This is an open access article distributed under the Creative Commons Attribution Licensewhich permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited. Abstract Bank branches have a vital role in the economy of all countries. They collect assets from various sources and put them in the hand of those sectors that need liquidity. Therefore, in this study, the factors affecting performance efficiency in the areas of management, personnel, finance, and customers were segmented and obtained results were ranked using both methods of Data Envelopment Analysis and hierarchical analysis.
Barring any additional actions by policymakers, this paper argues that the United States has unwound sanctions based on legal distinctions that make it unlikely that it can achieve these goals.
The paper concludes by sketching possible solutions for U. Unlike prior instances in which the United States has unwound large-scale sanctions regimes, the United States only committed to lift a limited set of sanctions and pledged to enforce the vast complex of Iran sanctions not within the scope of the JCPOA.
While many have analyzed the impact of the deal on the Iran sanctions regime, few have even touched on the question. Barring any additional actions by policymakers, this paper argues that the United States has unwound sanctions on the basis of legal distinctions that make it highly difficult for it to simultaneously provide Iran the economic relief it expects under the JCPOA while leaving the rest of the U.
Future targets of sanctions may differ from Iran in substantial ways, but insofar as future adversaries pose a multiplicity of threats and policymakers intend to deploy sanctions to counter those threats, policymakers will have to be able to effectively disentangle sanctions that address issues that have been worked out without undermining the rest of the sanctions architecture.
Section I provides an overview of the U. Section II examines how each of these distinctions problematize the process of unwinding sanctions. In doing so, the JCPOA gives rise to two alternative, but equally problematic outcomes— 1 one in which these measures continue to dissuade foreign companies from engaging in business in Iran, thereby eliminating the possibility of meaningful economic relief for Iran, and 2 another where non-U.
In addition, the distinction between nuclear and non-nuclear sanctions falls short as an organizing principle for lifting sanctions. Among the legal authorities under which the U.
As a result, the United States provides sanctions relief that is inherently over inclusive. Section III discusses the path forward. In the short- to medium-term, this section argues that the United States should propose a financial remediation program whereby Iranian banks are given the opportunity to verifiably demonstrate the integrity of their businesses through a system of international inspections.
Iran, not the United States, must assume the burden of proof. This section also discusses what the JCPOA can teach policymakers about devising sanctions regimes that are easier to unwind on a piecemeal basis.
As a starting point, policymakers can rationalize sanctions by predicating them in terms of precisely defined policy grounds that focus on specific categories of business activity.
Legal Background The United States government has sanctioned Iran primarily through three legal mechanisms—congressional statutes, executive orders, and OFAC regulations and designations. To permanently unwind these sanctions, Congress must generally take affirmative action.
In most cases, this administrative and enforcement authority has been delegated to the Secretary of the Treasury, acting in consultation with the Secretary of State and other specified cabinet officials. The SDN list also serves as notice to U. Violations can result in both civil and criminal penalties.
Unlike statutory sanctions, the President can usually unilaterally revoke, modify, or supersede his own executive orders or those issued by a predecessor at any time and without explanation.
For instance, Congress can codify sanctions previously imposed under executive orders and attach waiver conditions. In addition, to the extent that the President has issued executive orders to implement sanctions mandated by statutes specifically targeting Iran, any actions by the President to cease applying those sanctions including altering executive orders will have to comply with waiver conditions delineated by the underlying statutes.
This same hurdle is absent in cases where the President has imposed sanctions exclusively under the authority of IEEPA and NEA as both statutes empower the President to revoke or modify executive orders based on their authority. First, the Secretary of State, pursuant to his authorities and responsibilities under Section 6 j of the Export Administration Act ofhas designated Iran as a state sponsor of acts of international terrorism.
Based off of this designation, various statutes prohibit foreign aid, financing, and trade to Iran. Evolution of the Iran Sanctions Regime How these various sanctions against Iran relate to one another can be best understood in light of the context in which they were imposed. A year later, President Clinton further ratcheted up sanctions, barring all trade and investment with Iran under Executive Orders, and Starting inTreasury officials directly reached out to banks across the world in a concerted effort to persuade them to cut off ties with Iranian banks.
Finally, in Novemberthe Treasury Department revoked authorization for U-turn transfers involving Iran. With this authority, U. The Treasury Department stepped up its financial campaign against Iran, designating additional Iranian banks in Congress also played a more active role.
From toCongress passed four statutes mandating the imposition of sanctions against Iran and entities transacting with Iran, which the President implemented in a series of Executive Orders.Iran’s Dirty Banking: How the Islamic Republic Skirts International Financial Sanctions By Avi Jorisch INTRODUCTION Emirates NBD Bank PJSC U.S.
BANKS CONDUCTING BUSINESS WITH INTERNATIONAL BANKS THAT SERVICE DESIGNATED IRANIAN BANKS 1. Bank of America NA 2. Business intelligence in banking is a complex and robust pipeline that incorporates a variety of tools.
Find out what goes into a BI solution for a bank. Studies in Computational Intelligence , Springer , ISBN view. electronic edition via DOI Business Intelligence System in Banking Industry Case Study of Samam Bank of Iran.
view. electronic edition via DOI. export record. BibTeX; Bridging the Gap between System-Level and Component-Level Development. Terminal review for implementation of new shared banking system The Hokuriku Bank, Ltd., a member of Hokuhoku Financial Group, Inc.
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