/ IHRights#Iran: Hossein Amaninejad and Hamed Yavari were executed in Hamedan Central Prison on 11 June. Hossein was arrested… https://t.co/3lnMTwFH6z13 Jun

He Who Wants the Rose Must Respect the Thorn: Examining Hydropower in Iran

22 Jun 22 by رجینا م. پائولوس
He Who Wants the Rose Must Respect the Thorn: Examining Hydropower in Iran

Iran Human Rights: Events of the last few years have made the future of the Islamic Republic more uncertain than ever. The economic crisis has pulled a large sector of society into poverty and exposed systematic corruption and the authorities’ incompetence in solving people’s daily problems. Faced with discontent, the Islamic Republic’s only recourse has been to violently repress popular protests. The question is no longer "when” but "how" Iran will transition from authoritarian rule. An unaddressed question that requires an exploration of the alternative models that may fill the power vacuum following the collapse of the Islamic Republic.

Iran Human Rights has invited experts and academics to start the discussion on "Iran in Transition" from their respective specialist fields. 

Read more about the aims of "Iran in Transition"

In this essay, Regina Paulose examines "the Future of Hydropower in Iran." You can watch Regina presenting her paper at the end of the essay at the "Iran in Transition" online conference held on 31 January-1 February 2022.

 

 

Regina M. Paulose is an International Criminal Law Attorney based in the United States. She is Co-Counsel to the Aban Tribunal, a People’s Tribunal focused on alleged crimes perpetrated during the Aban 2019 protests. She is the Editor of Green Crimes and International Criminal Law (Vernon Press) where she has also authored a chapter which discusses the impact of hydropower dams in Asia.

 

 

Abstract: While this series of articles postulates how issues could be resolved with a new governance model in Iran, entirely distinct from its current form, this article examines the future of hydropower development in the country given current issues that must be addressed. This article specifically focuses on rights and corruption as the main challenges that any new governance structure must address. Given the current global emphasis on addressing climate change and water scarcity, hydropower development in Iran will be an issue that must be examined and refitted within a realistic framework, specifically a framework that allows Iran to meet its international obligations, not only for the benefit of the environment, but for the people in the country and for stability in the region.

 

Keywords: Hydropower, Iran, water scarcity, water management, anti-corruption, UNCAC, CERD, climate change

 

  1. Hydropower’s Three Headed Problem in Iran

In September 2021, the Iran Water and Power Resources Development Company, a subsidiary of Iran’s Energy Ministry announced that it would be upgrading its existing facilities in order to produce more hydropower energy.[1]This was announced even though “recent drought and severe decline of rainfalls across the country” have caused the electricity output of hydropower plants to “decline significantly.”[2] The decrease in snow cover, which contributes water to the dams, has also declined.[3] The changes in the weather have caused rolling power cuts, 15% of which is supplied by hydropower dams, in several provinces.[4] In Iran “hydropower production has a key role in supplying the peak power demand. The first Iranian hydropower plant was built in 1961 on the Dez River. Since then, Iran has been actively developing hydropower projects. Depending on the hydrologic conditions, hydropower represents 6–15% of the nation’s electricity and is the largest renewable energy source in Iran.”[5] It is estimated that “dam projects have diverted 90 percent of the country’s water resources” to populated areas thereby causing “most of the country’s landmass has become arid.”[6] 

Experts point out that the prioritization of economic development over water management is a core problem and thereby impacts the way the Islamic Republic has responded to climate change.[7] Predictably, the current government has conditioned certain climate actions on the lifting of US economic sanctions related to the nuclear deal.[8]  Yet, despite claiming to be cash strapped,[9] the current government has continued to push for hydropower plants to be built. The number of dams in Iran after the year 2018, is projected to rise to over 1,000.[10] 

Hydropower in Iran appears to be facing three major challenges. This article will focus on two particular challenges. The first challenge is the significant rights issues that have been created as a result of poor water management policies and the proliferation of hydropower projects. Connected with the rights issue is the regional tensions that are continuing to increase as these policies also impact citizens of different countries. The second challenge is corruption. Corruption appears in many instances of hydropower development around the world. In Iran, corruption is a factor that is worsening environmental conditions. Another challenge is the enormous costs versus benefits of hydropower in Iran. This challenge will not be examined in this article because of the many factors that must be considered. Hand in hand with the issue of economics is the issue of energy consumption, with officials recently blaming illegal cryptomining as one of the contributors to the energy rates.[11]  It is estimated that Iran is responsible for 4.5% of the world’s Bitcoin mining.[12] At the start of 2022, this particular issue has also made an appearance in the Kazakhstan protests.[13]

Future leaders in Iran must reconsider its hydropower policies and more importantly reassess whether this is the appropriate “green energy” tool that is needed.

 

  1. Hydropower and the Rights Debacle 

The impacts of poor water management policies can be seen throughout the world, as hydropower growth (as a response to create energy and conserve water) has caused rights issues for humans, the environment,[14] and in some cases, led to an increase in regional tensions.[15]  Cautionary tales are littered throughout the world, but one particular case can be found in Cambodia where the Lower Sesan 2 Dam has been built. In 2012, China Huaneng Group took over the project from a Vietnamese company and China Huaneng Group did partake in any consultations with the community, most of whom are Indigenous Peoples.[16] Rather, leaders in the community have reported the “pressure” they were put under to sign predetermined terms for construction of the Lower Sesan 2. After construction of the Lower Sesan 2 was completed in 2018, it is estimated that nearly 5,000 people have been displaced, over 10,000 people who live upstream from the dam have their livelihood and food sources significantly impacted and has “caused massive damage to the ecology of rivers upstream and downstream of the project.”[17] As detailed below, the same impacts of hydropower construction are taking place in Iran and unlike in Asia, the current Islamic Republic leadership has admitted these projects have caused damage.

  1. Iran

In July 2021 in the Khuzestan province, people took to the streets to protest because of power cuts despite a heatwave.[18] The Islamic Revolutionary Guard Corps (IRGC) opened fire at the people killing dozens. The issues in Khuzestan are exacerbated by the presence of dams that were constructed in the area. In 1976, engineers noted that the Gotvand dam was not built in the 1970s due to the research that indicated the dam would “directly affect the sale concentration of the water.”[19] Despite the research, the dam was built in 2012. In 2015, the head of the Steering Committee to Desalinate Gotvand Dam called the dam “a national mistake.”[20] That same year the Supreme Court of Iran confirmed errors in the construction of the dam.[21] In 2018, an official from the Islamic Republic candidly admitted, “with this one engineering mistake, we turned Khuzestan’s water salty.”[22] The Gotvand dam is also noted for its contribution to environmental degradation in the area. In 2014, approximately 400,000 palm trees died because of the salinity of the river. The damage impacts Iran’s agriculture of dates, forty percent of which are produced in the province.[23] The impact that dams like the Gotvand have on produce was described by an expert:

“On the one hand, they have made the water salty through sugarcane agriculture and building dams like Gotvand. On the other hand, some farmers cultivate rice, which needs a lot of water. They redirect water on one hand and on the other hand, they hold water behind dams, increasing evaporation and wasting water. When the volume of fresh water falls, salty water pushes in… and when the quality of water drops, the environment is damaged. Now, both of these things have happened in Khuzestan: Both the quality of water and the volume of fresh water have gone down. The water is taken away upstream and the cultivation of sugarcane, the Gotvand Dam, and the discharge of sewage have both reduced the quality of water and made it saline.”[24]

Khuzestan’s population continues to live with the impact of the dams. Drinking water, which originates from the Karun River (where the Gotvand dam is located), has become so polluted that the health of the population is negatively affected. In addition to the outbreak of measles and other diseases, “malfunctioning sewage systems, a shortage of purified water, and the need to chlorinate water because of bacteria and the risk of disease have now become an everyday phenomenon.”[25]

Of course, another example is the ecological destruction of Lake Urmia, where the construction of dams on its basin “is the most important factor in drying up the lake.”[26] It is estimated that there are currently 40 dams in operation around the lake. In 2011, protestors raised awareness concerning the dying lake and in 2013, President Rouhani vowed to take care of the issue and allocated $5 billion USD to the infrastructure and conservation of the Lake, and prohibited dam construction.[27] By 2018, the Urmia Lake Restoration Program decided that it would carry on with “big engineering works, including a dam, tunnel, and canals.”[28] In 2021, it is reported that these promises have so far yielded conversations around sustainable agriculture and tunnels which diverted water away from the Little Zab River.[29]

In November 2021, farmers in Isfahan protested over the lack of water as a result of droughts.[30] The farmers had assembled along the now dried up river bed of the Zayanderud demanding water equality, as the Islamic Republic has opted to divert water for industries and mining instead of farming.[31] The IRGC used brute force against the farmers, burning their tents and injuring approximately 300 people.[32] The situation regarding water rationing in Isfahan has yet to resolve itself, as the only concerted action that has been taken by the Islamic Republic is to kill, detain, and torture[33] conservationists and environmentalists.

Iran is party to the International Covenant on Economic, Social, and Cultural Rights (ICESCR). Under Article 1(2), the ICESCR specifically states, “in no case may a people be deprived of its own means of subsistence.” Further, Article 11 states Iran should recognize the right to an adequate standard of living for people and their families, including adequate food, clothing and housing, and to the continuous improvement of living conditions. Hydropower dams seem to move in the opposite direction of the obligations enumerated under ICESCR Article 1 and 11. The adoption of the “Human Right to a clean, healthy, and sustainable environment” by the Human Rights Council in 2021 may also become a right that is prominently discussed as hydropower grows in Iran.[34] Further it is worth noting that in some of these provinces, the relationship between the current government and the minorities must be examined in light of Iran’s obligations under the Convention of the Elimination of All Forms of Racial Discrimination (CERD) to which it is a party. A future government in Iran must take heed of its international obligations and also make significant steps to marry its water management strategies and policies to the commitment that Iran has made at forums such as COP 26.[35]

  1. Region

The dams in Iran are causing tensions with neighboring communities, as the dams have cut off water for their use. One notable example is the Garan Dam, where construction was completed in 2013. The Garan Dam[36] sits on the Garan River but one of its tributaries is the Diyala River in Iraq which flows through Kurdistan.  The completion of the dam was predicted to have “adverse impacts” in the surrounding area, many arguing that it has sown the seeds to a “water war” as the Garan impacts the water which flows into Kurdistan.[37] In addition to the dams, Iran is also building tunnels which appears to change the course of the water flow, which they have done to almost all 40 rivers that emanate from Iran.[38] Many people who depend on the water in Iraq have seen damage to their agricultural lands and “waves of migration” are taking place out of the areas.[39] The dam that Iran built on the Little Zab River has “left 80,000 people in Kurdistan without drinking water.”[40] The Little Zab is the “primary source of livelihood for nearly two million people.”[41]  Among the list of resources the Little Zab provides includes food resources. As a result, forced migration from a shrinking river is the only real solution for many people. 

On the opposite side of the equation is how Iran is impacted by other dams in the region. For instance, people who live in Khuzestan are impacted by the dams which operate in Turkey. “Turkey’s dams across the Euphrates and Tigris reduce the flow of water into Iraq and Syria, and so into the Shatt Al-Arab, the 200-km long river which borders Iran and Iraq.”[42] Iran and Afghanistan also have their own share of water problems specifically around the Helmand River.[43]

Iraq is not a stranger to declining water levels and the impact of regional drought. Iraq has responded to the severe droughts by drilling new wells and “rehabilitating dozens of wells, installing pumping stations to deliver water to affected residential areas, and cleaning and upgrading irrigation channels to reduce water usage violations.”[44] Iraq is seeking to enter into dialogue with Iran on water resource issues, but appears now to be exploring a case at the International Court of Justice against Iran concerning the diversion of rivers.[45]  Iraq is already well versed in negative impacts of large hydropower projects as it continues to face challenges as a result of the Guneydogu Anadolu Projesi in Turkey.[46] There are no water cooperation agreements in place between Iraq, Iran, and the Kurdish areas.[47] This is something that must be considered in order to prevent further escalation in conflict.

 

  1. Corruption

Many who are well versed with the current government structure of Iran are aware the IRGC is far from a traditional military. The IRGC is overseen by its “Commander in Chief,” the Supreme Leader. The IRGC has grown since 1979 and its reach extends to almost every sector in Iran, including dam construction and water transfer schemes.[48] Many of these activities began after the Iran- Iraq War.[49] An affiliated entity of the IRGC is the Khatam-al Anbiya Construction company and its known associates which handles most of these particular energy projects in the country. It has been reported that affiliates such as Sepasad and another firm Mahab Ghodss lobbied Parliament to build more dams. They took on central roles in the construction project and both companies have been labeled the “water mafia.” The water mafia “is above the law and does not tolerate any critiques, accountability efforts to monitor or audit its activities.”[50]  Other commentators have noted similar behavior from the IRGC and its conglomerates, who “have long silenced any criticism of their dam projects...cost benefit assessments have not been made public, and one administration after another has approved the development” of the dams.

Compounding the problem of corruption is the lack of data that is available regarding dams in Iran. In 2017, Small Media issued a report which indicated that out of 1,000 dams that had been built only 100 dams had information which was complete. Small Media attributed the lack of transparency to Khatam-al Anbiya.[51] The importance of data and information sharing cannot be underscored enough. As this author noted previously, hydrological data has become of great importance to downstream countries along the Mekong River and among those countries in South Asia who are impacted by dams built by China.[52] Of course, the larger problem that corruption poses is given the Islamic Republic’s control over all water resources in the country,[53] there is limited ability for equality when it comes to rationing water supplies. Further, water could be weaponized against those who are not aligned with the current regime’s views.

Aside from the corruption which stems directly from the IRGC, people, like those who live in Khuzestan have pointed out a different form of corruption that occurs with water management. The imbalance of representation from different communities in water management discussions have led to water diversions causing distress in provinces such as Khuzestan but enriching other provinces because they are represented in the higher echelon of government.[54] This particular type of cronyism appears to be prevalent throughout the structure of the Islamic Republic.

Iran is a state party to the United Nations Convention against Corruption (UNCAC) as of 2009.  On January 5, 2022 it was reported that Iran’s Justice Minister met with the UNCAC Secretary to discuss reclamation of corrupt assets and capacities to fight corruption.[55] As this author has previously noted, UNCAC is intended to strengthen efforts at creating an anti-corruption regime and obliges state parties to criminalize corruption and its related forms.[56] It appears Iran has been taking steps to address corruption. In the summer of 2018, the Islamic Republic set up courts to specifically try people for corruption. A person who is found guilty can receive a range of punishments, including the death penalty.[57]  Recently, the IRGC’s financial scandals became public and the IRGC Commander in Tehran made no denial regarding the misuse of funds. Dr. Al-Sulami noted “the Iranian regime could find itself prompted to hold sham trials for a limited number of IRGC affiliates and figures. The aim of such trials would be to protect and uphold the integrity of the IRGC.”[58] One scholar observes, “it is an established practice in the Iranian judiciary to punish the whistleblowers and journalists who reveal cases of corruption rather than the officials who committed the corrupt actions.”[59]  

For the future, it is clear that the role of the IRGC will have to be completely reconstituted, and of course, energy development projects belong in the hands of the Environmental Department. Moreover, data and all related information to hydropower projects, and other environmental projects should follow basic parameters such as the creation and development of environmental impact assessments, the inclusion of participation of communities who have consented to projects, and the development of monitoring systems so the public can hold accountable those who mismanage their funds. 

  1. Conclusion

Any future governance model in Iran must also take into account its existing international treaty obligations. Iran is party to three international treaties to date that are relevant in the discussion concerning hydropower dams, the ICESCR, CERD, and UNCAC. Further newer rights, such as the Right to a Healthy Environment and climate change agreements should also be incorporated. It is hopeful that any transition in Iranian governance looks to utilize these treaties and others in developing sound policies around hydropower energy.  In addition, it would be fruitful for more water sharing and cooperation mechanisms to be put into place so that a more coordinated and well-balanced water policy is put into place.

Ideally, the use of hydropower in the region would stop so that the rivers could flow naturally and existing dams that cannot be maintained because of costs, should be put under consideration to be decommissioned.

 

 

[1]Tehran Times, Energy Ministry to implement program for improving hydropower plants, September 13, 2021, https://www.tehrantimes.com/news/465009/Energy-Ministry-to-implement-program-for-improving-hydropower

[2] Ibid

[3] Tehran Times, Iran short of rain by 33%, December 14, 2021, https://www.tehrantimes.com/news/468070/Iran-short-of-rain-by-33

[4] Maya Gebeily, As Iran faces ‘water bankruptcy’ drought exposes past problems, future threats, Thompson Reuters Foundation, July 28, 2021, https://news.trust.org/item/20210728093025-mzoyl/

[5] Saeed Jamali, et al, Climate Change and Hydropower Planning in the Middle East: Implications for Iran’s Karkheh Hydropower Systems, JOURNAL OF ENERGY ENGINEERING, September 2013, 153

[6] Azadeh Karimi, Iran Water Transfer Project Exposes Systematic Corruption in Management, Expert Says, Kayhan Life, October 29, 2019, https://kayhanlife.com/news/kayhan/iran-water-transfer-project-exposes-systematic-corruption-in-management-expert-says/

[7] Sanam Mahoozi, Iran’s failure to tackle climate change – a question of priority, Al Jazeera, November 9, 2021, https://www.aljazeera.com/news/2021/11/9/irans-failure-to-tackle-climate-change-a-question-of-priority

[8] Ibid

[9] Benoit Faucon and Ian Talley, Taliban Takeover is a Boon for Cash-Strapped Iran, The Wall Street Journal, August 25, 2021, https://www.wsj.com/articles/taliban-takeover-is-a-boon-for-cash-strapped-iran-11629904448

[10] Elham Hoominfar and Claudia Radel, Contested Dam Development in Iran: A Case Study of the Exercise of State Power over Local People, July 7, 2020, Sustainability, http://dx.doi.org/10.3390/su12135476

[11] Iran International, Iran’s New Record High Electricity Consumption Hard to Explain, June 30, 2021, https://old.iranintl.com/en/iran/irans-new-record-high-electricity-consumption-hard-explain

[12] United States Institute for Peace, Iran Suffers Twin Power & Water Crisis, August 3, 2021, https://iranprimer.usip.org/blog/2021/jul/13/iran-suffers-twin-power-water-crises

[13] Doksha Madhok, Kazakhstan is huge for crypto mining. Political upheaval could jeopardize that, CNN, January 7, 2022, https://www.cnn.com/2022/01/07/investing/bitcoin-mining-kazakhstan-protests-impact-intl-hnk/index.html

[14] Recent cases throughout the world have begun examining the rights of nature, particularly the rights a river may have. See Lidia Cano Pecharroman, Rights of Nature: Rivers That Can Stand in Court, Resources, 2018; 7(1):13. https://doi.org/10.3390/resources701001

[15] Gebeily at 4.

[16] Human Rights Watch, Underwater Human Rights Impacts of a China Belt and Road Project in Cambodia, August 10, 2021, https://www.hrw.org/report/2021/08/10/underwater/human-rights-impacts-china-belt-and-road-project-cambodia

[17] Ibid

[18] Struan Stevenson, A Look At The Breaking Points in Iran, International Business Times, January 9, 2022, https://www.ibtimes.com/look-breaking-points-iran-3371885

[19] Tehran Bureau, How Iran’s Khuzestan went from wetland to wasteland, The Guardian, April 16, 2015, https://www.theguardian.com/world/iran-blog/2015/apr/16/iran-khuzestan-environment-wetlands-dust-pollution

[20] Arezoo Mirzakhani, Gotvand Dam: An Environmental Disaster, Iran Wire, July 16, 2018, https://iranwire.com/en/features/5407

[21] Ibid

[22] Ibid

[23] Ibid

[24] Ibid

[25] Mahrokh Gholamhosseinpour, Forced to Migrate for a Glass of Drinking Water, Iran Wire, June 29, 2018, https://iranwire.com/en/features/5386

[26] See Ouria Mahmoud & Harun Sevinc, The Role of Dams In Drying Up Lake Urmia and Its Environmental Impacts on Azerbaijani Districts of Iran, Saussurea. 2016, 6. 54-65.

[27] Tehran Bureau, I am Lake Urmia: a social media campaign takes on the environment in Iran, The Guardian, September 22, 2016, https://www.theguardian.com/world/iran-blog/2016/sep/23/iran-lake-urmia-environment

[28] Richard Stone, After revival, Iran’s great salt lake faces new peril, Science, April 29, 2021, https://www.science.org/content/article/after-revival-iran-s-great-salt-lake-faces-new-peril

[29] Peter Schwartzstein, The return of a once-dying lake, Future Planet, February 25, 2021, https://www.bbc.com/future/article/20210225-lake-urmia-the-resurrection-of-irans-most-famous-salt-lake

[30] Stevenson, at 13.

[31] Sahab Bahar, Iran’s water is running dry. Now its water woes are worsening, Atlantic Council, December 13, 2021, https://www.atlanticcouncil.org/blogs/iransource/irans-water-is-running-dry-now-its-water-woes-are-worsening/

[32] Ibid

[33] See Al Monitor, Plight of Iranian environmentalists raised at Glasgow summit, November 2, 2021, https://www.al-monitor.com/originals/2021/11/plight-iranian-environmentalists-raised-glasgow-summit

[34] Human Rights Council, The human right to a clean, healthy, and sustainable environment, October 8, 2021, A/HRC/RES/48/13, https://undocs.org/A/HRC/RES/48/13

[35] World Health Organization, Islamic Republic of Iran reaffirms commitment to address impacts of climate change on human health and well-being at COP26, November 8, 2021, http://www.emro.who.int/iran/news/islamic-republic-of-iran-reaffirms-commitment-to-address-impacts-of-climate-change-on-human-health-and-well-being-at-cop26.html

[36] The Garan Dam recently made the news because of the body of a victim of the 2019 Aban protests which was found. See Center for Human Rights in Iran, Family of Marivan Man Found in Dam: “We are Sure He Died in Detention Under Torture” December 20, 2019, https://www.iranhumanrights.org/2019/12/family-of-marivan-man-found-in-dam-we-are-sure-he-died-in-detention-under-torture/

[37] Rudaw, Iranian Dam Projects Beginning of a Water War with Kurdistan, December 3, 2013, https://www.rudaw.net/english/kurdistan/03122013

[38] Faris al-Omran, Iraq raises the alarm on Iran’s increasing efforts to block river water, October 13, 2021, https://diyaruna.com/en_GB/articles/cnmi_di/features/2021/10/13/feature-01

[39] Ibid

[40] Rudaw, KRG partially cuts water flow to Iraq as Iran builds dam on Zab River, July 2, 2017, https://www.rudaw.net/english/middleeast/iran/02072017

[41] Kakalaw Abdulla and Dler Abdulla, Iraqi Kurdistan faces water ‘catastrophe’ as Iran cuts off rivers, Middle East Eye, September 3, 2020, https://www.middleeasteye.net/news/iraq-kurdistan-water-catastrophe-iran-rivers

[42] Tehran Bureau, at 14.

[43] Bahar, at 29.

[44] Tehran Bureau, at 14. 

[45] Ibid

[46] See Mark Dohrmann and Robert Hatem, The Impact of Hydro-politics on the Relations of Turkey, Iraq, and Syria” Middle East Journal, vol 68, no. 4, 2014, http://www.jstor.org/stable/43698183

[47] Environmental Justice Atlast, Daryan Dam and its transboundary impacts, Iran, November 29, 2016, https://ejatlas.org/conflict/daryan-dam-iran

[48] Nik Kowsar, The IRGC and Iran’s ‘Water Mafia’, MEI, February 5, 2021, https://www.mei.edu/publications/irgc-and-irans-water-mafia

[49] Frederic Wehrey, The Rise of the Pasdaran, RAND, 2009, 59, https://www.rand.org/content/dam/rand/pubs/monographs/2008/RAND_MG821.pdf

[50] Khalil Khani, Did Sanctions Cause Iran’s Environmental Problems? – Analysis, Eurasia Review, September 8, 2021, https://www.eurasiareview.com/08092021-did-sanctions-cause-irans-environmental-problems-analysis/ 

[51] Radio Farda, The Case of Iran’s Lost Dams, October 31, 2017, https://en.radiofarda.com/a/iran-dams-disappeared/28825889.html

[52] Regina M. Paulose, Hydropower and Human Rights: Revisiting the World Commission on Dams Report, IJPIEL, December 17, 2021, https://ijpiel.com/index.php/2021/12/17/hydropower-and-human-rights-revisiting-the-world-commission-on-dams-report/

[53] Austin Corona, How Mangled Dam Diplomacy is Sharing Iraq’s Water Crisis, Fikra Forum, November 4, 2020, https://www.washingtoninstitute.org/policy-analysis/how-mangled-dam-diplomacy-shaping-iraqs-water-crisis

[54] Tehran Bureau, at 14.

[55] Islamic Republic News Agency, Iran’s Justice Minister meets UNCAC Secretary, January 5, 2022, https://en.irna.ir/news/84603231/Iran-s-Justice-Minister-meets-UNCAC-Secretary

[56] Regina M. Paulose, Beyond the Core: Incorporating Transnational Crimes into the Rome Statute, Cardozo Journal of International and Comparative Law, Vol 21, No 1, Fall 2012.

[57] Erin Cunningham, Iran’s new anti-corruption courts have begun sending businessmen to the gallows, The Washington Post, November 30, 2018, https://www.washingtonpost.com/world/irans-new-anti-corruption-courts-have-begun-sending-businessmen-to-the-gallows/2018/11/29/c94a56a0-ed09-11e8-8b47-bd0975fd6199_story.html

[58] Dr. Mohammed Al-Sulami, Iran’s IRGC downplays rampant corruption and its implications, Arab News, August 31, 2020, https://www.arabnews.com/node/1727456

[59] Pooya Azadi, The Structure of Corruption in Iran, Stanford Iran 2040 Project, August 2020, https://stanford.app.box.com/s/vzsjsnp53couuw6nxtljru0qxrpb8ezf