domestic refining capacity. Doesn t this render gasoline sanctions obsolete? A. It is true that Iran has undertaken an intensive campaign to upgrade its domestic refining capacity to eliminate the vulnerability it faces from sanctions targeting refined petroleum imports. However, this campaign, which is several years old, has yet to significantly increase Iran s gasoline production and it is questionable if it ever will. Current refinery projects are years behind schedule and will take several more years to complete. Further, despite rationing gasoline, Iran is expected to see a two to six percent annual increase in gasoline demand for the foreseeable future, making even more new refining capacity necessary. The Iran Refined Petroleum Sanctions Act specifically targets Iran s domestic refining capabilities by imposing sanctions on any company that helps Iran maintain or expand its refining capacity. Much of the technology needed to upgrade and expand Iran s refineries comes from Western companies that are unlikely to continue their activity in Iran when faced with the potential loss of access to the U.S. market. While China has announced plans to invest in Iran s refinery sector, it is unlikely to greatly affect Iran s gasoline production levels since China has limited technical and operational capability to carry out such a major program. The bill also targets any bank or financial institution providing credit or financing for any refinery project or the export of material for such refineries, thus reducing the likelihood of significant refining expansion. Finally, even if Iran succeeds in expanding its domestic refining capacity to meet its internal needs, it will take years, while the sanctions would have an immediate impact. The mere talk of sanctions has already forced Iran to spend billions of dollars attempting to expand domestic production. Q. Won t Russia and China supply Iran with refined petroleum if the U.S imposes sanctions? A. While the support of China and Russia for increased sanctions is preferable, it is not needed to successfully limit Iran s ability to import refined petroleum. No Security Council resolution is needed to carry out sanctions, as the initiative seeks to leverage private market forces to force companies to choose between doing business with the United States or with Iran. Neither Russia nor China has the spare capacity of refined petroleum to completely make up for the loss of other international suppliers. Further, those Chinese and Russian companies that would supply Iran also have significant U.S. exposure opening them to significant losses if sanctioned. If Tehran were able to acquire some refined petroleum abroad, it is likely to be at substantially increased cost as Iran will be forced to carry out much of the importation itself using its own ships and providing its own insurance. If foreign companies are willing to help Iran, they will likely charge increased rates to sell, ship and insure the petroleum to compensate for the increased risk they face.

22 And the regime will be forced to further reduce already rationed gasoline supplies, risking the ire of its citizens. Q. Does it make sense to sanction gasoline imports since Iran spends so much money subsidizing the sale of imported gasoline? A. Any savings Iran achieves by not having to import refined petroleum will be lost by the resulting drop in the amount of oil available for export. Iran s subsidization of gasoline prices is a huge burden on the regime that only increases as it produces more domestically. The revenue lost by Iran due to the sale of subsidized gasoline during was nearly $32 billion, or 11.2 percent of Gross Domestic Product (GDP). If Iran produced 100 percent of its gasoline domestically and sold that gasoline at subsidized prices, it would cost the regime more than 18 percent of its GDP a higher percentage of GDP than the United States spends on health care in a year. Further, if Iran succeeds in expanding its domestic refining capacity to meet its internal needs, it will have done so only after expending a massive amount of capital. The mere talk of sanctions has already forced Iran to spend billions of dollars in an attempt to expand domestic production with little correlating decrease in refined petroleum imports. Q: Couldn t Iran just end gasoline subsidies and blame the decision on the United States? A. The Iranian public views access to cheap gasoline as its natural right given Iran s vast energy resources. If confronted with the loss of gasoline imports, the Iranian regime may attempt to further ration gasoline or reduce demand by raising the price of gasoline, or both. However, any such moves would likely be met with broad public protests and riots, as was the case in 2007 when the Iranian regime last tried to impose gasoline rationing. In that instance, dozens of gas stations were set on fire and the regime was forced to increase the amount of gasoline provided at subsidized rates. An unpopular regime already facing mass protests over the disputed presidential election would be unlikely to take such a dramatic move to further stoke dissent. Q: What is the administration s view on the legislation? A. While the administration has not commented specifically on the Iran Refined Petroleum Sanctions Act, it has highlighted the need for additional pressures on Iran. In response to Iran s rejection of an international proposal to send a portion of its LEU abroad for processing and Iran s continuing refusal to suspend its nuclear program, President Obama said there would need to be consequences. We have begun discussions with our international partners about the importance of having consequences, the president said. During the 2008 presidential campaign, then-senator Barack Obama specifically highlighted the potential of sanctions on Iran s refined petroleum imports, saying, If we can prevent them from importing the gasoline that they need that starts changing their cost-benefit analysis. That starts putting the squeeze on them. 251 H Street, NW Tel Washington, DC Fax

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