The Trump administration is threatening America’s European allies with harsh sanctions—among them, exclusion from a principal component of the global financial system—should they decide to keep doing business with Iran.

In early June, Sigal Mandelker, a previously obscure Justice Department and Homeland Security official now serving as acting deputy secretary of the Treasury Department, spoke before an audience at the Foundation for the Defense of Democracies (FDD), a Washington think tank, and fired a shot across the proverbial bow of European governments and businesses, warning, “Companies doing business in Iran face substantial risks, and those risks are even greater as we reimpose nuclear-related sanctions.”

“We will hold,” said Mandelker, “those doing prohibited business in Iran to account.”

The venue at which Mandelker spoke was only too appropriate. Described by the journalist Mark Perry as “perhaps the most powerful outside influencer of the Trump White House today,” FDD is credited, even by its opponents, as being among Washington’s most effective proponents of neoconservative ideas. In the estimation of Trita Parsi, the author of Losing an Enemy: Obama, Iran, and the Triumph of Diplomacy, “FDD certainly punches above its weight.”

Over the past several years, FDD had helped lead the opposition to the Joint Comprehensive Plan of Action (JCPOA), also known as the Iran nuclear agreement, and is currently spearheading a push to wage economic warfare not only against Iran, but also against European countries too should they decide to part from the Trump administration’s policy on Iran.

Punching Above Its Weight

In his 2015 profile of the group, journalist and author John Judis explained that in the wake of the September 11 attacks, the former New York Times correspondent turned neoconservative publicist, Clifford May, rebranded a small pro-Israel nonprofit called EMET (which is Hebrew for “truth”) into FDD, which, according to its mission, “promotes informed debate about policies and positions that most effectively end the scourge of international terrorism.”

May, who served as Republican National Committee communications director from 1997 to 2001, was recruited to head the new organization by Jack Kemp, the former GOP congressman and vice-presidential nominee.

In its early years, FDD boasted board members from both parties, including Kemp, Democratic senators Frank Lautenberg and Chuck Schumer, Congressman Eliot Engel, and Al Gore campaign manager Donna Brazile. But, according to Judis, by 2008 the Democrats bailed once FDD’s new advocacy arm, Defense of Democracies, started running ads against Democrats.

Today, FDD’s chief executive is Mark Dubowitz, a former financier who was once, according to the Israeli news site Ynet, a director of international business development for DoubleClick, which later was acquired by Google. He is said to have turned to policy advocacy after 9/11.

Dubowitz is widely seen as “the architect of many of the sanctions that we have against Iran right now, who advised Congress on how to draft that legislation and has also advised Treasury and the White House on his opinions about sanctions.” The Washington Post’s neocon blogger Jennifer Rubin calls him a “sanctions guru.”

In a recent profile, The New York Times described Dubowitz’s campaign to kill the JCPOA as “among the most consequential ever undertaken by a Washington think tank leader.” But, oddly, upon achieving his long-sought goal, Dubowitz began to furiously back-pedal, claiming he now felt “ambivalent” about Trump’s decision. Indeed, he now claims he wanted to “fix not nix” the deal all along.

According to the foundation’s website, Dubowitz and May lead a team of around 40 policy analysts and fellows who have, over the past couple of years, churned out dozens of policy papers and op-eds critical of the JCPOA. FDD fellows frequently appear on Fox News, and in the 18 months before the signing of the JCPOA in 2015, FDD fellows testified against the deal before Congress 17 times.

Among the most vocal opponents of the JCPOA has been FDD senior counselor John Hannah. Hannah, who once served as Dick Cheney’s national-security adviser, has been a tireless critic of the JCPOA. Testifying before the House Committee on Oversight and Government Reform in May 2016, Hannah declared that in the year or so after the JCPOA went into effect, “Iran’s bad behavior has only escalated.”

“The US response to these repeated provocations,” Hannah complained, “has ranged from tepid to non-existent.” Therefore, said Hannah, “it is extremely important that Congress now hold the administration’s feet to the fire when it comes to its commitment to combat Iran’s continued aggression. At a minimum, Congress should do everything in its power to ensure that Iran receives no new sanctions relief in the absence of significant new Iranian concessions.”

Hannah’s hard-line approach has apparently won him fans in the Trump administration (even though he served as a foreign-policy adviser to Jeb Bush). Reports circulated earlier this year that Hannah was close to being offered the role of US envoy to Syria but he ultimately declined.

Perhaps the most prolific member of the FDD gang is Reuel Marc Gerecht, who served as a CIA case officer from 1985 to 1994 and went on to become a contributing editor at The Weekly Standard as well as a fellow at the American Enterprise Institute before joining FDD.

Gerecht, who once quipped that he’s “written about 25,000 words about bombing Iran,” has criticized the Iran deal as being “as holey [sic] as Swiss cheese”; “the worst arms-control agreement since the Washington Naval Treaty of 1922”; and not “really an arms-control agreement; it’s just cover for American inaction.” In the days leading up to Trump’s announcement, Gerecht alone published three successive articles critical of the agreement, on May 4, 5, and 6 in The Atlantic.

The reason Gerecht and his FDD colleagues consistently engage in such rhetoric is easy enough to figure. As perhaps the nation’s leading critic of neoconservative foreign policy, Andrew Bacevich, told me, “fearmongering,” such as that coming from FDD and the American right wing generally, serves to “incite panic about Islamism, with Iran today having become the big bugaboo.”

“In Washington,” says Bacevich, “promoting hysteria works.”

It works, and it also pays. A review of FDD’s last publicly available IRS 990 (2016) reveals that this relatively tiny operation received more than $9 million in contributions, with May and Dubowitz each pulling in over $500,000 that year.

And while information regarding the identities of recent FDD donors remains obscure (though an FDD spokesman did tell me the group receives no foreign funding), Home Depot founder Bernard Marcus and US Healthcare founder Leonard Abramson are listed as board members. Marcus and Abramson, along with the likes of Seagram heir Edgar Bronfman Sr. and Sheldon Adelson, have reportedly given generously to FDD in past years. For example, the Nation Institute’s Eli Clifton found that in 2011, Marcus alone had donated over $10 million to the Foundation.

FDD is not only a staple on op-ed pages and cable news networks like Fox; it has diligently built up a network though its own National Security Fellows Program, a 12-month fellowship “for the next generation of U.S. national security leaders,” which was headed from 2009 to 2014 by none other than former Trump adviser Sebastian Gorka (whose profile has since been removed from the FDD website).

Part of the reason for FDD’s recent success is that it has, unlike many other think tanks and groups, been able to retain access to the White House.

Its recipe for success, according to Trita Parsi, is that FDD “has not uttered a word of criticism of Trump and his policies—and it is a price they seem willing to pay in order to influence Trump.”

An early example of FDD’s potential influence in Trump’s Washington was an event the group held last October at the St. Regis hotel on 16th St. that featured then–CIA director (now Secretary of State) Mike Pompeo and then–national-security adviser H.R. McMaster. According to Curt Mills of The National Interest, the two officials were given a “hero’s welcome,” and the sentiment was clearly reciprocated. Said McMaster, “We need FDD’s help.… We need organizations like FDD to continue their scholarship on the threats that we face.”

There was a lot of love in the room that day. About his hosts, McMaster gushed, “I love FDD.” FDD’s Juan Zarate, who advised Pompeo during his confirmation hearing to be CIA director, proclaimed of Pompeo, “Frankly, I love the man.”

Only days following the event at the St. Regis, the CIA provided FDD’s Long Wars Journal an advance copy of previously classified files obtained during the raid on Osama bin Laden’s Abbottabad compound which, claimed FDD’s Bill Roggio and Thomas Joscelyn, contained “new details concerning al Qaeda’s relationship with Iran.”

Dubowitz’s disingenuous claims to be a “fixer” not a “nixer” to the contrary, it is clear that FDD has emerged as one of the leading cheerleaders of the Trump administration’s increasingly hard-line policy toward Iran.

Prior to May 8, the day Trump announced he was going to violate the terms of the JCPOA, FDD helped lead the opposition to the agreement, issuing a flurry of “Chicken Little” warnings on everything from the inadequacy of the agreement’s “sunset” clauses to the looming threat of Iranian expansion and aggression. Testifying before the House Foreign Affairs’s Middle East and North Africa Subcommittee, FDD senior adviser Olli Heinonen declared that “the time to act is now, and not six years from now when the sunset clauses begin to take effect. It will be far harder to fix the deal once sunset clauses help Iran to permanently establish itself as a threshold nuclear state.”

Next Year in Tehran?

Now, having won the battle over the JCPOA, FDD is on to bigger things, what Barbara Slavin of the Atlantic Council’s Future of Iran Initiative described to me as a “campaign of maximum pressure against the Iranian government and the Iranian people.” And one of the pressures that FDD is looking to apply on Tehran comes in the form of sanctions.

Sigal Mandelker’s June 5 speech was only one example of how, over the past several weeks, FDD has begun proselytizing for harsher sanctions on Iran. On May 21, Dubowitz and FDD senior adviser Richard Goldberg took to the pages of The Wall Street Journal to suggest that Trump place sanctions on “Iran’s mining, construction and engineering industries, and any other sector of strategic importance.” Goldberg and Dubowitz also urged the Europeans to take action by cutting off the Central Bank of Iran from the SWIFT financial network, a move opposed by German Chancellor Angela Merkel.

A month later, on June 20, Goldberg and Dubowitz returned to the Journal with a warning to the Germans and other European allies who want to keep Iran connected to SWIFT: Should European Union members use SWIFT to send direct payments to the Central Bank of Iran, Goldberg and Dubowitz believe the Trump administration should retaliate. Trump should designate the offending “European country’s central bank as a violator of sanctions, blocking its access to dollars and isolating it from the international financial system.”

The authors do allow that “such steps may seem draconian.”

Indeed. Undermining the global financial system in order to sanction a country, Iran, that is in full compliance with a multilateral agreement, the JCPOA, that we ourselves are in violation of does seem a bit draconian.

Of course, the ultimate goal of killing the nuclear deal and engaging in renewed economic warfare against Iran is, as a number of FDD analysts openly acknowledge, regime change in Tehran, a goal that Col. Lawrence Wilkerson (ret.), who served as Secretary of State Colin Powell’s chief of staff (2002–05), derides as “absurd.”

Absurd, yes. Perhaps even delusional. But not so to M Street’s warrior kings, who informed the White House in a June 2017 memo that “the very structure” of the Iranian regime “invites instability, crisis and possibly collapse.” Nor to Gerecht, who believes that “everybody wants to see regime change in Iran.”

And yet, as Wilkerson points out, the problem with regime change is that, “regardless of the nature of the regime in Tehran—theocratic or a Jeffersonian democracy or somewhere in between—that regime is going to have roughly the same foreign policy as the current one. It is just the nature of power and security.”

Wilkerson points out that “the Shah wanted a nuclear weapon, for example, and we almost gave him one!”

Despite what FDD’s analysts say over and over again, Parsi is skeptical that regime change is really what they’re really after—indeed, Parsi suspects their goal might be something worse: regime collapse.

“If Iran becomes a successful democracy,” Parsi explains, “Iran’s power will likely grow significantly. Efforts to isolate and sanction it will become more difficult. The balance of power in the region would shift even further to its benefit. None of these are positive developments for FDD.”

“Rather,” says Parsi, “their goal appears to be regime collapse and prolonged chaos and instability in Iran. Short of war, only that would shift the balance of power in the region toward Israel, whose interests FDD appear very concerned about.”

Critics have often accused FDD of being little more than a stalking horse for Israeli interests in Washington. But Judis noted in his profile of the organization that he had seen “no evidence [Clifford] May and FDD ‘take instructions’ from the Israelis.”

But what is clear is that FDD, awash in funding by stalwart advocates of Israel, has adopted policy positions that rarely—if ever—deviate from the preferred policies of Israeli Prime Minister Benjamin Netanyahu’s right-wing Likud party. As one longtime Iran policy hand quipped to me recently, “They really should be called the Foundation for the Defense of Likud.”

And it is true that FDD’s position on the Boycott, Divestment and Sanctions (BDS) movement for Palestine as well as its enthusiastic reaction to Trump’s reckless decision to move the US Embassy to Jerusalem also reflect the predilections of the Israeli right wing.

But nowhere else has FDD’s pronounced tendency to echo right-wing Israeli policies manifested itself more clearly than in its advocacy for greater American involvement in the war on Syria.

Writing in (where else?) the New York Post in April, Goldberg complained that because Iran’s military presence in Syria has expanded, “America needs more than a once-a-year cruise-missile strike to defend the full range of our national-security interests.”

For Goldberg, it is imperative that the United States, in his words, “re-establish a robust military deterrent toward Iranian expansionism in close collaboration with regional allies.”

But the very concept of Iranian expansionism, says Wilkerson, “is a bugbear created by Bibi Netanyahu and [Israeli defense minister] Avigdor Lieberman to frighten Israelis.” Wilkerson then went on to note the great disparity in military spending between the United States and Israel (a combined $670 billion) and Iran ($6.3 billion).

Like Goldberg, Gerecht sees Iran as the prime mover behind the Syrian conflict. Writing in The Atlantic on May 4, Gerecht criticizes Obama’s unwillingness “to do anything to brake the Islamic Republic’s rising Shiite imperialism, which in Syria led to the massive slaughter and flight of Syrian Sunnis who’d rebelled against Bashar al-Assad’s tyranny. And what happened in 2012-13 in Syria and Iraq—with the absence of America—triggered the rise of the Islamic State.”

But Wilkerson says this is simply hogwash. “What led to ISIS, plainly and simply,” he says, “was the 2003 US invasion of Iraq, the attraction to Iraq of Al Qaeda because of the invasion, the selection by bin Laden of Abu Musab al-Zarqawi to run Al Qaeda-in-Iraq, and the utterly stupid US decision to disband the Iraqi military which drove thousands of Sunnis to make common cause with Al Qaeda.”

Over the past year, FDD has shown that a relatively small, well-funded, and savvy interest group can help propel the administration to unapologetically implement a widely unpopular policy, like withdrawing from the JCPOA. Its ties to powerful administration insiders like Pompeo, combined with a seemingly open-ended invitation to testify before Congress, thanks to close ties to the GOP establishment and hawkish Democrats like Senator Bob Menendez, all translate into policy influence.

FDD’s fearmongering and rank hysteria over Iran may fuel its bottom line and help shape the dominant narrative, but, as Bacevich notes, among the immediate casualties of such an approach “is reasoned discourse.” FDD’s advocacy also brings to mind Albert Camus’s observation that “mistaken ideas always end in bloodshed, but in every case it is someone else’s blood. That is why some of our thinkers feel free to say just about anything.”

Meanwhile, in the face of recent history, evidence, and common sense, FDD continues its push for regime change in Iran. And, worryingly, it seems to be making progress toward that end.

Correction: An earlier version of this article misstated John Hannah’s employment history. He never worked as an aide for John Bolton. The text has been corrected.