by Omri Schwartz

Shooting Ourselves in the Foot: The Comprehensive Iran Sanctions Act – It’s Devastating Effects on an Already Depressed Job Market in the USA

H.R.2194 – Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 that President Barak Obama signed back in July took effect Sep. 29, 2010. Under the newest guidelines of this law many small businesses are bound to close, sending droves of newly unemployed people to the dole. Taking the antique rug market as an example, here are a few of the issues at the core of the matter:

(1)    No Exportation of Persian-made goods — The Office of foreign assets control / the US Treasury issued a new guideline: no exportation (to any country even if the buyer has no ties to modern day Iran) of any Persian made goods without an exportation license even if they are 500 years old and have been in the USA for the past 450 years. The exportation license may take upwards of six months to be reviewed and there is no guarantee that it will be approved. So even if buyers from Europe come to America, walk into an Antique Carpet Gallery in New York and would like to acquire an item (some of them may be priced well over $100,000)  they will most likely back out since they have no idea whether or not they will be able to receive the item.

(2)    No importation of Persian-made goods — Even if the item hasn’t been in Iran for over 500 years – This is somewhat understandable since the government does not have any true experts on hand.

(3)    Congress’ unwillingness to work with small business and the lack of representation in government — The people at the Nazmiyal Collection in NY have been trying to work with both Sen. Schumer’s (D. NY) & Congresswoman Carolyn B. Maloney’s (D. NY) offices for the past few months, but the responses have been lukewarm at best. At first we were informed that exportation was legal so we made a proposition to allow businesses a 30 day export license for a particular item. This will enable dealers to sell their items to overseas buyers on an “approval” basis and if the buyer decided not to acquire the items then they will have the right to send back the items within 30 days of export. After speaking with the Treasury, it was made clear that exportation was in fact not legal. In essence closing up the option of selling these items to any party overseas even if the buyer is in London, Paris or Milan.

Despite the government’s economic stimulus packages the U.S. economy is still extremely depressed with an unacceptable unemployment rate. In the case of Antique Persian carpets (those that are at least 80 years old), these pieces were woven for export purposes so an overwhelming percentage of them have nothing to do with modern day Iran. Unless quick and decisive action is taken by lawmakers to amend the law and allow businesses to sell their goods, the new sanctions will inevitably deal a crippling blow to many people and businesses. With a significant recession and high unemployment rates, every job matters and if foreign markets remain inaccessible, managers will be forced to cut hours and layoff staff in the very near future. With declining sales, valued employees will have to be let go to help reduce overhead in a slow market. Secretaries, sales personnel, bookkeepers, professional carpet restorers, and many other workers could soon see their last paycheck if international sales avenues continue to close.

Contrary to the intentions to protect the nation’s interests, sanctions affecting the international resale of antique Persian carpets do nothing to cut-down on the funding of Iran’s anti-American activities. In effect, the new regulations will result in lost jobs and lost income if local representatives ignore the problem and don’t make it easier for antique Persian carpets to be exported to buyers overseas.

We took the antique rug market as an example but the same is to be expected to happen in any aspect of antique Persian made goods affecting large companies such Christies & Sotheby’s (who rely on American buyers for their overseas sales and overseas buyers for their USA sales) to the smaller privately owned business such as the Nazmiyal Collection in NY.

The Nazmiyal Collection does strongly support the economic sanctions against Iran and are only requesting a streamlined export process and 30-day window for returns so buyers can see the items in person and feel comfortable before committing to a substantial financial investment. They were even willing to assist government officials in drafting up the protocols and suggested that a filing fee be added to cover the expenses that these new regulations might cause. So far representatives from the offices of New York State Senator Charles E. Schumer and Congresswoman Carolyn B. Maloney have been little to no help (just getting a response from the office took numerous contact attempts and weeks of waiting). Also, none of the emails that were sent to the Whitehouse or the secretary of state’s office have even been acknowledged.

So as a last resort — since our own elected officials have so far been unwilling or unable to step up to save countless jobs — we hope you, the true voice of the people, will come to the aid of the many future unemployed workers that need your help. All we ask is to continue to conduct business as long as modern day Iran does not benefit in anyway.