Following reports that the U.S. government transferred $4,000,000 in cash to the Government of Iran in its settlement of outstanding claims being litigated at the U.S.-Iran Claims Tribunal in The Hague, an exchange took place at the U.S. State Department’s press briefing that is illustrative of the U.S. sanctions compliance challenges facing a private U.S. citizen:

QUESTION:  Does the – if a private citizen owed the Iranian government, let’s say, a more modest amount of money – say, $40,000 … would it be legal for that person, whoever it is, to send cash to the Iranian Government? Would it be legal under current U.S. law to send that cash to Iran?

TONER:  Good question. I’m not sure the answer. I mean, it’s not – I mean, obviously, there’s no applicable sanctions that I’m aware of, but I know we’re not doing – from U.S. financial institutions, we’re not engaged –

QUESTION:  Well, did the Administration require to get from itself, from Treasury, a special, specific license to do this –

TONER:  Yeah.

QUESTION:  — $ 400 million cash transfer.

TONER:  I’m not aware of that, but I can certainly ask.

From what I can piece together, the U.S. State Department Spokesperson Mark Toner stated that there are “no applicable sanctions” that he is aware of that would restrict a U.S. person from transferring $40,000 in cash to the Government of Iran – other than the restrictions imposed on U.S. financial institutions.

His answer, however, should have been: “No. Absolutely not. A U.S. person cannot send $40,000 in cash to the Government of Iran absent license authorization, which will not be forthcoming. It would be a serious violation of current U.S. law for a U.S. person to engage in any transactions with the Government of Iran absent express authorization from the U.S. government.  Silly question.”

How, then, is a private U.S. citizen supposed to understand the scope of U.S. sanctions regulations targeting Iran when the Government’s own spokesperson fumbles the issue in such a public manner?  Do we expect more from a private U.S. citizen than we do from our civil servants speaking on behalf of the U.S. government?