It is indisputable that Iran is not in compliance with the JCPOA. Whether it was clandestinely violating it all along or this first occurred later may be a source of debate; but nevertheless, the fact remains it is in non-compliance.
After the disappointing failure of the Security Council to renew the thirteen-year old arms embargo against Iran, Secretary of State Mike Pompeo delivered a notice to the UN Secretary General and president of the Security Council initiating the so-called snapback sanctions procedure, under Resolution 2231.
By way of background, UN Security Council Resolution 2231 of 2015 is the one that recognized the JCPOA and lifted the long list of previous UN Security Council resolutions imposing UN sanctions against Iran. It also provided for a procedure whereby those sanctions could be reinstated that is commonly referred to as the snapback provision. Thus, thirty days after receiving notice from the US, as a JCPOA participant, of an issue that the participant believes constitutes significant non-performance of commitments under the JCPOA, the UN sanctions are deemed reinstated. The only way to stop the reinstatement of the UN sanctions is if, within such thirty-day period, there is an affirmative vote by the Security Council to continue the lifting of sanctions relief provided for in Resolution 2231. Since the US could veto such an effort, the UN sanctions regime would perforce snapback into full force and effect.
Some have raised the issue of whether the US still has the right to trigger this provision of Resolution 2231, since the President announced on May 8, 2018 that the US would withdraw from the Iran nuclear deal. However, it is submitted that this misapprehends the nature and import of Resolution 2231, as well as, the JCPOA.
First of all, it is important to understand that the term ‘JCPOA participant’ is a defined term under Resolution 2231, which includes the US, China, France, Germany, the Russian Federation, the UK, the EU and Iran. It should also be noted that the JCPOA is not an actual legal agreement. It is unsigned and was never approved as a binding legal treaty by the US Congress. It was also likely not appropriately approved by the Iranian Parliament in the form presented to Congress or by the Ayatollah Khamenei.
The Obama administration, in a letter to then Congressman Pompeo, admitted the JCPOA was not a legally binding agreement and postured that it was nothing more than a political commitment. The withdrawal by the US from the JCPOA is nothing more than a symbolic act. In this regard, it should be noted that the term JCPOA is an acronym referring to the Joint Comprehensive Plan of Action, which, as its title implies, is a plan, not an agreement. As such, legal arguments about whether the US is still a legal party entitled to enforce what amounts to a non-agreement are specious and irrelevant. Interestingly, the letter goes on to acknowledge that the only real deterrent to Iran’s violation of its commitments is the US’ right to snapback UN sanctions and impose and ramp up its own unilateral sanctions against Iran.
The only relevant document is Resolution 2231 and, under it as noted above, the US is definitionally a participant entitled to snapback protection. As a practical matter, this is immutable, given that this provision cannot be changed without amending the Resolution, which the US could veto, as a permanent member of the Security Council. It is, therefore, entitled to enforce the Resolution, by its terms. Indeed, consider the absurdity of suggesting otherwise, given that Iran also withdrew from the JCPOA. It would make a complete mockery of the Resolution 2231 to argue that Iran’s withdrawal meant it was no longer a participant and, therefore, no longer subject to the reinstatement of UN sanctions against it under the Resolution. Moreover, the Resolution expressly references Iran’s commitment never, under any circumstances, to seek, develop or acquire any nuclear weapons and reaffirms its obligations as a State Party to the Treaty on the Non-Proliferation of Nuclear Weapons. Remember, it was Iran’s violation of its legally binding obligations under that Treaty, which was the source of the sanctions originally levied against Iran, in the first place.
Resolution 2231 does not prevent the US imposing its own sanctions on Iran for non-nuclear matters. Thus, the US was within its rights to sanction Iran for its egregious human rights violations, detention of US citizens on fabricated charges, support of terrorist groups and ballistic missiles program.
Moreover, even if the EU, Russia or China balk at or ignore the US’ right to snapback the UN sanctions, the US can still act unilaterally to impose crippling secondary sanctions. This would effectively deter most business dealings with Iran by EU countries, including their banking systems and companies under their jurisdiction. It would also impinge on the ability of Russia and China freely to do business with Iran, given their dependence on exchange currencies like the dollar and euro for trade. To put this in perspective, European firms have curtailed their business dealings with Iran based solely only on the sanctions imposed by the US on Iran, despite the EU urging them to defy the sanctions. The fact that the Iranian regime is already suffering mightily under existing US sanctions is further evidence of its effectiveness.
The renewed muscular effort by the US to contain not only the nuclear threat posed by the Iranian regime, but also its malign activities, has yielded other beneficial results. Thus, we were greeted with the wonderful and unexpected good news that President Trump and his team had successfully brokered a peace agreement between the UAE and Israel, only a little more than two weeks ago. This week, a US and Israeli delegation flew to the UAE, in a historic flight over Saudi Arabia, which in another breakthrough, granted permanent over-flight rights to Israel. There are also prospects for other countries, like Bahrain, Sudan, Oman and Saudi Arabia to join in making peace with Israel. Amazingly, even the President of Lebanon hinted at the possibility of peace talks with Israel.
Unfortunately, not everyone shared in the glee. As might have been expected, the Iranian government vehemently decried the peace agreement. The club of nefarious players opposing the deal also included Hamas and the PA.
The Abraham Accord, as the new peace deal has been aptly named, is a historical achievement. It’s been over a quarter of a century since the peace treaty between Israel and Jordan and more than forty years since the peace treaty with Egypt.
Much has changed since then. Iraq, once a powerful opponent of Iran, was soundly defeated by the United States and it’s coalition partners and it is no longer a regional power in the Middle East. A civil war broke out in Syria, which has allowed it to become prey to ISIS, Russia, Iran and now Turkey. Lebanon, once a state that balanced the interests of its Christian, Sunni and Shiite citizens, is now held hostage to Hezbollah, an Iranian proxy. Gaza is controlled by Hamas, another Iranian proxy and the autocratic kleptocrats of the PA presume to control and oppress the lives of the people in the PA controlled areas, for more than a decade since their last elected terms expired. In the new era of the Abraham Accord their intransigence has become a liability, not an asset, in their relationship with the Arab world around them.
One of the most significant and adverse changes that occurred, though, is the emergence of the Iran, under the control of the Ayatollahs and their terrorist IRGC enforcers, as a nefarious force determined to achieve hegemony in the region and wipe out its opponents. The current government of Iran is a Shiite Theocracy and there are few, if any, internal checks on its power. It is a repressive regime and many in Iran don’t agree with its policies or appreciate the lack of freedom. Unfortunately, a promising popular massive uprising was brutally suppressed in 2009, while the Obama administration stood aloof, failing to support the protestors in any meaningful fashion.
The autocratic Iranian government views itself, as being in a state of war with Israel and the Sunni Arab nations, like Saudi Arabia and the Emirates. It seeks to annihilate Israel, control Mecca and dominate the Sunni controlled countries. It also views the United States as its enemy; make no mistake about it, despite the so-called Iran deal, the Iranian government still views the US as the great Satan.
One of the drivers of the recent UAE-Israel deal and the success of President Trump’s bold new peace initiative is the credibility he established by finally acknowledging the reality that the so-called Iran deal was nothing more than a charade. The Obama administration’s overture to Iran that dismissed the very real concerns of allies, like Israel and the Sunni Arab States, left them wondering whether the US was still a reliable and trusted friend. The fact that Iran was able to continue and even accelerate its malign activities and development of its other weapons programs like ballistic missiles, without any active US countermeasures, only served to embolden Iran’s misbehavior and frighten US allies in the region.
Despite the assurances made by the Obama administration that there would be a rigorous inspection regime and, as a result of the JCPOA, Iran would moderate it misbehavior, this turned out to be aspirational, not reality. The canard has been exposed and it appears Iran honored the so-called deal only in the breach. There are numerous examples of Iranian Regime’s breaches of the JCPOA, as noted above and its continuing malign activities, directly or through its proxies, against the US and its allies, in the region and elsewhere. We also cannot forget that the US State Department has declared Iran a State Sponsor of Terrorism ever since January 19, 1984 and the US intelligence community views Iran as an enduring threat to US national interests, despite the JCPOA.
The JCPOA neither prevents the Iranian government from securing nuclear weapons nor incentivizes it to become a good neighbor. It merely serves to condone its reckless and nefarious behavior, including the criminal and terrorist activities of its proxies, which was reinforced by the Obama administration’s policy of continuing to fund the Iranian regime, despite its wrongdoing. This included the notorious delivery of over $1.5 billion in virtually untraceable cash, in a variety of currencies, as a part of the many billions in assets released to Iran, which, at least in part, was funneled to Iran backed terrorists. These misguided policies and actions were viewed as a comprehensive shift in favor of the terrorists governing Iran and away from the US’ traditional loyal friends in the region, including Israel, the Emirates and Saudi Arabia. It was also at the expense of the Iranian people yearning to be free of their autocratic and repressive regime.
To better understand the overwhelming nature of the threat posed by the Iranian regime to US interests in the region, outlined below are just some recent occurrences and those of the not so distant past. History is an invaluable tool to deepening our understanding of those who have declared themselves to be our avowed and implacable enemies; it strongly suggests we should believe the threat is real.
It was only a few weeks ago that CNN reported that the Iranian government was paying bounties to kill US soldiers in Afghanistan. It is also responsible for the death of more than 600 US troops in Iraq. Who can forget how the Iranian regime blatantly attacked US bases in Iraq with ballistic missiles, in January of 2020 and then there were rocket attacks, by its Hezbollah proxy, in March of 2020. Iran has also repeatedly conducted dangerous and harassing approaches of US Naval forces in the international waters of the Persian Gulf.
The flurry of new revelations include reports that the recent explosion in Beirut, which caused so much devastation, was the result of Hezbollah’s bomb-making activities and a new delivery of additional explosives material, funded by the Iranian government. There’s also the recent International tribunal determination that Rafiq Hariri, the former president of Lebanon was killed by Hezbollah, an Iranian proxy, as ordered Khamenei and planned by Soleimani, as a part of their scheme to exert complete control over Lebanon. The Houthis, another Iranian government proxy, have been firing Iranian supplied ballistic missiles against Saudi Arabia and they declared their readiness to attack Israel alongside Iranian government backed Hezbollah. They are also responsible for oppressing and expelling the last few remaining Jews in Yemen. Hamas, yet another Iranian government proxy, is once again shooting rockets and sending incendiary devices against Israel, seemingly in response to the peace agreement between Israel and the UAE, although a Qatari brokered cease fire was just put in place.
The history of Iranian government attacks against the US includes the 1983 bombings of the US Marine Barracks and Embassy in Beirut, as well as, the 1996 Khobar Towers bombing in Saudi Arabia.
It is critical to recognize that the Iranian regime is at war with the United States. Indeed, as Federal District Court Judge Daniels ruled, Iran, including the Ayatollah Khomenei, were responsible for the 9/11 attacks on the US, one of the most provocative and destructive terrorist acts committed against the US homeland and its people. In his 53 pages of detailed Findings of Facts and Conclusions of Law, the role Iran and its various governmental organs played in this horrible attack on the homeland are described. Among other things, the Court found: (1) Iran has been waging war against the United States for over 30 years; (2) the Ayatollah Khomeini holds absolute power and can dismiss the president, overrule the parliament and courts and overturn any secular law; (3) the religious division between Sunni and Shi’a did not, in fact, pose an insurmountable barrier to cooperation on terrorist operations and an alliance was formed between Shi’a Iran and Sunni al Qaeda to conduct terrorist attacks against the United States, including 9/11; (4) Iran was behind the Khobar Towers bombing and the attacks on the US Embassies in Nairobi, Kenya and Dar-es-Salaam; and (5) Iran devised plans aimed at breaking the backbone of the American economy, crippling or disheartening the United States and its people and disrupting its economic, social, military and political order, including the scheme to crash Boeing jumbo jets, with large fuel capacities, into the World Trade Center, White House and Pentagon that was code named “Shaitan dar Atash” (loosely translated as, Satan in Flames).
Nothing in the purported Iran deal changed this, as the Ayatollah continues to make clear on a regular basis. Hope and spin are no substitute for putting in place genuine safeguards to prevent Iran and its proxies from attacking the US and its allies. It’s not just about the nuclear threat. The Court found that Iran has many plans for attacking the US, including: (a) using chemical weapons and radioactive dirty bombs; (b) bombing hundreds of electrical power plants, gas stations and oil tankers; (c) using passenger airliners as bombs against US cities; and (d) bombing the railroads.
Isaiah (Chapter 28, Verse 15) offers some insights into the ineffectiveness of disingenuous agreements. He cautions the scorners and spin-doctors. An agreement purporting to establish limits, like red lines not to be crossed, or to cheat death can’t be sustained. Mere words can’t provide shelter and refuge in the face of an enemy intent on war. It’s nothing more than a false hope.
Let’s take the lessons of Isaiah to heart. The promise of safety for the homeland, because of some contrived and hopeful strategy to limit Iran from completing a nuclear bomb, for a short period of 10-15 years, is not genuine. It is based on a false premise. We are, as 9/11 demonstrated, vulnerable to terrorist attacks by non-nuclear means.
We cannot afford once again to promote a non-binding impotent agreement, like the JCPOA. It was also foolhardy not to address Iran’s misbehavior outside of the limited scope of its already illegal quest for a nuclear device. The President’s strategy of renewed sanctions against the Iranian regime and bad actors like the IRGC has taken a toll. It’s time to ramp them up further and, hence, the initiation of the snapback. An unreformed and reinvigorated Iran, with renewed access to world markets and sanctions relief, is still an avowed and implacable foe of our country, as well as, its own people. It’s why many of the freedom loving people of Iran support the re-imposition of sanctions as a means of ridding themselves of this oppressive regime. We must also support their efforts to free themselves from tyranny.
With the advent of President Trump, terrorism by Iran is no longer blindly tolerated. Sanctions were levied against the IRGC and other bad actors in the Iranian regime, in response to their malign actions; no longer is Iran’s misbehavior just condoned and without consequences. Murderous terrorists leaders like Solimani were surgically targeted and received their just due. The territorial pretensions of ISIS were virtually eliminated. A new reality appears to have taken hold in the Middle East, where once again the US is viewed as a force for good; not a callous associate of Iran’s ambitions and disloyal to its old friends in the region.
We should all be united in support of the US’ efforts to snap back the full weight of the sanctions. Don’t be misled by calls by those in the previous administration, who condoned the Iranian government’s wicked activities. The new approach of the Trump administration has already succeeded in yielding a real peace dividend and presents the prospect of continuing to do so.
It’s time to build on the success of the US brokered Israel-UAE peace agreement and preserve and enhance it by creating a regional alliance for peace and security, sponsored by the US. Indeed, why not establish a Middle East Treaty Organization (METO), based on the NATO structure. METO, anchored by Israel, Egypt, the UAE and future peace partners could be a vehicle to enhance the security and preserve the peace in the region. Hopefully, one day soon, a free Iranian people will be able to join too. Until then, we must unite those interested in peace in containing the threat to peace posed by the existing tyrannical Iranian regime and its proxies.
There is a new reality burgeoning in the Middle East, fostered by the US and centered on peace with Israel and development. Psalms 122:6 declares, those who seek the peace of Jerusalem shall prosper and enjoy tranquility and Number 24:9 assures, those who bless Israel will be blessed. May the blessings of peace prevail.
 See UN agency says Iran is violating all restrictions of nuclear deal, by Kiyoko Metzler, David Rising and Edith M. Lederer, AP, dated 6/5/20; Europeans trigger dispute mechanism in urgent bid to save Iranian nuclear deal, by Natash Turak, CNBC, dated 1/14/20; UN reports increasing violations of Iran nuclear deal, by Kiyoko Metzler, David Rising and Jon Gambrell, AP, dated 11/11/19; Iran is Not Complying with the Nuclear Deal, by Fred Fleitz, in National Review, dated 7/14/17; and Iran Nuclear Deal, by Peter Brookes. Brett Schaefer and James Phillips, Heritage Foundation, dated 1/29/20.
 See, for example, the matter of the missing uranium disk that could be used to generate neutrons for triggering fission in an atomic bomb’s U-235 core, reported in New tensions dim hopes for salvaging Iran nuclear deal, by Richard Stone, in Science Magazine, dated 6/17/20 and The IAEA’s nuclear reports on Iran are its harshest rebuke yet, by Samuel M. Hickey, at armscontrolcenter.org, dated 6/16/20.
 See The United Nations failed to renew the arms embargo on Iran. What does that mean?, by Hollie McKay, Fox News, dated 8/18/20.
 Secretary of State Michael R. Pompeo-At a Press Availability, Remarks to the Press, on August 20, 2020 (on the State Department website at www.state.gov).
 As detailed in Resolution 2231 of 2015.
 See Remarks by President Trump on the Joint Comprehensive Plan of Action, issued on May 8, 2018 (on the White House website at www.whitehouse.gov)
 See MEMRI, The Iranian Majlis Has Not Approved The JCPOA But Iran’s Amended Version of it, dated 10/14/15.
 See MEMRI, Iranian Guardian Council Secretary-General Ahmad Jannati: Khamenei Has Not Approved or Signed the JCPOA, dated 10/16/15.
 Letter, dated November 19, 2015, from the State Department to the Honorable Mike Pompeo, House of Representatives.
 See Iran is withdrawing from the 2015 nuclear deal after Trump ordered deadly strike on its top general, by John Haltiwanger, in Business Insider, dated 1/5/20.
 See also Joint Statement of Foreign Ministers of France, Germany and the United Kingdom on the JCPOA, dated 1/14/20, which makes clear that Iran continues to be obligated and has violated those obligations, as well as, noting the triggering of the Dispute Resolution Mechanism, under Section 36 of the JCPOA.
 See Do Recent U.S. Sanctions Against Iran Violate the JCPOA?. By Richard Horowitz, in the National Interest, dated 9/26/17.
 See How the US sanctions are paralyzing the Iranian economy, by Rick Noack, Armand Emamdjomeh and Joe Fox, in the Washington Post, dated 1/10/20. See also Why Companies around the World are Reversing Course on Iran Business, at Iran Watch, dated 8/11/20.
 See Remarks by President Trump Announcing the Normalization of Relations Between Israel and the United Arab Emirates of 8/13/20, online at www.whitehouse.gov; Stunning Israel-UAE deal upends the ‘rules’ about peace-making in the Middle East, by Michael Oren, in the Blogs at the Times of Israel, dated 8/14/20; The Israel-U.A.E. Deal and the Beirut Blast Both Box in Iran, by Farnaz Fassihi and David D. Kilpatrick, in the New York Times, dated 8/18/20; and With UAE deal, Israel opens tentative new chapter with Gulf Arabs, by Frank Gardner, BBC, dated 8/18/20.
 In boon for Israel, Saudi Arabia gives permanent overfly rights to and from UAE, by Raphael Ahren, in the Times of Israel, dated 9/2/20.
 See Bahrain, Sudan May Follow UAE In Making Peace With Israel, Minister Says
By Gwen Ackerman and Vivian Nereim, in Bloomberg, dated 8/17/20.
 Israel says it expects Bahrain and Oman to follow UAE in formalizing ties, in Reuters, dated 8/16/20.
 See Trump expects Saudi Arabia to join UAE-Israel deal, in Reuters, dated 8/19/20 and Saudi Arabia Cautiously Welcome UAE, Israel Normalization, in AP, dated 8/19/20.
 See Lebanese president hints at possibility of peace talks with Israel, by the TOI staff, in the Times of Israel, dated 8/16/20.
 See Iran’s Khamenei: UAE ‘treason’ against Palestinians and Islam will not last long, by Agencies and TOI staff, in the Times of Israel, dated 9/1/20; In 1rst response from Iran, official says ‘UAE will be engulfed in Zionism fire’, by TOI staff, in the Times of Israel, dated 8/14/20; and Iran, Turkey, Ben Rhodes, Tlaib United in Criticism of UAE-Israel Deal, by Seth Frantzman, in the Jerusalem Post, dated 8/15/20.
 See At joint Hamas-Fatah rally in West Bank, 2,000 protest Israel-UAE deal, by AFP and TOI staff, at the Times of Israel, dated 8/20/20.
 See Palestinians say United Arab Emirates Deal with Israel hinders quest for Mideast peace, Joseph Krauss, AP, dated 8/14/20.
 See, for example, Unrest in Iran forces Obama’s hand, by Ben Smith, in Politico, dated 6/15/09 and Why Obama Let Iran’s Green Revolution Fail, by Eli Lake, in Bloomberg, dated 8/24/16.
 See Iran’s Post Modern Jihad Against the Jews, an excellent analysis by Dr. Reza Parchizadeh, at BESA, dated 7/20/20.
 See, for example, U.S. Remains the Great Satan, Hardliner in Iran Say, by Thomas Erdbrink, in the New York Times, dated 9/1/15.
 See The Iran Nuclear Deal: What You Need To Know About The JCPOA, at obamawh.archives.gov/iran-deal, under the Title: The JCPOA is Based on Verification, not Trust, which touts that it provides for the most comprehensive and intrusive verification regime ever negotiated.
 Statement by the President on the Framework to Prevent Iran from Obtaining a Nuclear Weapon, dated 4/2/15, at obamawh.archives.gov/the- press-office/2015/04/02/statement.
 See also Iran blocking sites access, UN nuclear watchdog says, in BBC news, dated 6/5/20 and Iran rejects US call for UN watchdog to inspect more sites, by Laura Smith-Spark and Sarah El Sirgany, CNN, dated 8/30/17.
 See Iranian Aggression and Bad Actions Since the JCPOA, at Endowment for Middle East Truth, at www.emetonline.org.
 See Overview of State-Sponsored Terrorism by Iran at www.unitedagainstnucleariran.com.
 See State Sponsors of Terrorism-United States Department of State at www.state.gov/state-sponsors-of-terrorism/.
 See Statement for the Record, Worldwide Threat Assessment of the US Intelligence Community, to the Senate Select Committee on Intelligence, by Daniel R. Coates DNI, dated 5/11/17.
 See The secret backstory of how Obama let Hezbollah off the hook, an expose of Iranian backed Hezbollah drug trafficking, weapons smuggling and money laundering, by Josh Meyer in Politico, dated 12/18/17; Yes, Obama Helped Fund the Iranian Regime, by David Harsanyi, in National Review, dated 1/8/20; U.S. wire payments to Iran undercut Obama, by Louis Nelson, in Politico, dated 9/18/16; Secret Obama-era permit let Iran convert funds to dollars, PBS News Hour, dated 6/6/18; and transcript of Senate Hearing before the Subcommittee on National Security and International Trade and Finance, examining the terrorism financing risks of allowing the Islamic Republic of Iran to gain access to large amounts of hard currency and the US Government’s payments of $1.7 billion in foreign cash to Iran, dated 9/21/16.
 See Sorry ‘Factchecker,’ Nikki Haley is Right-Obama Sent Iran a Planeload of Cash, by David Harsanyi, in National Review, dated 8/25/20 and Obama should apologize for shameful cash payment to Iran, by Douglas MacKinnon, in the Hill, dated 1/1/20.
 See Obama-era cash traced to Iran backed terrorists, by Bill Gertz, in the Washington Times, dated 2/7/18 and How Obama Secretly Gave Iran Access To Billions Of Dollars-And Enabled Terrorism, in Investors Business Daily, dated 6/8/18.
 See US intelligence indicates Iran paid bounties to Taliban for targeting American troops in Afghanistan, by Zachary Cohen, CNN, dated 8/17/20.
 See Iran killed more US troops in Iraq than previously known, Pentagon says, by Kyle Rempfer, in Military Times, dated 4/4/19.
 See American troops had only hours to react to Iranian ballistic missile attack. Here’s what they did, by Shawn Snow, in Military Times, dated 4/21/20.
 See Iraq base attack: US in retaliatory strikes on Iran backed fighters, BBC news, dated 3/13/20.
 See IRGC Vessels Conduct Unsafe, Unprofessional Interaction with US Naval Forces in Arabian Gulf, by US 5th Fleet Public Affairs, Centcom, dated 4/15/20.
 See Hezbollah purchased explosive material during time of post storage-report, by Benjamin Weinthal, Jerusalem Post, dated 8/19/20.
 See Iran: Rafiq Hariri Was Assassinated by Hezbollah on the Orders of Khamenei and Qassem Soleimani’s Plan, ncr-iran.org, dated 8/19/20.
 Houthis, Hezbollah and Hamas: Israel and Saudi Arabia face similar threats, by Seth Franzmanm Jerusalem Post, dated 3/26/18.
 See Houthis are forcing out Yemen’s last remaining Jews, by Hanan Greenwood, in Israel Hayom, dated 8/21/20.
 See Israel-Hamas ceasefire deal reached after weeks of Gaza balloon attacks, by Judah Ari Gross and Aaron Boxerman, in the Times of Israel, dated 8/31/20.
 See Families of Beirut bomb victims mark 30th anniversary of first major terrorist attack on US, by Cristina Corbin, Fox News, dated 11/29/15.
 See Beirut Rules: The Murder of CIA Station Chief and Hezbollah’s War Against America, by Fred Burton and Samuel M. Katz (Berkley, 2018), which describes Iran’s complicity in the terrorist attack.
 Attorney General Ashcroft laid responsibility for this dastardly deed on Iranian backed Hezbollah. See Attorney General Statement, dated 6/21/01.
 The historic ruling was entered, on December 22, 2011, in the Havlish case, brought by family members and legal representatives of victims of 9/11, in US District Court, Southern District of New York, 03 MDL 1570 and 03 Civ. 9848 (GBD) (FM).