Dubai is a significant location for Under Secretary of the Treasury Stuart Levey to deliver his March 7 message to the world about the risks of doing business in Iran.
On the one hand, Dubai is literally across the water from Iran, a logical, nearby, natural trade partner for Iran on practically everything. On the other hand, Dubai is also a jurisdiction that has put into place a sophisticated anti-money laundering regime and increasingly capable financial regulatory regimes across the board, including for its capital markets. Counter terrorism cooperation between the U.S. and the government of the UAE of which Dubai is a part is extensive.
In light of close U.S.-UAE cooperation on a wide range of securitty issues, it was notable but not surprising that Under Secretary Levey's comments focused solely on the need of the private sector to adjust its behavior towards Iran. Under Secretary Levey told about 200 bankers at a Eurofinance conference in Dubai "to consider whether it is wise for your company to focus its efforts on doing business with Iran. . . The world's top financial institutions and corporations are re-evaluating their business with Iran because they are worried about the risk and their reputations. You should worry too and be especially cautious when it comes to doing business with Iran."
He went on to commend the cancellation of a planned conference in Dubai entitled "Doing Business in Iran."
The Under Secretary then made explicit what was implied in his formal remarks, stating that "those who are tempted to deal with targeted high-risk actors are put on notice: if they continue this relationship, they may be next to be targeted for action."
Will Treasury move forward with sanctions under Section 319 of the Patriot Act, freezing funds in the U.S. at a financial institution that is holding assets of a sanctioned Iranian entity outside the U.S.?
As Wednesday Addams might say, "be afraid. Be very afraid."
