As the Joint Comprehensive Plan of Action (JCPOA) enters its third year of implementation, an atmosphere of uncertainty has slowed the pace of post-sanctions trade and investment. In Tehran, government figures have sought to lay blame for Iran’s faltering economic recovery on a concerted American campaign to undermine the agreement and dissuade investment. In a September interview on the sidelines of the United Nations General Assembly, Iranian Foreign Minister Mohammad Javad Zarif pointed to the atmosphere of uncertainty as a part of US President Donald Trump’s strategy to undermine the deal. He said, “I think he has made a policy of being unpredictable, and now he's turning that into being unreliable as well. He has violated the letter, spirit, everything of the deal.”

Another view has been promulgated in Washington — one that points emphatically at risks endemic to Iran’s economy, particularly in regard to the economic activities of the Islamic Revolutionary Guard Corps (IRGC). Since President Trump decertified the Iran nuclear deal in October, American officials and advocacy groups have been even more vocal about these risks.

In October, at a briefing alongside Saudi Minister of Foreign Affairs Adel al-Jubeir in Riyadh, US Secretary of State Rex Tillerson declared that “both of our countries believe that those who conduct business with the [IRGC], any of their entities — European companies or other companies around the globe — really do so at great risk.” Just last week, Sigal Mandelker, treasury undersecretary for Terrorism and Financial Intelligence, stated the following in her testimony to the Senate Committee on Banking, Housing and Urban Affairs: “In our engagements both here in the United States and abroad, we have made clear that companies doing business in Iran face substantial risks of transacting with the IRGC or IRGC-linked entities.”

The discussion of risk as an essential characteristic of Iran’s economy is part of a strategy to deflect US responsibility for Iran’s faltering reintegration into the global economy. The groundwork for this strategy was set by advocacy organizations such as the Foundation for Defense of Democracies (FDD) and United Against Nuclear Iran (UANI), which have long published materials and organized events to ostensibly warn companies of the risks inherent in conducting business in Iran. The FDD has published guides on the “Risks of Doing Business in Iran,” and UANI operates a whole website devoted to Iran Business Risk.