by Esfandyar Batmanghelidj

On Tuesday, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Valiollah Seif, governor of the Central Bank of Iran (CBI) as a “Specially Designated Global Terrorist,” accusing him of moving “ millions of dollars on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hezbollah.” OFAC’s move opened a new front in the Trump administration’s accelerating conflict with Iran. The designation of a single individual, even the central bank governor, may not seem that significant. After all, Trump announced last week that he would reimpose all primary and secondary sanctions lifted as part of the Joint Comprehensive Plan of Action (JCPOA) as part of withdrawing from the nuclear deal. But targeting Seif may prove to be the pivotal moment in an economic war.

Iranian financial institutions have long been designated for suspected terrorist financing, and the Obama administration used such measures to isolate Iran’s economy in the effort to bring Iran to the negotiating table over its nuclear program. But the move to target Seif as an individual represents a significant escalation for two reasons. First, it reflects the direct targeting of a member of the Hassan Rouhani administration in a clear role of civilian leadership. Seif is not a rogue actor. He is a public figure, who travels regularly to Europe to engage in technical dialogue. Just recently, he welcomed Swedish central bank governor Stefan Ingves to Tehran. Seif also travels to the United States when invited for meetings at the International Monetary Fund and World Bank.

Moreover, Iran’s central bank is at the heart of an expansive effort to reform the country’s anti-money laundering (AML) and counter-terrorist financing (CTF) standards. Iran’s parliamentary research center recently concluded in a comprehensive report that “a considerable portion of the problems in Iranian banks’ correspondent relations with global counterparts is rooted in non-sanction reasons” including poor AML/CTF standards. Seif has been a central figure in the effort to improve these standards. Politically speaking, OFAC’s action could not be more different from the routine targeting of Iran’s military brass.

Second, the move represents an escalation because of who was likely behind it. It had long been assumed that OFAC was relatively immune to the more irascible political impulses in Washington. The application of sanctions was informed first and foremost by the need for restraint. As noted by former Treasury Secretary Jack Lew in a 2016 speech, OFAC was expected to “guard against the impulse to reach for sanctions too lightly or in situations where they will have negligible impact.” Lew advised his colleagues to be “be conscious of the risk that overuse of sanctions could undermine [America’s] leadership position within the global economy, and the effectiveness of [American] sanctions themselves.”

The Strategy of Economic Warfare

Neither Trump nor his close advisors are averse to undermining America’s leadership position in the world. The decision to sanction Seif under a terror designation carries the hallmarks of the Foundation for Defense of Democracies (FDD). A 2016 policy brief by FDD’s Mark Dubowitz and Annie Fixler, written on the occasion of Seif’s visit to Washington for meetings at the IMF, identifies the central bank governor as “no stranger to illicit finance” and claims that CBI “stands out for its long rap sheet of financial crimes.” More recently, Richard Goldberg and Saeed Ghasseminejad argued that “the White House should re-impose sanctions on the Central Bank of Iran” in order to push Iran’s currency into a “freefall” and precipitate a deeper economic crisis. This later piece makes it especially clear that FDD is not interested in the application of sanctions to achieve economic coercion. It seeks economic destruction.

As a strategy to confront Iran, economic warfare has clear advantages for the White House. The strategy allows Trump to continue to claim to be a non-interventionist and does not require him to send American troops to die in another quagmire. Economic warfare also allows avowed interventionists such as National Security Advisor John Bolton to pursue their destructive ends without the disapprobation following their support of the Iraq War. By trying to force Iran to collapse from within, by goading the Iranian people to tear down their own state, and by portraying that process as a popular revolution, Bolton can achieve his messianic goal without the high risk of blowback that would certainly face this chaotic administration from a military conflict.

Acknowledging that the Trump administration is adopting a strategy of economic warfare towards Iran means recognizing that the long-held distinction between economic concerns and security concerns vis-a-vis Iran are collapsing. In recent months, European and Iranian officials have made an effort to clarify that the JCPOA is “not an economic deal” but “a very important deal in the field of the non-proliferation regime.” In this formulation, the economic component of the deal is only valuable insofar as it serves a security goal. But Trump’s move to reapply sanctions on Iran—despite the country’s compliance with its commitments under the deal and with the clear purpose of fomenting instability in Iran—transforms the effort to save the JCPOA into an effort to shield Iran from an unjust economic war.

Europe’s Response

Seeing the economic threat to Iran as a security threat should have a significant bearing on how Europe responds to Trump’s provocations. In its recent formulation of a diplomatic strategy to save the JCPOA, Europe is seeking to preserve the economic benefits of the nuclear deal to incentivize Iran’s continued commitment to its non-proliferation commitments. But in the aftermath of the U.S. snapback of sanctions, and the likely escalation of those sanctions beyond levels previously seen, the imperative must be to insulate Iran’s economy and the Iranian people. The U.S. is seeking to instigate instability by putting pressure on the Iranian people, who know all too well the pain of shortages in foodstuffs and medicines that sanctions portend.

Iran will likely be able to prevent internal instability, but doing so will entail securitizing larger parts of the economy and society as was the case during the Mahmoud Ahmadinejad administration. In such a scenario, the ascendency of the IRGC will risk regional conflict by exacerbating the security dilemma with Saudi Arabia and Israel. Europe must recognize that a strong Iranian economy is fundamental to both internal and regional security, especially in the face of sustained pressure from the United States.

On Tuesday, French officials convened a briefing for French business on possible responses to Trump’s reimposition of secondary sanctions. French Minister of Economy Bruno Le Maire reportedly cited Thucydides’s observation that “money is the nerve of war” to describe what is at stake. Later that day, reports emerged that the foreign ministers’ meeting among the EU, France, Germany, the UK, and Iran focused on a “nine-point plan” devoted to “maintaining economic ties with Iran, continuing Iran’s ability to sell oil and gas products and protecting EU companies doing business in Iran.”

The limits of European independence in international relations and tradecraft have been exposed by the break with the United States over Iran. As described by Siemens CEO Joe Kaeser in a recent interview, the corporation’s decision to wind down operations in Iran is a reflection of the “primacy of [the American] political system. If that primacy says ‘this is what we’re going to do’, then that is exactly what we’re going to do.” As in the case of the primacy of American military might, Europe long relied on the primacy of U.S. sanctions enforcement, grafted as it were onto the primacy of the U.S. financial system, in order to lend power to the once cohesive foreign policy of the transatlantic partnership. Now, the primacy of the U.S. system is a liability for Europe and a threat to Iran.