Why is Armenia being singled out for strict enforcement, when no sanctions at all have been imposed on Turkey, Azerbaijan, or other states that are statutorily subject to sanctions and that have far larger and more consequential ties with Iran?
This inconsistency raises substantive questions about the role of scale, scope, and selectivity in the Administration’s discretionary decision-making regarding the application of sanctions.
HERE ARE THE FACTS:
SCALE: The level of Armenian economic engagement with Iran is far lower than neighboring Turkey’s or Azerbaijan’s.
— Turkey is among Iran’s top economic partners, with annual bilateral trade in oil, gas, and other products approaching $10 billion.
— Azerbaijan’s Shah Deniz gas field is currently 10% owned by Iran (via its National Iranian Oil Company (a sanctionable investment worth more than $2 billion).
— In contrast, Armenia’s annual trade with Iran has, in recent years, been less than $300 million.
SCOPE: The range of products, goods, and services traded between Armenia and Iran is limited
— Armenia provides Iran with electricity, sheep and goat meat, and other non-dual use products.
— Iran’s primary exports to Armenia are natural gas and other oil products, as well as iron ore, glass, and fertilizer (all non-dual use products).
— Iran’s trade with both Turkey and Azerbaijan involves a considerably broader array of products and services.
SELECTIVITY: Armenia has been singled out for selective enforcement, despite having far lower levels of engagement with Iran than Turkey, Azerbaijan, or other countries that meet the statutory standards for sanctions.
To be clear, this selective action is being taken against, Armenia:
— A democratic country universally praised for its free and fair elections, and good governance.
— A member of NATO’s Partnership for Peace and contributor to peacekeeping in Afghanistan, Iraq, Mali, Kosovo, and Lebanon.
— A Christian-majority country (the first Christian nation) that stands for freedom and against the forces of hatred and intolerance.
— A blockaded, landlocked genocide-survivor state with per capita GDP of roughly $4,000/year.
— A safe haven for at-risk religious minorities and other refugees from Middle East.
— A country facing serious security threats from Turkey and Azerbaijan.