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SOil Market Impact

of Sanctions Against theCentral Bank of Iran

Mark Dubowitz & Reuel Marc Gerecht

November 2011

Confdentia


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About The Authors

Mark Dubowitz is executive director of the Foundation for Defense of

Democracies. His policy work focuses on Iran and Syria, sanctions, and on theuse of technology to encourage democratic change. He is the director of theIran Energy Project which provides leading research and analysis in supportof strong, broad-based energy sanctions--including gasoline, natural gas, andoil sanctions--as part of a comprehensive strategy to end the Iranian regimespursuit of nuclear weapons, support for terrorism and human rights abuses. Italso focuses on the risks of foreign companies in doing business with the U.S.government-blacklisted Islamic Revolutionary Guard Corps, a dominant forcein the energy sector.

Mr. Dubowitz writes frequently on Iran energy sanctions issues. He is a regularcontributor to Forbes Energy Source. His work is often featured in internationalprint and broadcast media. Mr. Dubowitz co-authored past Iran EnergyProject reports, including Irans Chinese Energy Partners: Companies Eligible forInvestigation Under U.S. Sanctions Lawand Irans Energy Partners: Companies RequiringInvestigation Under U.S. Sanctions Law. He is the co-author of four condentialstudies provided by FDD to the U.S. government on: (1) the oil market impactof sanctions against the Central Bank of Iran; (2) the role of the IslamicRevolutionary Guard Corps in the Iranian crude oil supply chain; (3) the roleof the IRGC in the rened petroleum trade; and, (4) the creation of the UnitedStates as an Iranian-Oil-Free Zone to prohibit the importation into the U.S.of rened petroleum products derived from Iranian crude.

Mr. Dubowitz has testied before Congress on Iran sanctions issues and briefedthe military, government and counterterrorism ofcials on a range of nationalsecurity and terrorism-related concerns.

Reuel Marc Gerecht is a senior fellow with the Foundation for Defense ofDemocracies. He focuses on Iran, Iraq, Afghanistan, terrorism, and intelligence.

Mr. Gerecht is the author of The Wave: Man, God, and the Ballot Box in the MiddleEast (Hoover Institution Press, 2011), Know Thine Enemy: A Spys Journey intoRevolutionary Iran(Farrar, Straus & Giroux, 1997) and The Islamic Paradox: ShiiteClerics, Sunni Fundamentalists, and the Coming of Arab Democracy(AEI Press, 2004).

He is a contributing editor for The Weekly Standardand a correspondent for TheAtlantic Monthly, as well as a frequent contributor to the Wall Street Journal, theNew York Times, and other publications. He is the co-author of two condentialstudies provided by FDD to the U.S. government on: (1) the oil market impactof sanctions against the Central Bank of Iran, and, (2) the creation of theUnited States as an Iranian-Oil-Free Zone to prohibit the importation intothe U.S. of rened petroleum products derived from Iranian crude.

Mr. Gerecht served as an Iran specialist at the CIAs Directorate of Operations.

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About The Iran Energy Project

The Iran Energy Project is a project of the Foundation for Defense of Democracies (FDD).

The project (www.Iranenergyproject.org ) provides research and analysis that identies Irans energy vulnerabilities as part of a comprehensive sanctions strategy to end the Iranian regimes nuclear weaponsprogram, support for terrorism, and human rights abuses. The project also analyzes the prominent role of the

Islamic Revolutionary Guard Corps in Irans energy industry.

Companies still doing business with Iran risk being sanctioned by the United States, the European Union,Canada, Australia, and other countries. The Iran Energy Project tracks these companies using available opensources and publishes its ndings on a website that is free to the public. The website also provides breakingnews, critical analysis, and relevant legislation.

In the past year, many of Iran's major energy partners have ended their business ties with Iran. To assistgovernment ofcials with effective sanctions enforcement, the Iran Energy Project provides updates oncompanies that remain in the Iranian energy sector, as well as those that resume their business ties.

FDDs Iran Energy Experts are:

Oil Market Impact of Sanctions Against the Central Bank of Iran

Benjamin Weinthal

Fellow, Berlin

Jonathan Schanzer

Vice President of Research

Laura Grossman

Senior Research Analyst,Program Manager, Special

Research Projects

About the Foundation for Defense of Democracies

The Foundation for Defense of Democracies is a non-prot, non-partisan policy institute dedicatedexclusively to promoting pluralism, defending democratic values, and ghting the ideologies that driveterrorism. Founded shortly after the attacks of 9/11, FDD combines policy research, democracy and

counterterrorism education, strategic communications, and investigative journalism in support of its mission.

For more information, please visit www.defenddemocracy.org.

Mark Dubowitz

Executive Director

Reuel Marc Gerecht

Senior Fellow

Emanuele Ottolenghi

Senior Fellow, Brussels


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FOUNDATION FOR DEFENSE OF DEMOCRACIES

Amb. Richard CarlsonVice Chairman

Dr. Paula DobrianskyFmr. Under Secretary o State or

Democracy and Global Afairs

Steve ForbesCEO, Forbes Magazine

Judge Louis FreehFmr. Director o the FBI

Amb. Max KampelmanFmr. Ambassador

Bill KristolEditor,

Te Weekly Standard

Sen. Joseph LiebermanU.S. Senator (I-CT)

Robert McFarlane

Fmr. National Security Advisor

R. James WoolseyChairman o FDD, Fmr. Director o the CIA

LEADERSHIP COUNCIL

BOARD OF ADVISORSHon. Charles Allen

Gary BauerRep. Eric Cantor

Gene GatelyGen. P.X. Kelley

Charles Krauthammer

Kathleen Troia KT McFarlandRichard Perle

Steven PomerantzOliver Buck Revell

Bret StephensHon. Francis Bing West

IN MEMORIAMJack Kemp

Fmr. Secretary o Housingand Urban Development

Dr. Jeane J. KirkpatrickFmr. Ambassador to the UN

Cliford D. May

President

Mark DubowitzExecutive Director


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NONPARTISAN & NONPROFIT,

FDD FIGHTS TERRORISM

& PROMOTES FREEDOM

P.O. Box 33249

Washington, DC 20033-3249

(202) 207-0190

www.defenddemocracy.org

Iran Energy Projectwww.iranenergyproject.org

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FDD Oil Market CBI Report Low Res