Money and Passports: Why the Regime Has Turned to Iranians Abroad S. Rouzbeh ۱۴۰۴/۰۶/۱۱ A new council and joint-investment scheme are presented as efforts to attract capital and connect with experts, but S. Rouzbeh argues that they also serve to control the Iranian diaspora and shift political and sanctions-related risks onto people abroad. S. Rouzbeh – On 5 Shahrivar 1404, corresponding to 27 August 2025, the Islamic Consultative Assembly approved the “Supreme Council for Iranians Abroad”, with a predominantly security-oriented membership. At the same time, it authorised the Innovation and Prosperity Fund to enter into joint investments with Iranian investors living abroad, both inside and outside Iran. On the face of it, the aim is to “attract investment and build networks among experts”; in practice, however, it is a mechanism for controlling the Iranian migrant community (explained in paragraph 3) and transferring political and sanctions-related risks to people abroad in order to shore up the government’s survival and legitimacy, rather than to develop a free economy. Why now? 1) Sanctions pressure and an urgent need for foreign currency: a new round of oil and shipping sanctions has been imposed in recent days; at the same time, explicit warnings about the “risk of secondary sanctions” for any foreign institution dealing with sanctioned individuals have been repeated. In this climate, attracting dollars from Iranians abroad has become doubly important as a financial stopgap. 2) Financial and banking deadlock: Iran remains on the FATF blacklist as a “high-risk country”; this means that banking transactions with Iran are risky, even if the project is located outside Iran. 3) Managing the diaspora: The word diaspora comes from a Greek root meaning “to scatter”. In the social and political sciences, it refers to a group of people who have migrated or been driven from their homeland and are dispersed across different countries, yet remain connected to their birthplace and their national ethnic identity. Simply put, a diaspora is a nation’s population scattered beyond its country’s borders, or its migrant community. Key characteristics of a migrant community 1. Geographical dispersion: Members of the diaspora live in different parts of the world. 2. Maintaining a shared identity: Despite being far from home, they preserve their cultural, linguistic and national ties. 3. Connection with the homeland: They have an interest in, and are sensitive to, political, social and economic developments in their country of origin. 4. Political and economic influence: They often influence developments in their country of origin, whether through investment or through political and media pressure. Examples • The Jewish diaspora, one of the oldest examples, dispersed throughout the world before the establishment of Israel. • The Armenian diaspora, whose members settled across many countries after the mass killings carried out by the Ottoman government. • The Iranian diaspora, whose members migrated to Europe, America, Canada, Australia and neighbouring countries after the 1979 Revolution and the subsequent crises in the Islamic Republic, and whose numbers reach several million. Thus, when people speak of the “Iranian diaspora”, they mean the community of Iranians abroad who, despite the distance, remain involved in and connected to Iran’s fate. The recent wave of activism by Iranians abroad has pushed the government towards establishing “security frameworks”; for this reason, the council includes the Ministry of Intelligence, the Islamic Revolutionary Guard Corps Intelligence Organisation (SAS), the judiciary and the Law Enforcement Command. This means that diaspora policy-making has been defined according to a security logic. What does the resolution say? • Article 14: The “Supreme Council for Iranians Abroad” is established under the presidency of the President of the Islamic Republic, with the participation of the government’s highest-ranking security, judicial and media officials, and with a secretariat in the Ministry of Foreign Affairs. • Article 15: Authorisation for the Innovation Fund to make joint investments with Iranians living abroad to support the international development of knowledge-based companies—inside or outside the country. The article was approved by an overwhelming majority (reports cite “203 votes in favour” out of “221” MPs present). Benefits of the scheme for the government • Injecting foreign currency and addressing the deficit: The immediate aim is to bring in dollar resources from the private wealth of Iranians abroad, without requiring any genuine opening in the government’s foreign policy. • Controlling and monitoring the diaspora: By centralising decision-making under a council with a strong security component, the government can target the recruitment of “experts and investors” and monitor their networks. • A façade of legitimacy: Presenting this as “support for Iranians abroad” can be portrayed in official propaganda as a gesture of flexibility and understanding, without requiring any reform of the country’s legal or political structures. • Partially circumventing international regulations: Setting up investment mechanisms for Iranians “abroad” through government arms is an attempt to shield projects from domestic risks; however, this cover has limited effectiveness against US sanctions and FATF measures. Consequences and risks for Iranians abroad 1) Risk of secondary sanctions and criminal and financial consequences Any cooperation with government institutions or sanctioned persons—even through a third-party company in a third country—could expose you as a migrant or your financial partner to secondary sanctions (frozen accounts, severed banking relationships and legal prosecution). OFAC guidance and recent warnings from the US Treasury Department make this explicit. 2) Banking and payment risks arising from FATF The Islamic Republic of Iran is on the FATF blacklist; reputable banks and fintech companies around the world scrutinise every related transaction strictly. The result? Frozen funds, suspended accounts, higher compliance costs and the withdrawal of foreign partners. 3) Data and security risks The Supreme Council includes intelligence and judicial bodies. Any “networking platform for experts and investors” can in practice become a database used for surveillance, summonses and pressure on families inside the country. This concern is reinforced by the record of “arbitrary detention of dual nationals and foreign nationals”. 4) Travel and movement risks Independent organisations have repeatedly warned about the danger of arbitrary detention as a means of leverage; in recent weeks, countries have also issued “do not travel” warnings. Economic involvement and travel to Iran increase this risk. 5) Legal risks relating to contracts and money transfers Contract enforcement, neutral arbitration, guarantees for the return of principal and profits, currency conversion and the withdrawal of capital are all affected by government interference and sanctions. Many claims are, in practice, impossible to pursue effectively, especially when the other party is an institution with de facto immunity. (The sanctions and FATF situation intensifies this risk.) 6) Reputational risk Even the unwitting inclusion of a person or company in a chain of parties linked to sanctioned entities can disrupt permits, insurance, banking relationships and professional academic collaborations in the country where the migrant lives. The responsibilities and recommended strategy for Iranians abroad • The legal red line: Before any cooperation, independent legal advice should be obtained in writing in the country of residence on sanctions regimes (the United States, Europe, Britain and Canada), export controls and the risk of secondary sanctions. One should also check the SDN lists and the warnings issued by one’s financial regulator. • Transparency of the other party: Identify the ultimate beneficial owners (UBOs), ensure there are no links to the Islamic Revolutionary Guard Corps or sanctioned entities, and establish a transparent payment route (an unsanctioned bank, or a third country with a clear legal status). If the other party or fund is a “front”, one should not cooperate. • Rule of law in contracts: Every undertaking should be drawn up under the laws of a neutral jurisdiction (for example, English or Swiss law), with an international arbitration clause, an escrow account outside Iran, and an automatic termination clause in the event of sanctions. • Distinguish “support for the people” from “cooperation with security institutions”: If the aim of such cooperation is to support Iranian entrepreneurs, low-risk, independent and transparent routes should be chosen (for teams abroad, purchasing services from non-governmental start-ups outside Iran, and transparent, lawful academic collaboration). • Protecting family members inside Iran: Any registration in “talent and investor systems” should take account of the security consequences for relatives inside the country. Personal data should be kept to a minimum, and requests for additional documents should be declined. • The media’s civic responsibility: Sharing accounts of one’s experiences, demanding transparency from the organising bodies and warning others are all part of the diaspora’s and the Iranian migrant community’s social responsibility. Conclusion The “Supreme Council for Iranians Abroad” ploy may benefit the government in the short term, through the possible inflow of foreign currency, a show of “support for experts”, and the creation of a new channel for managing and controlling the migrant community. But for people abroad, it carries “combined risks”: secondary sanctions, banking restrictions resulting from FATF, security and data risks, and uncertainty over the enforceability of contracts. A “joint-investment” mechanism backed by security institutions and sanctioned actors under pressure from Western countries and the international community brings neither prosperity nor profit, but only danger and risk. The diaspora’s responsibility is to insist on compliance with the law and ethical standards: cooperation is meaningful only when it is legally safe, transparent, independent of security institutions and consistent with the interests of the people. Otherwise, the Islamic Republic’s “networking of experts” amounts to building a network of threats, risks and dangers for Iranian migrants and their families. Key sources: the text of the resolutions and the council’s composition (ISNA / Tasnim / IRNA / Donya-e Eqtesad); FATF status; recent sanctions and OFAC warnings; human rights reports on arbitrary arrests and travel risks Source: https://srouzbeh.com/en/posts/archive-4dc5f653-6cda-f992-fc96-4924971bfcac Please credit the author and link to this edition.