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letter to Clinton RE Iran sanctions

20110310 letter to Clinton RE Iran sanctions

Dear Secretary Clinton:
tlnitrd ~tatrs ~rnatr
March 10,2011
You have frequently cited the progress oflran’s nuclear weapons program, despite the
Administration’s leading efforts to fashion multilateral and unilateral sanctions against Iran. We
support the Administration’s efforts, but we believe that there is still much more that must be
done to prevent Iran from obtaining a nuclear weapons capability. We want to assure you of
broad, bipartisan support in Congress for use of the full measure of U.S. economic, diplomatic,
and political power to thwart Iranian nuclear ambitions.
On September 29,2010, Deputy Secretary Steinberg announced the State Department’s
initiation of investigations into international firms that had not yet committed to exit Iran’s
petroleum sector. We understand that the State Department is continuing these investigations.
As you know, the Comprehensive Iran Sanctions and Divestment Act (CISADA) provides the
State Department with 180 days to complete its investigation and make a determination as to
whether sanctions are warranted. We look forward to your notification of these determinations
by March 29,2011.
Numerous open sources, including reports by the Congressional Research Service and the
Government Accountability Office, have detailed foreign investment and other activity that
violates u.S. sanctions laws. We therefore also seek an update on the status of all investigations,
as well as those transactions the Department is looking into but has not yet initiated an
investigation, concerning violations of the Iran Sanctions Act (ISA) as amended by CISADA.
Based on publicly available information, we would hope that your update will include the
following entities, which appear to be in violation of our law:
1) The Chinese National Offshore Oil Company, which is aiding Iran in the development of
Iran’s North Pars field.
2) The Chinese National Petroleum Company, which is aiding Iran in the development of
the North Azadegan and South Pars fields.

3) Sinopec, which is aiding Iran’s refinery capacity at Bandar Abbas and the Arak refinery
near Markazi. .
4) The German company ABB Lumus, which has signed a contract to expand the Abadan
refinery with the U.S-sanctioned National Iranian Oil Company.
5) Entities reportedly selling refined petroleum to Iran, including: Zhuhai Zhen Rong of
China, the PDVSA trading unit of Venezuela, Turpas of Turkey, and Unipec of China.
6) The Industrial Bank of China, the China Construction Bank, the Agricultural Bank of
China and the Bank of China, all of which are reportedly aiding Iran by providing
financial services in violation of Section 104 of CISAD A.
It appears that Chinese firms in the energy and banking sectors have conducted
significant activity in violation of U.S. law. We CaIUlot afford to create the impression that
China will be given free rein to conduct economic activity in Iran when more responsible nations
have chosen to follow the course we have asked of them. We are sure you agree.
We would also like to know whether the Department has developed standard criteria to
determine when it would be appropriate to use the “necessary to the national interest” waiver and
whether the Department is considering such a waiver in any pending investigation should the
party not discontinue prohibited activities. Additionally, what guidance has the Department
promulgated concerning when it has received “credible information” to launch an investigation?
We request you make available to us the clear guidelines you have set for the Department.
The most recent International Atomic Energy Agency report on Iran’s ongoing
weaponization activities makes clear that we must decisively utilize tougher economic, political,
and diplomatic measures in the limited time we may have left to thwart Iran’s efforts to acquire
weapons of mass destruction and the means to deliver them. We urge your prompt response to
this letter, beginning with the determinations you have made with respect to the imposition of
sanctions mandated by CISADA, by March 29,2011.



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