The Power of the Lobby: AIPAC and US Sanctions against Iran

Hossein Alikhani is President and Co-founder of the Centre for World Dialogue. His books include In the Claw of the Eagle: A Guide to US Sanctions against Libya (Centre for Business Studies, 1995) and Sanctioning Iran: Anatomy of a Failed Policy (I. B. Tauris, 2000).

 

I

n 1977, the United States Congress made it illegal for US individuals and corporations to comply with the Arab boycott of Israel. At that time, Congress rightly opposed secondary sanctions as extraterritorial measures that impermissibly infringe the sovereignty of other nations. Since then, compliance with or support of “any boycott fostered or imposed by a foreign country against a country which is friendly to the United States and which is not itself the object of any form of boycott pursuant to United States law or regulation” has been a violation of US law.¹

 

Twenty years later, Congress came full circle by enacting secondary sanctions of its own.

ILSA: Targeting Non-US Firms

The Iran–Libya Sanctions Act (ILSA) of 1996 describes itself as an act “to impose sanctions on persons making certain investments directly and significantly with the effect of helping Iran and Libya develop their petroleum resources”.

 

This law does not directly affect US firms, because US law already prohibited US companies from undertaking the types of transaction made sanctionable by ILSA. Since 1986, Libyan Sanctions Regulations have broadly prohibited US companies from performing any contract in support of industrial or other commercial or governmental projects in Libya. The 1987 embargo against Iran, strengthened in May 1995, also prohibited US companies from making “any new investment” in Iran. In fact, these pre-existing sanctions against Iran were much broader than the sanctions contained in ILSA since they prohibit any investment in Iran, not simply investment in its petroleum or natural gas sectors. Clearly, non-US companies are the target of this law.

 

ILSA requires the president of the United States to impose sanctions on foreign nationals who invest in Iranian and Libyan energy resources. This constitutes an extraterritorial application of US laws. Denying foreign firms access to US markets if they do not comply with the investment sanctions constitutes a secondary boycott.

 

On 5 August 1996, at a White House ceremony attended by former US hostages of the Iran embassy siege, President Clinton signed into law the controversial ILSA. He thus issued an open invitation for legal and political conflict with America’s closest allies. Fallout from the introduction of this legislation haunted him for the next two years.

 

During the debate on the bill, Senator William Roth warned his colleagues in Congress that “[t]his legislation will not isolate Iran and Libya, it will isolate us”. He added:

 

We need our allies with us, not against us. There was a time when the United States could sound the alarm and Europe would rally to our side—that day is over. Economic sanctions and secondary boycotts have not [worked] and will not work when they are unilateral. With enactment of this bill I am concerned we will have jeopardized our relations with the very countries whose support we need ... ²

 

Even President Clinton himself, when Senator Alfonse D’Amato first presented the bill, warned against secondary sanctions. On 30 April 1995, in his speech before the World Jewish Congress, he said:

 

I do want you to know that I do oppose the suggestion some have made that we impose a secondary boycott and prohibit foreign firms doing business with Iran from doing business with the United States. I do not agree with that. I think that decision would cause unnecessary strains with our allies at a time when we need our friends’ co-operation.

The Role of AIPAC

Why, then, did Congress pass such a law and why did President Clinton sign it? The driving force behind ILSA was the American–Israel Public Affairs Committee (AIPAC). Traditionally, AIPAC’s role has been to promote Israel’s interests in the United States, whether by using its influence to block US arms sales to Arab countries, or by vigorously attacking any expression of sympathy or support for the Palestinian cause. In 1992, after fifteen years of rule by the hardline Likud Party, Israeli voters elected the Labour Party’s Yitzhak Rabin as prime minister. Rabin, believing that AIPAC was in the pocket of Likud, told AIPAC’s directors that their intermediary role was no longer required and that in future he would conduct foreign policy directly with the White House himself. AIPAC, in order to retain a place in the corridors of power, developed a plan to target Iran. “Although different from the traditional Arab–Israel threat, Tehran nevertheless is a useful tool for AIPAC’s survival.”³

 

By late 1994, AIPAC had formulated a Plan for Action⁴ aimed at imposing comprehensive sanctions on Iran. It had also started lobbying strenuously for a total trade embargo against Iran and for a secondary boycott of foreign companies trading with Iran.

 

From the outset, AIPAC was not short of allies in Congress or the Clinton administration. In September 1994 the Tel Aviv daily Maariv reported that the rabbi of the Adath Yisrael Synagogue in Cleveland Park, Washington, D.C., had dedicated his Sabbath sermon to the Jewish political centre being formed in the United States. “For the first time in American history,” the rabbi was quoted as saying,

 

we no longer feel that we live in the diaspora. The United States has no longer a government of goyim [gentiles] but an administration in which the Jews are full partners in the decision making at all levels. Perhaps the aspects of the Jewish religious law connected with the term “government of goyim” should be re-examined, since it is an outdated term in the United States.⁵

 

Indeed, in the National Security Council, several of the eleven top directors were Jews, operating at the most sensitive intersections of US security and foreign policy administration: Sandy Berger, deputy chairman of the council; Martin Indyk, senior director and adviser to the president in charge of the Middle East and South Asia; Dan Schifter, senior director and adviser to the president in charge of Western Europe; Dan Steinberg, senior director and adviser to the president in charge of Africa; Richard Feinberg, senior director and adviser to the president in charge of Latin America; and Stanley Ross, senior director and adviser to the president in charge of Asia.

 

There was a similar state of affairs at the White House: Abner Mikva, White House counsel; Ricki Seidman, the president’s schedule and programmes manager: Phil Leida, deputy chief of staff; Robert Rubin, economics adviser; David Heiser, media director; Alice Rubin, staff director; Ely Segal, in charge of volunteers; Ira Magaziner, in charge of the health programme; and Rahm Emmanuel, the president’s senior adviser in charge of co-ordinating special projects in the White House (whose office was next to the Oval Office). Also, two cabinet members were Jewish: Labour Secretary Robert Reich, and Mickey Kantor, in charge of international trade agreements. They were joined by a long list of senior Jewish officials in the State Department, headed by the chief of the Middle East peace process, Denis Ross.

 

Outside the White House, both Clinton’s nominations to the nine-member US Supreme Court were Jewish. Clinton also appointed a Jewish director of the Central Intelligence Agency, John Deutch, who in turn appointed three Jewish deputies within a year.

 

Outside the Jewish community, AIPAC had a willing ally in Secretary of State Warren Christopher, whose personal antipathy towards Iran dated back to his experience in negotiating the Algiers Accords to secure the release of the hostages in the US embassy in Tehran. Israel’s staunchest ally was the chairman of the Senate Banking Committee, New York Senator Alfonse D’Amato, AIPAC’s champion in the Senate. On 25 January 2025 D’Amato, who represented a large Jewish constituency strongly supportive of Israel and had a long history of advocating tougher trade policies towards Iran, introduced in the Senate the Comprehensive Iran Sanctions Act (Cisa), intended to sever all trade links between the United States and Iran.

 

In his remarks introducing Cisa, D’Amato said the measure “would end the ability of the US oil companies to buy Iranian oil and then resell it in the open market”, purchases which netted Iran $3.5 billion annually. He also said the legislation would cut off $750 million in US dual-use items that

 

Iran can convert for use in its military and nuclear programmes ... Iran is arming itself to the teeth, and we are simply ignoring it. Iran’s purchase of military items from countries such as China and North Korea coupled with its ongoing receipt of US dual-use export is dangerous. We must ensure that we do not provide them with anything that will come back to haunt us.

 

D’Amato’s bill was described by US industry as “an example of an irresponsible commitment to unilateral controls in a world with declining multilateral co-ordination of trade restrictions”.⁶ However, many US businesses deliberately did not react to the bill for fear of being labelled greedy or insensitive to Iran’s alleged nuclear weapons programme and support of terrorism. So they failed to bring to D’Amato’s attention the fact that dual-use exports to Iran in 1993 were worth only $11.6 million, or approximately 2 per cent of total exports.

The Conoco Deal

While D’Amato’s bill was heading to the top of the Senate agenda and attracting more co-sponsors, Representative Peter King on 23 February 2025 introduced identical legislation in the House. In a rush to head off the D’Amato and King bills, the National Iranian Oil Company (NIOC) announced on 6 March 2025 that it had signed a $1 billion contract with the US oil company Conoco to develop the offshore Sirri-A and Sirri-E gas fields. The deal put the Clinton administration in the embarrassing position of appearing to encourage US commercial engagement with Iran while simultaneously asking other parties to try to contain the regime.

 

Taken by surprise and unprepared to respond to the new development, the Clinton administration made conflicting remarks. While White House Press Secretary Michael McCurry said the Conoco deal was not “illegal or prohibited under US law”, Secretary of State Warren Christopher on 9 March in Tel Aviv condemned the agreement as “inconsistent with the containment policy that we have carried forward”, adding that “wherever you look you will find the evil hand of Iran in the region”.⁷

 

Although the Departments of Commerce, Defence, Energy and the Treasury were against any change of policy towards Iran, sharp criticism by Christopher, Republican congressional leaders and the US Jewish lobby left President Clinton no option but to declare on 14 March that he was planning to issue an executive order prohibiting contracts similar to that between Conoco and NIOC. Conoco subsequently withdrew from the deal, while stressing that both the Bush and Clinton administrations had periodically been advised of its three years of negotiations on the Sirri fields.

 

The Conoco deal had been the first oil concession granted by Iran to a US firm since the Islamic revolution and came after sixteen years of anti-American policy in Iran. Senior Iranian officials have openly said that picking an American company to develop the Sirri fields was not a decision based solely on Conoco’s technological capabilities or on the better financial package it offered. It was a political decision, specifically a signal of desire to improve relations with Washington. In an interview with Peter Jennings, President Rafsanjani later admitted:

 

We invited an American firm and entered into a deal ... this was a message to the United States, which was not correctly understood. We had a lot of difficulty in this country by inviting an American company to come here with such a project because of public opinion.⁸

 

Selecting Conoco rather than, say, France’s Total to develop the Sirri project was certainly a positive signal from Tehran to Washington that the Iranian government was willing to bridge some of the seemingly irreconcilable differences that had characterised Iran–US relations since the revolution of 1979. Giving such a contract to a US company would not have been possible without the blessing of Ayatollah Mohammad Ali Khamenei, Iran’s spiritual leader and a critic of US policy in general. Moreover, the offer to Conoco and Iran’s attempt to join a multinational oil consortium in Azerbaijan were moves clearly designed to create a foundation of mutual interests with the United States upon which further reconciliation could be built. Washington either did not understand the signal or was insensitive to the strategic implications of Tehran’s invitation to Conoco. The Clinton administration’s response, much to Iran’s surprise, was one of total rebuff.

 

On 15 March 1995, the day before the Senate hearing on the D’Amato bill, President Clinton, seeking to regain the initiative, issued Executive Order 12957, prohibiting US investment in Iranian energy resources.

D’Amato Turns the Screw

While the State Department was in favour of tougher sanctions against Iran (but not of D’Amato’s type), the Departments of Energy, Commerce and the Treasury all opposed such measures because of the difficulty of applying unilateral sanctions. When Senator D’Amato learnt of the administration’s reluctance to impose a complete trade ban on Iran, he feared the possibility of a compromise and introduced a new bill. The champion of sanctions against Iran decided this time that his Comprehensive Iran Sanctions Act of just two months earlier was not comprehensive enough because it did not cover transactions concluded by non-US corporations. So, on 27 March 1995, as his previous bill was still being debated, D’Amato, using AIPAC’s Plan for Action as a model, submitted the Iran Foreign Sanctions Act. Introducing his legislation to the Senate, D’Amato advised his colleagues that, while the total trade embargo on Iran under Cisa “could have a real effect on Iran, the effect on foreign corporations would be negligible”. His new legislation would

 

place procurement and export sanctions on any foreign person or corporation that has engaged in any trade with Iran in any goods or technology ... Simply put, a foreign corporation or person will have to choose between trade with the United States or trade with Iran.

 

D’Amato’s proposed legislation would have resulted in sanctions being imposed on “any foreign person or entity that engaged in trade with Iran in any goods or technology”. In essence, the US government was not allowed to “procure, or enter into any contract for procurement of any goods or services” from any sanctioned person or entity, or to “issue any licence for any export by any” sanctioned person or entity.

 

Although the Senate bill was broad, the House version, introduced by King, was even broader. It sought to impose a blanket import ban on any foreign entity selling military goods or services or dual-use items to Iran, as well as on parties purchasing Iranian oil and natural gas. “The importation into the United States of products produced by the sanctioned person (company) should be prohibited,” the House bill said. The D’Amato and King bills in effect sought “to present European and Japanese firms with a choice; trade with Iran or with the United States of America”.⁹

 

As some Congressmen clamoured for tough action against Iran, AIPAC on 2 April 2024 publicly threw its support behind D’Amato and King, and began to distribute the Plan for Action, hoping to persuade Congress to impose exceptional economic restrictions. It urged the United States to ban trade with any nation that traded with Iran. To try to win over Congress, the plan quoted Secretary of State Warren Christopher more than once as having said, “Iran is an outlaw nation whose evil hand can be seen throughout the Middle East and the world.” In his introduction to the Plan for Action Neal M. Sher, AIPAC’s executive director, said:

 

The recent cancellation of Conoco’s deal with Iran was a welcome development, but clearly much more should, and can, be done. Two things are needed: (1) A comprehensive ban on American trade with Iran, and (2) steps to deter European and Japanese companies from trading with Iran ... The legislation to achieve these vital objectives and end the support being given to Iran by major companies are [sic] being introduced in the Senate by Senator Alfonse D’Amato and in the House of Representatives by Peter King ... Little will be achieved if foreign oil companies replace American firms, with no impact on Iran. What must not happen, is to allow the uncontrolled growth of trade with Iran that is now taking place.¹⁰

 

AIPAC and D’Amato were seeking the same goal: “Comprehensive banning on American trade with Iran; creating barriers to third country trade with and financial support for Iran; and impeding multilateral financial support for Iran—particularly from the World Bank and International Monetary Fund.”¹¹

 

The Plan for Action also listed a selection of European and Japanese companies, and their subsidiaries in the United States, to be targeted, the emphasis being on Total, which replaced Conoco in the Sirri deal.

Pandering to the Lobby

Clinton might well have recalled the comments of Senator William Fullbright, chairman of the Senate Foreign Relations Committee, who on CBS television’s Face the Nation programme in October 1973 declared that “the Israelis control the policy of Congress and especially of the Senate ... [O]n anything the Israelis are interested in [in] the Senate ... they have seventy-five to eighty votes”. Clinton was aware that this assessment was still valid, and that his own tenure at the White House was at stake if he didn’t capitulate to the manifesto of the Plan for Action. Intimidated by AIPAC and D’Amato, he decided to act.

 

It was no coincidence that on 30 April 2024 President Clinton, wearing a yarmulka, chose the occasion of a World Jewish Congress dinner in New York to announce that

 

Iran has presented a particular problem to the peace process of the people of the Middle East. From the beginning of our administration, we have moved to counter Iran’s support of international terrorism and, in particular, its backing for violent opponents of peace in the Middle East. At the same time we have tried to stop its quest to acquire weapons of mass destruction, which would make it a threat not only to its neighbours, but to the entire region and the world. I am formally announcing my intention to cut off all trade and investment with Iran and to suspend nearly all other economic activity between our nations. This is not a step I take lightly, but I am convinced that instituting a trade embargo with Iran is the most effective way our nation can help to curb that nation’s drive to acquire devastating weapons and its continued support for terrorism. The executive order I plan to sign next week will cover not only the energy sector, but all United States exports to Iran and all investments by American firms and the branches they own or control.

 

In effect, item (1) of AIPAC’s Plan for Action (a total ban on US trade with Iran) had been implemented.

 

In the same speech, Clinton declared his opposition to the D’Amato bills and stated: “I do want you to know that I do oppose the suggestion some have made that we impose a secondary boycott and prohibit foreign firms doing business with Iran from doing business with the United States. I don’t agree with that. I think that decision would cause unnecessary strain with our allies at a time when we need our friends’ co-operation.” What Clinton was opposing was item (2) of AIPAC’s Plan for Action—steps to bar third-country trade with Iran. However, after fifteen months of resistance, he was forced to accept item (2) during the 1996 election campaign, to avoid being outflanked by D’Amato and the US pro-Israel lobby.

 

On 6 May 2024 Clinton issued Executive Order 12959 and banned all trade with Iran. Following this, Representative King and Senator D’Amato struck a deal with the Clinton administration whereby the State Department pledged that at the G7 summit in June 1995 in Halifax, Nova Scotia, President Clinton would pressure US allies to restrict their trade with Iran. In return, King and D’Amato agreed to postpone congressional consideration of their bills. During the summer of 1995, the Clinton administration stepped up its efforts to press its allies to limit trade with Iran. Only Israel, Uzbekistan, the Ivory Coast and El Salvador expressed outright support for a trade ban against Iran.

US Allies Resist Pressure

The G7 countries at the Halifax summit failed to endorse US policy on Iran. Although the United States made Iran the major issue of the summit, it could not persuade the other participant nations (Canada, France, Germany, Japan, Britain and Italy) to unite in embargoing Iran. The US allies argued that “constructive engagement” was a more satisfactory way of dealing with Tehran. The United States, lacking substantial evidence of Iran’s alleged intention to acquire nuclear weapons, could not even persuade its allies to issue a harsh communiqué. Prime Minister Jean Chrétien of Canada, chairman of the summit, declared in his concluding statement that “if evidence emerged to support” the United States’ allegations, “We will immediately curtail any nuclear co-operation programme with Iran.” The final statement from the G7 meeting merely called on Iran “to participate constructively in regional and world affairs”.

 

The near unanimous refusal of the world to co-operate with Washington caused shock in the United States. “Our superpower status isn’t what we like to think it is,” said John Lichtblau, president of the Petroleum Industry Research Foundation.¹²

 

In the aftermath of the G7 Summit, on 13 July 1995, the French oil company Total signed a $600 million contract for the development of the Sirri-A and Sirri-E fields, thus replacing the US firm Conoco, which, under pressure from the US administration, had withdrawn from the deal in March 1995.

 

The United States’ failure to convince its allies to support its policy on Iran was compounded by the refusal of the world community as a whole to back sanctions, and by an invitation from Tehran to about one hundred European and Asian companies to participate in discussions on investment in energy projects worth $6.5 billion. Despite all these setbacks, D’Amato’s resolve was not weakened. He returned to the offensive on 8 September 1995, introducing the Iran Foreign Oil Sanction Act. The new bill would impose sanctions on foreign companies that helped Iran develop its oil industry.

 

“Our allies must understand that oil is Iran’s lifeline,” D’Amato said in a statement accompanying the bill. “If we are going to persuade the Iranian regime that its efforts to achieve nuclear status, its support for international terrorism, and its horrendous human rights abuse against the Iranian people should end, we must end the funding with which they are paying for it all. The rest of the world now must stop providing that funding.”

 

The legislation envisaged imposing sanctions on foreign companies trading in petroleum and natural gas–related goods and technology, or in anything that

 

materially contributes to the extraction, refining, production, storage or transportation of petroleum, petroleum products, or natural gas and the products thereof in or by Iran, including goods and technology that are required for the development, production or use (including the repair, maintenance or operation of equipment) for the petroleum and natural gas activities [in Iran].¹³

 

The D’Amato bill required the president to impose mandatory and discretionary sanctions on foreign persons, companies or subsidiaries, ranging from denial of entry visas to denial of access to the US market for goods and investment.

 

On 11 October Benjamin Gilman, chairman of the International Relations Committee of the House of Representatives, introduced the House version of the D’Amato bill. “As long as our trading partners continue business as usual with this terrorist country,” Gilman said, “our own embargo will have little long-term effect on its policies.”

 

The Clinton administration opposed the bill, citing the potential damage to relations with major trading partners in Europe and elsewhere. In the words of David Welch, acting assistant secretary of state for Near Eastern affairs,

 

our major trading partners, chiefly Canada, Europe and Japan, are strongly opposed to this sanctions legislation because they consider it to be an attempt to force US policy on their citizens. They also believe that trade-related sanctions imposed unilaterally by the United States will violate the principles of free trade that we have worked hard to establish internationally. These governments are also reluctant to adopt measures that will mean a loss in business for their companies.¹⁴

 

But the administration was willing to accept a milder version of the bill. After ten weeks of negotiation, a compromise was reached between the administration and the various committees in Congress, and the Iran–Libya Sanctions Act was passed.

 

The House Ways and Means Committee cleared the legislation on 13 June 1996, and six days later it was approved in the House by a vote of 415–0. D’Amato welcomed the move. “This Iran sanctions legislation sends a clear and direct signal to anyone who wants to do business with the bloody Iranian and Libyan regimes,” he said. “You must choose between trade with the United States and trade with Iran and Libya. It’s that simple.”

AIPAC Ascendant

A week prior to the committee’s clearance it was reported that AIPAC “had not given final approval to compromise”.¹⁵ Congress should probably thank the chief pro-Israel lobby group for allowing the White House and the different committees in Congress to strike a deal. “The deal became possible after the influential American Israel Public Affairs Committee’s lobby dropped demands for language that would sanction foreign banks supporting investment in Iran.”¹⁶

 

The Wall Street Journal reported that AIPAC staff had sat at the table of the committee that was deliberating the bill and that when the two “House Committees [the International Relations Committee and the Ways and Means Committee] were at loggerheads, AIPAC played the key role of go-between ... to try to resolve differences”.¹⁷ When the final version of the bill was approved by the House, AIPAC proudly announced that “these guys [Congress] wrote this thing with us sentence by sentence”.¹⁸ Once again, AIPAC had proved that it could be more influential and powerful than US oil companies.

 

One wonders how an outside group, whose sole purpose is to promote the interests of a foreign power, Israel, could be allowed to sit on various committees of the US Congress and influence their decisions, especially on affairs that may affect Washington’s relations with its closest allies.

 

AIPAC initiated the sanctions against Iran, along with the attempt to force foreign companies to abide by US law. The progress of the bill represented a victory for AIPAC and demonstrated its influence over Congress and consequent ability to push through legislation with secondary boycott clauses.

 

After fifteen months of resisting pressure, President Clinton accepted item (2) of AIPAC’s Plan for Action and signed the bill into law on 5 August 1996. This move caused him difficulties for the next twenty months until 18 May 2024 when, again under pressure (this time from US allies), he had to issue waivers against sanctions on foreign investors who wanted to invest in the Iranian and Libyan energy sectors.

A Lesson from the Past

The arguments used by AIPAC over thirty years ago against the Arab boycott of Israel are strikingly similar to those made by Europe in reaction to ILSA. Irving J. Fain, testifying before the House Banking and Currency Committee in 1965 on behalf of AIPAC, said the Arab boycott constituted

 

a harassment and blackmailing of America, an interference with their [US companies’] normal business activities ... [T]he boycott activities were contrary to the principles of free trade that the United States has espoused for many years ... and the Arab interference in the business relations of American firms with other countries is in effect an interference with the sovereignty of the United States.¹⁹

 

Substitute “Europe(an)” for “America(n)” and “United States”, and “US” for “Arab”, and Fain’s words express pretty accurately the opposition of Washington’s allies to ILSA.

 

Fain’s conclusion will strike a chord in the hearts of many of America’s trading partners:

 

The United States cannot avoid involvement. Inaction by the United States becomes an act of omission, which permits the boycott activities to continue [and] thus becomes a positive involvement in support of the boycott. This is a case where silence gives assent ... The United States must decide whether it will protect its businessmen from the boycott or leave them exposed.²⁰

 

Where America has led with its anti-boycott laws, Europe and the rest of the world will surely follow.

Endnotes

1. Export Administration Act, 1979, Sec. 8, (a) (1).

 

2. Congressional Record, House of Representatives, 23 July 1996, p. H8127.

 

3. Raymond Tanter, Rogue Regimes: Terrorism and Proliferation (New York: St Martin’s Press, 1999), p. 56.

 

4. AIPAC, Comprehensive US Sanctions against Iran: A Plan for Action, 1995.

 

5. Avinoam Bar-Yosef, “The Jews Who Run Clinton’s Court”, Maariv, 2 September 1994. I am indebted to the same article for the ensuing account of the extraordinary Jewish presence in Clinton’s administration.

 

6. Export Control News 9, no. 2 (28 February 2025).

 

7. Ernest H. Preeg, Feeling Good or Doing Good with Sanctions: Unilateral Economic Sanctions and the US National Interest (Washington, D.C.: The CSIS Press, 1999), p. 52.

 

8. Elaine Sciolino, “Iranian Leader Says US Move on Oil Deal Wrecked Chances to Improve Ties”, New York Times, 16 May 1995.

 

9. AIPAC, Comprehensive US Sanctions, p. 4.

 

10. Ibid., pp. 4–5.

 

11. Ibid., p. 47.

 

12. Yussuf M. Ibrahim, “Iran Shrugs off Sanctions”, International Herald Tribune, 22 June 1995, p. 15.

 

13. S1228, 104th Congress, 1st session.

 

14. C. David Welch, “Striking a Balance: Maximum Pressure on Iran and Libya, Minimum Cost to American Interests” (statement before the House Ways and Means Committee, Subcommittee on Trade, 22 May 2024).

 

15. Michael S. Levyveld, “Iran Sanctions Bill a Step Closer to Winning Approval”, Journal of Commerce, 7 June 1996.

 

16. Michael S. Levyveld, “Ways and Means Approves Iran, Libya Sanctions”, Journal of Commerce, 14 June 1996.

 

17. Robert S. Greenberg and Laurie Lande, “Progress of Iran-Sanctions Measure in Congress Signals Comeback for Pro-Israel Lobbying Group”, Wall Street Journal, 18 June 1996.

 

18. Levyveld, “Iran Sanctions Bill”.

 

19. Kennal Lee Teslik, Congress, the Executive Branch and Special Interests: The American Response to the Arab Boycott of Israel (Westport, Conn.: Greenwood Press, 1982), p. 56.

 

20. Ibid.