In an interview with BBC Persian, Treasury Undersecretary for Terrorism and Financial Intelligence David Cohen says that his department’s assessment is that reports published regarding serious and extensive shortages of medicine in Iran are exaggerated. He thinks the government of Iran is trying to portray a manageable problem as bigger than it really is (I am not using direct quotes because I suspect that the original interview was conducted in English and I only have access to the Persian version).

Journalist Mohammad Manzarpour should be given kudos for not allowing Cohen to get away with this rather careless comment. Stepping away from the question of exactly how an official of the US Treasury Department — or anyone else for that matter — is able to make an accurate assessment of conditions on the ground in Iran without sufficient data, Manzarpour shifts the conversation to reports from family members in Western Europe and the US who have been asked to send medicine to Iran for serious illnesses such as cancer, and the fact that due to financial sanctions, even Iran’s private sector has had a difficult time getting letters of credit for importing medicine or ingredients for the production of medicine inside Iran. According to another report by BBC Persian, Iran’s purchase of medicine from Europe has dropped by 30 percent in the past 5 months. Furthermore, despite the issuance of licenses by the Office of Foreign Assets Control (OFAC) for exporting medicine to Iran, banks continue to refuse transactions. (Eric Ferrari, a Washington-based sanctions attorney, describes the Treasury department’s licenses regarding food and medicine as essentially useless).

Manzarpour’s questioning forces Cohen to acknowledge that Iranian imports of medicine may have been reduced. Channels may have narrowed in comparison to 5 years ago, Cohen states, but there are still reliable channels for the import of food, medicine, and medical equipment.

So sanctions have not stopped the export of medicine to Iran; they have just made it more difficult. And according to Cohen, this situation can be resolved when the Iranian leadership responds to demands to stop its nuclear program, which would result in the removal of sanctions. He wants the BBC Persian’s audience to understand that the objective of sanctions is not the sanctions themselves; sanctions exist because of the Iranian government’s decisions.

How is this not collective punishment? Isn’t Cohen saying that so long as the nuclear issue is not resolved, at least some Iranian patients may not get their medicine and that this is okay for him?

By this time, an irritated Cohen realizes that he has been caught. No, he’s not saying that the US is indifferent to the negative side-effects of sanctions on people who had no role in the making of Iran’s nuclear program; sanctions have not been designed to harm people; the Treasury Department is in contact with financial institutions everyday so that they understand the boundaries of sanctions and know what is allowed and what is not; and we will continue our talks with suppliers of food, medicine, and medical equipment as well as with financial institutions…

Cohen is not responsible for the US’ sanctions policy even if as a political appointee he does have some control over the zeal with which his office implements the sanctions regime. But his statement of care for the plight of the Iranian people shows quite a bit of cluelessness — real or feigned — about how sanctions, irrespective of where and on whom they are imposed, work. There is no way that sanctions which are imposed on a country’s financial system and Central bank can be described as not designed to harm people. The Treasury Department’s efforts to get around the blunt and ferocious effects of the sanctions regime may be laudable, but none of these efforts address the costs imposed on the Iranian economy as a whole, even if these so-called manageable problems had a more competent government in charge to deal with them. Consider, for example, that although the export of food and medicine to Iran is not banned, at minimum, financial sanctions still increase the cost of importing goods to Iran, which results in higher prices for consumers.

And what of the charge that it’s the government of Iran that’s either not managing problems resulting from sanctions properly or is intentionally not distributing goods in ways that take care of the needs of the Iranian population? Of course these charges are correct. The Iranian government is responsible both for its refusal to back down on its nuclear program as well as its incompetent and/or horrid distribution of resources. Indeed, many of us who have opposed sanctions do so precisely because we look at the sanctions regime as a US policy that is mediated by the Iranian government and other powerful networks that have a vested interest and the means to transfer the costs of sanctions to the less powerful.

Powerful economic and political networks anywhere in the world reshape policy — even those that are directly intended to harm or constrict them — all the time by transferring the costs to others. This is especially the case when authorities issuing the policy have no way of assuring that the costs are not transferred (through the use of direct punishment, for instance). So, David Cohen’s pronouncements that sanctions are not intended to harm the Iranian people or prevent their access to medicine or other necessary goods, as well as his office’s earnest efforts to get around the side effects of the same sanctions that they rather zealously work to implement, are a bit disingenuous, to say the least.