On the recordSeptember 22, 2016
I would make the point that, as we talk about whether Iran took possession of this money in cash or by check, that transaction is immaterial. I understand the argument here, but let me explain why I do not think that holds true with respect to the process here. There are other options that could have been followed, that have been followed by the international community when payment is made. For example, the administration could have held the funds in an escrow account overseas, verified that the end recipients of the funds were, in Iran, not sanctioned entities, like the Islamic Revolutionary Guard Corps. By providing cash, the administration is doing the work for the Iranians that they need done in terms of preparatory work for money laundering. That is the problem. That is the problem with the way this was done. Cash transactions, in and of themselves, raise serious terrorism financing risks, according to the Financial Action Task Force; and that is the official body, international body, that sets the global standards for preventing money laundering and is most focused on stopping terror finance. What they say, again, is that the physical cross-border transportation of currency is the main method used to move illicit funds, to launder money, and to finance terrorism. That is why we want to cut off cash.…





