By Tyler Cullis
In July 2019, Brian Hook—the U.S. Special Representative on Iran—released a video addressing the purported “myth” that the U.S. sanctions humanitarian trade with Iran. That wasn’t a “myth” at the time, as the U.S. had historically circumscribed how humanitarian trade with Iran may take place. But now more recent events indicate that sanctioning humanitarian trade is not only a reality but increasingly appears to be a hallmark feature of current U.S. sanctions policy towards Iran.
Last week, the Trump administration designated the Central Bank of Iran as a Specially Designated Global Terrorist for allegedly providing financial support to the Islamic Revolutionary Guard Corps-Quds Force and Hezbollah. This action followed Trump’s promise to “substantially increase” sanctions on Iran in response to Tehran’s purported involvement in the Saudi oil facilities attack.
The consequences could be devastating. Iran’s central bank is critical to facilitating payment for medicine and agricultural commodities being imported into Iran. It allocates the limited foreign reserves at Iran’s disposal—itself a consequence of the U.S.’s imposition of sanctions on almost all of Iran’s productive sectors, including its oil sector—to those Iranian banks involved in the humanitarian trade. Absent this allocation, Iranian importers do not have the required hard currency to make payment for the humanitarian goods.