Suggested Questions for CFR Event Featuring Central Bank Governor of Iran

April 14, 2016 Phone: (212) 922-0063 press@uani.com Suggested Questions for CFR Event Featuring Central Bank Governor of Iran On Friday, April 15 at 8:30 a.m. ET, the Council on Foreign Relations (CFR) will be hosting an event featuring Valiollah Seif, the Governor of the Central Bank of Iran. Mr. Seif is currently in Washington, D.C., to attend meetings of the International Monetary Fund (IMF) and World Bank. United Against Nuclear Iran (UANI) is today releasing a list of suggested questions to assist event attendees probe the integrity of the Iranian financial system and the myriad risks of doing business in the country. Sanctions and Banking Risks Certain sanctions have been lifted as part of the JCPOA. Iran is now reportedly seeking access to the U.S. financial system, which amounts to a form of additional sanctions relief. Where specifically does the JCPOA state that the U.S. is obligated to provide Iran the ability to dollarize transactions, thereby giving Iran access to the U.S. financial system?   What additional concessions is Iran prepared to provide in exchange for access to the U.S. financial system - a form of sanctions relief not specifically provided for under the JCPOA?   As you know, since the signing of the JCPOA Iran has engaged in provocative and repressive behavior which clearly intensifies the environment of risk - financial, legal, and reputational - for international companies considering doing business in Iran. For example: unprecedented execution levels, arbitrary arrest and detention of foreign nationals, intensified intervention in Syria, and test-firing long-range ballistic missiles inscribed with threats that "Israel must be wiped out." What would you say to compliance officers or Western firms given the clear existing risks surrounding Iran business?   President Obama recently affirmed that U.S. dollar transactions involving Iranian entities would remain absolutely prohibited, even as an intermediary step. How will it be possible for any Western company to guarantee they will structure their transactions so as to entirely avoid dollarization given the greenback's ubiquity?   On January 19, you were quoted in the Financial Times describing the country's banking system as "outdated" and saying banks must be brought in line with Basel III requirements. Given that the anti-money laundering and terror-finance watchdog, the Financial Action Task Force (FATF), recently declared that it "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," how do you plan on modernizing the Iranian banking sector, in light of your country's history of deceptive conduct to facilitate support for terrorism and pursuit of nuclear and ballistic missile capabilities?   At the recent Financial Times Iran Summit in London, FT journalist and panel moderator David Gardner cited the inherent "difficulty of an organization like the IRGC and their involvement in the banking system." How can any Western firm hope to guarantee the bona fides of any Iranian co-party in view of - in Mr. Gardner's words - the "tentacular reach" of the still-blacklisted IRGC?   International and Swiss media have reported that Swiss banks and commodity traders, which have historically been quite permissive in who they do business with, are shunning Iran. How can Iran overcome its continuing pariah-like status in the global financial system? Country Risk & Corruption   Transparency International has ranked Iran 130 out of 167 in its corruption perceptions index of 2015. Nevertheless, President Rouhani has said that "we have to eliminate the consolidation of power. With the consolidation of power in one institutions, corruption is created... If the guns, the money, the newspapers... are gathered in one place, there will be corruption." To assure the international business community, will the Rouhani Administration push to hold the IRGC accountable as it relates to corruption through its vast network of front companies?   Iran ranks 118th of 189 countries in the World Bank's ease of doing business index, and the Iranian government has been faulted for its "bureaucracy, slow public services, and taxation." Why should companies seek to do business in Iran when these have been long-term problems under the current system of government?    Given Iran's poor human rights situation and governance, it is not surprising that Iranian expatriates are reticent to return or travel to Iran for work - despite lucrative executive job offers from Western firms. A Reuters report notes "problems such as red tape, a murky business culture, security issues, pollution and a lack of international schools for their children." What message would you send to Iranian expats? Economic Policies of the Iranian Government   On November 18, 2015, you said that Iran plans to unify the rial's official exchange rate and unregulated open market rate a "maximum six months after" the implementation of the JCPOA. Are you still on schedule to achieve that objective? What explains the continued poor performance of the rial in the aftermath of the JCPOA? Does this speak to the more fundamental weaknesses in the Iranian economy beyond the limitations of sanctions?   This week, your government's "lame-duck Parliament approved a bill... canceling cash subsidies to 24 million Iranians," which according to the New York Times, "anger[ed] the government of President Hassan Rouhani" to which you belong. At the same time though, such moves accord with recommendations from groups like the International Monetary Fund which have counseled Iran to reduce these cash payments to reduce the Iranian economy's deficit. As the Central Bank Governor, where do you stand on this matter?   Last month, the Majlis and the Guardian Council passed a new AML/CFT law aimed at combating financing for terrorism. Does this mean that Iran will cease its support for Hezbollah, Hamas, and Islamic Jihad? United Against Nuclear Iran (UANI) is a program of the American Coalition Against Nuclear Iran, Inc., a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code.

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