With four sets of sanctions over the past three years, the United Nations is supposed to be leading the charge to stop Iran's drive toward the nuclear bomb. The most recent U.N. move, Security Council Resolution 1803, passed in March 2008, calls upon all U.N. member states "to exercise vigilance over the activities of financial institutions in their territories with all banks domiciled in Iran." This resolution highlights two Iranian state-owned banks as nuclear proliferators: Bank Saderat and Bank Melli.
You might, then, suppose the U.N. itself would steer clear of at least these two banks.
But in the case of Bank Melli, think again. The U.N. Children's Fund, better known as UNICEF, has been keeping an account at Iran's U.N.-flagged Bank Melli, and using that account not only for funds to be spent inside Iran, but to collect money for transfer to U.N. operations in terrorist-controlled Gaza.
Posted on the English-language Web site of UNICEF's Iran office is an invitation to make donations via Bank Melli. UNICEF includes the account number, 5005, and the location, at Bank Melli's Eskan branch in Tehran.
Nearby, on the same UNICEF site, is a link to an appeal by UNICEF's Iran office for donations for relief to Gaza, through the same Bank Melli Account ("key word: Gaza"). Gaza is controlled by a U.S.-designated terrorist group, Hamas. Dedicated to the destruction of Israel and hostile to the U.S., Hamas in recent years has been receiving training, funding and weapons from Iran.
In sum, UNICEF has been offering itself as a conduit for funds between terrorist-sponsoring, U.N.-sanctions-violating Iran and terrorist-controlled Gaza, via a bank that the U.N. itself has specifically flagged as prone to illicit nuclear proliferation activities.
Bank Melli is under sanctions by both the European Union and the U.S. Its name has emerged in U.S. headlines over the past year in connection with a host of alarming activities. These range from Bank Melli's illicit financing of nuclear proliferation, to its services as a banker to the Iranian Revolutionary Guard Corps (which is also under U.S. sanctions), to the forfeiture of an office building on Manhattan's Fifth Avenue that, according to U.S. authorities, was controlled by a front for Bank Melli.
Because the U.N. enjoys diplomatic immunity--and is itself exempt from many of the restrictions it would impose on its member states--none of this is to accuse UNICEF of anything illegal. But the choice of Bank Melli for any U.N. activities at all sets a strange example, particularly in light of the U.N.'s specific warning about the bank's involvement in sanctions-busting nuclear proliferation activities.
This choice is also disturbing in view of the U.N.'s extensive record of administrative slop--which has too often exhibited the opposite of "vigilance." U.N. officials themselves ought to know enough to be wary by now of the ways in which the organization's sprawling, erratically overseen and diplomatically immune global system lends itself to fraud and money laundering across borders.
One recent high-profile example was the 1996-2003 Oil-for-Food program in Iraq. In that case, in the name of good works, the U.N.--UNICEF included--ultimately served as both cover and partner for Saddam Hussein in his sanctions-busting network of illicit finance. Another recent case was the Cash-for-Kim scandal, which flared up in 2007 around evidence that the U.N. Development Program in Pyongyang was dispensing funds to the government of North Korea in ways that violated the U.N.'s own rules.
In what might be taken as a cautionary tale, a U.S. Senate subcommittee investigation reported in 2008 that the UNDP in North Korea had transferred funds to North Korean proliferation-related front companies. The same investigation found that North Korea had exploited accounts opened in connection with the UNDP's name to transfer millions of dollars to its embassies abroad for "housing"--though what kind of "housing" has never been publicly clarified (the UNDP has said it was unaware at the time of any wrong-doing).
But even if we assume that all funds flowing through the UNICEF account with Bank Melli have been for purely benevolent aims, the mere use of this bank by a U.N. agency sends a disturbing message. It signals that the U.N. is oddly casual about its own sanctions resolutions. "An arm of the U.N. utilizing Bank Melli should be inconceivable," says one American former national security official.
At UNICEF headquarters in New York, a spokesman says there is nothing untoward about the agency using Bank Melli. He says the Melli account has been in use since 2004, and serves as a collection point for in-country private donations. Throughput in 2008, he said, involved a relative pittance of $30,000, and donations so far this year have totaled $137,460, which includes $18,500 for the Gaza Appeal.
The spokesman adds that funds for UNICEF accumulated in Bank Melli are transferred to another Iranian bank, Bank Tejarat. It is with Bank Tejarat that UNICEF's Iran office keeps three main accounts, which last year received "total inflows from New York" amounting to $3.1 million (about two-thirds of that in euros).
Unlike Bank Melli, Bank Tejarat has not been highlighted in the U.N.'s own sanctions resolutions. But the use of Bank Tejarat is not entirely reassuring. Like Bank Melli, Bank Tejarat is owned by the Iranian government and is under sanctions by the U.S. Treasury. In a 24-page guide put out by Treasury to clarify how to comply with U.S. sanctions, one of the examples explains how a U.S. bank should treat a payment destined, via London, for a branch of Bank Tejarat in Paris. Treasury explains: "This payment must be rejected by the U.S. bank because Bank Tejarat is owned by the Iranian government, and processing the payment would be facilitating trade with Iran."
For the U.N., which routinely operates in countries that are under U.N. sanctions, there is something of a conundrum here. To bring in funds, there is sometimes no other way than to go through institutions that turn up on U.S. or European blacklists. But that is precisely one of the reasons why particular care on the part of the U.N. would be in order.
In this case, vigilance does not seem high among U.N. priorities. Asked about the account earlier this week, one UNICEF spokesperson in New York initially responded by asking where Bank Melli was listed, because "I can't find it on Google."
A more knowledgeable UNICEF spokesman then e-mailed an explanation that Bank Melli had been initially selected for use in 2004 "because with the most local branches in Iran, it was most accessible to private-sector donors including individuals and corporate entities." But that does not explain why, in the 18 months since the U.N. itself passed a binding sanctions resolution flagging Bank Melli as requiring special vigilance, UNICEF continued doing business there. Bank Tejarat, where UNICEF holds its main accounts for Iran, claims on its English-language Web site to be "maintaining 2010 branches throughout the country." In the already questionable matter of fundraising inside Iran, how many thousands of bank branches does UNICEF require?
The UNICEF spokesman in New York further stated that the Gaza Appeal ran only during March. But according to a press release dated Feb. 1, 2009, from the UNICEF office in Iran, the Gaza Appeal was running as of the beginning of February, advertising that "Iran's citizens can now also help UNICEF's efforts" by donating money via Bank Melli. As of Sept. 2, the appeal was still listed on the UNICEF Web site, still soliciting funds via the same Melli account.
Who has been putting funds into this bank Melli account? That list is not publicly available. Who oversees this scene? UNICEF is guided by a 36-member executive board whose current directors include Iran as well as a number of other countries targeted by U.N. sanctions, such as Sudan, Myanmar and Zimbabwe. According to a UNICEF spokesman in New York, monitoring of UNICEF money in Iran is "done by the UNICEF Iran office," which includes a mix of international and Iranian staff, with no transparency about either the full staff list or who handles the accounts.
There are UNICEF auditors based in New York who "travel as necessary to undertake audits." Their findings are released to the public only in generic form, with no detail about UNICEF's Iran office, let alone details of any bank transactions.
So who's really minding this store? UNICEF's American executive director, Ann Veneman, was not available for comment--though a statement from her about the plight of children in Gaza appears on UNICEF's English-language Iran Web site, alongside the invitation to donate via Bank Melli. The U.S. Treasury did not respond to queries about these matters. And the U.N. Secretary-General's office takes effectively no responsibility for activities of U.N. agencies. It also seems there is no systematic arrangement within the organization to help staffers such as those of UNICEF check transactions in order to screen out individuals and entities named in the U.N.'s own sanctions resolutions.
Behind this looms the question of what else the U.N. is doing in Iran, and with which banks. There are currently at least 11 U.N. agencies operating there--or 17, or 18, depending on which U.N. Web site you want to trust. It is a balkanized system, reporting variously to U.N. offices from New York to Geneva to Vienna and beyond; orbiting around a U.N. "resident coordinator" in Tehran, but fraught with inter-agency rivalries. There is no single desk where the buck stops.That is a weakness all too tempting for Iran to exploit.
For many Americans, UNICEF evokes childhood memories of foregoing Halloween candy to collect coins for kids less fortunate. UNICEF today is an aid behemoth with a $3 billion annual budget and global presence. Surely there must be ways for UNICEF and its fellow U.N. agencies to provide treats to impoverished children without offering regimes such as Iran's such a wide-open invitation to play tricks.