Yesterday, the Wall Street Journal ran a piece by the nephew of Shapour Bakhtiar, the last prime minister under the Shah, regarding how “in their determination to cut a nuclear deal with Tehran, Washington and Brussels are rubbing salt into the wounds of the victims of Iranian terror” by removing from their respective sanctions lists certain truly nefarious individuals. Bakhtiar the nephew looks at Anis Naccache to illustrate his point – the man who was behind the attempted assassination of his uncle, Shapour, back in the 1980s – who will receive sanctions relief as part of the Joint Comprehensive Plan of Action (“JCPOA”).

There’s a basic problem to this entire argument, though: Anis Naccache was never designated – neither under the UN, the EU, or U.S. sanctions programs – for activities related to terrorism or those activities described in the WSJ article. Indeed, Naccache was never designated under a U.S. sanctions program at all (which makes the headline of the piece [“Obama’s Sanctions Gift to an Assassin for Iran”] not a little absurd).

Naccache was designated under a EU sanctions program, but for reasons having to do with Iran’s nuclear program (thereby explaining his exit from the EU sanctions list). According to Council Decision Implementing Article 7(2) of Regulation (EC) No. 423/2007 Concerning Restrictive Measures Against Iran (June 23, 2008), Naccache was placed on the EU sanctions list for his role as the Chairman of the Board of Directors of Bazargan Tejarat Tavanman Saccal – a UN- and EU-designated company that had sought to procure sensitive goods for Iranian entities designated under UNSC resolution 1737. That is the sole factual basis for his sanctions designation – a point meekly admitted and then ignored in the WSJ article.

Because Bazargan Tejarat Tavanman Saccal itself will be removed from the EU and UN sanctions list under the terms of the JCPOA (see Attachment 2), the factual basis for Naccache’s designation is fatally undermined. As such, Naccache himself will be removed from the EU sanctions list (see Attachment 2).

This all goes to show how critical it is that we correctly apprehend the sanctions authorities under which an individual or entity is designated, as well as the factual basis for their designation. Failure to do so can quickly lead to wild claims about a particular designation or the removal of a sanctions designation – not to mention a poor understanding of how sanctions designations are used to advance a national policy.

This WSJ article is a case in point: the piece (1) bemoans the fact that Obama is taking a “terrorist” off the sanctions list without fully grasping that Naccache neither is or was on a U.S. sanctions list to begin with; and (2) wonders why we’re delisting a terrorist like Naccache when Naccache’s EU designation had nothing whatsoever to do with terrorist activities. In other words, the article is impressively wrong on all counts.

Understandably, these sanctions issues are complex and take time and effort to understand, but isn’t it about time the news media employ some fact-checkers as to these sanctions claims?