"Sanctionable" is one of a few English words to have two contrary meanings: legally punishable and ethically approvable. The contradiction appears to translate well into three European languages -- German, Italian and Spanish -- at least with regard to doing business with Iran.
The German government has been one of the most vocal critics of Iran's pursuit of nuclear weapons and human rights violations. Chancellor Angela Merkel herself regularly warns Iran of increasing economic pressure in response to Iran's refusal to negotiate seriously over its nuclear program. A government spokesman also adjured German companies to use their "moral sense" when doing business with Iran and that "the government is expecting some sensitivity from businesses."
So it was surprising to learn that Germany's central bank is helping Iran to receive $12 billion from India in oil payments. One would think the policy of dissuading the private sector from doing business with Iran would apply first and foremost to Germany's own central bank. As the New York Times reported, the U.S. government has been pressing German officials to take action against the Iranian-owned EIH Bank in Hamburg, to which the Bundesbank is transferring the money and which the U.S. government has sanctioned for involvement in Iran's missile program. When ADL raised this issue with the German government, they responded that the Bundesbank was simply "engaging in legal activities." While the transactions may not be sanctionable activity in the legal sense, they certainly are not sanctionable in the ethical sense.
While doing nothing illegal itself, the Italian-Iranian Chamber of Commerce (IICC) has been promoting clearly sanctionable activity (in the legal sense) that is hardly sanctionable (in the ethical sense.) Most glaringly, a top event advertised on the IICC website is the Iran Oil Show in Tehran, April 16-19, despite European Union sanctions that include "restrictions on trade in key equipment and technology for, and restrictions on investment in the Iranian oil and gas industry."
Just weeks ago, the IICC also hosted an Iranian business delegation that focused on the house construction, mining, and energy sectors, three areas dominated in Iran by the Islamic Revolutionary Guards Corp (IRGC). The IRGC and several of its commercial subsidiaries have been designated by the United Nations Security Council, the U.S. Government, and the E.U. as engaged in the proliferation of nuclear weapons.
What the government-approved Italian-Iranian Chamber of Commerce is promoting, the Government of Spain itself is sponsoring. The same Iranian business delegation first stopped in Madrid, hosted by the Madrid Chamber of Commerce and the Institute of Foreign Trade, known by its Spanish acronym, ICEX. ICEX is under the direct control of Spain's Ministry of Industry, Tourism and Commerce.
The Madrid Chamber of Commerce press release for the event noted the participation of "40 Iranian companies that work in four priority sectors of the relations between Spain and Iran: infrastructure, petrochemicals and energy, tourism and financial services." Was the Madrid Chamber of Commerce unaware that E.U. sanctions cover both energy and financial services sectors? Does the Spanish government not know that the IRGC's hundreds of subsidiary or related organizations have a major presence in the infrastructure and petrochemical sectors?
Amazingly, the one specific project mentioned in the press release was "the enlargement of the Tehran metro." Since the Tehran metro has announced that construction for its next six lines will only begin in 2018, the reference in the press release is most likely to "Line 7," currently under construction. The general contractor for Line 7 is Sepasad Engineering, an IRGC company specifically designated by the E.U. for nuclear proliferation.
So the question arises, did a Spanish government entity host an event to promote business with a sanctioned Iranian company involved in Iran's nuclear program?
We hope an answer can be found in the next six months. The press release announced plans to host another Iranian delegation in October.