2017年-IMF国际货币组织全球_Islamic_Republic_of_Iran_Selected_Issues_48页_1mb

Summary of Selected Issues on the Islamic Republic of Iran

Core Content

This document presents an analysis of several key issues facing the Islamic Republic of Iran, focusing on correspondent banking, monetary policy reform, fiscal reforms, and international taxation. It provides an overview of the challenges and potential policy options for Iran to re-integrate into the global financial system and improve its economic framework.

Correspondent Banking Challenges

Key Points

• Sanctions Impact: Iran has faced extensive economic sanctions over the past decade, which significantly damaged its correspondent banking relationships (CBRs), disconnecting it from the global financial system and disrupting trade and remittance flows.
• Sanctions Relief: The Joint Comprehensive Plan of Action (JCPOA), implemented on January 16, 2016, led to partial relief from sanctions, particularly from the EU and U.S. secondary sanctions, allowing some reconnection to the international financial system.
• Remaining Sanctions: Despite relief, U.S. primary sanctions and the SDN list continue to restrict non-U.S. financial institutions from engaging in certain transactions with Iran. Additionally, the U.S. dollar clearing restrictions and the possibility of "snap-back" sanctions pose ongoing challenges.
• FATF Listing: Iran remains on the FATF "black list" due to deficiencies in its AML/CFT framework. This listing imposes countermeasures that hinder full reconnection to global banks.
• Progress Made: Following the JCPOA, over 238 small and medium-sized international banks have established CBRs with Iranian banks. SWIFT reconnected the Central Bank of Iran (CBI) and 15 non-sanctioned Iranian banks in February 2016, improving cross-border payment services.

Challenges to Full Reconnection

• Sanctions Complexity: U.S. and EU sanctions are not fully aligned, creating compliance difficulties for global banks. Some U.S. states also impose restrictions on companies engaging in business with Iran.
• Compliance Costs: Global banks face high compliance costs due to strict enforcement measures, including fines for violations. This has made CBRs less profitable.
• AML/CFT Deficiencies: Iran needs to improve transparency and strengthen its AML/CFT framework to be removed from the FATF list and fully re-integrated into the global financial system.
• Entity Transparency: Many Iranian corporations lack transparency, making it difficult for foreign banks to identify beneficial owners and comply with regulations.

Policy Options

• AML/CFT Reforms: Iran must enhance its AML/CFT framework, including improving entity transparency, conducting a national risk assessment, and implementing a risk-based supervision system.
• Compliance Enhancements: Iranian banks should improve their internal AML/CFT controls, receive technical assistance, and pursue external certification to build trust with correspondent banks.
• FATF Engagement: Continued engagement with FATF and meeting its action plan deadlines will be critical for Iran to demonstrate progress and potentially be removed from the "black list."

Monetary Policy Reforms

Key Points

• Current Framework: Iran's monetary policy is guided by the Money and Credit Council (MCC), which prioritizes government credit policies over inflation control. The CBI lacks effective tools to manage inflation, as liquidity is controlled through rationing rather than pricing.
• Inflation Trends: Iran has experienced high and volatile inflation, especially during the sanctions period. While recent policies have reduced inflation to single digits, continued monetary expansion threatens to reverse these gains.
• Interest Rate Corridor: The current interest rate corridor is wide, with the CBI's borrowing rate at zero and its overdraft rate at 34%, limiting the CBI's ability to implement a more effective monetary policy.
• Exchange Rate Policy: The exchange rate has long been the nominal anchor for Iran's monetary policy. The authorities aim to unify the foreign exchange market and transition to a managed float, which would require a more market-based monetary policy framework.

Reform Steps

• Modernization: The CBI is moving toward a market-based framework, focusing on the interbank market for liquidity management. This includes injecting liquidity and targeting interbank rates.
• Policy Rate: Establishing a regular funding facility and a specific policy rate is essential for a more effective monetary policy.
• Financial Sector Reform Plan: Iran's Financial Sector Reform Plan includes improving oversight, regulating unlicensed institutions, and strengthening credit markets through diversification of funding sources and prioritizing SME financing.

Fiscal Reforms

Key Points

• Spending Pressures: Iran faces significant spending pressures due to its large public sector and subsidies. This has led to fiscal imbalances and unsustainable debt levels.
• Medium Term Fiscal Framework (MTFF): A MTFF is envisioned to improve fiscal sustainability and reduce the reliance on subsidies. This would involve setting clear fiscal targets, improving revenue collection, and managing public spending.
• Implementation Challenges: The MTFF requires strong institutional capacity, political will, and public support. It also involves addressing fiscal risks such as revenue volatility, rising debt, and potential external shocks.

Policy Recommendations

• Fiscal Consolidation: The MTFF aims to reduce the fiscal deficit and improve the efficiency of public spending.
• Reforms to Improve Revenue: Enhancing tax collection and reducing tax evasion will be crucial to support the MTFF.
• Public Spending Reforms: Reducing subsidies and improving the efficiency of public services will help stabilize the economy.

International Taxation

Key Points

• Tax System Integrity: Iran has made efforts to maintain the integrity of its tax system, including improving domestic legal frameworks and expanding its tax treaty network.
• Tax Incentives: Iran offers investment tax incentives to attract foreign investment, although these are limited in scope and effectiveness.
• Cross-Border Payments: Domestic taxes on cross-border payments create challenges for international transactions and can affect the competitiveness of Iranian businesses.
• Re-Allocation of Tax Cost: There is a need to re-allocate tax costs to reduce the burden on businesses and improve the efficiency of the tax system.

Policy Options

• Enhancing Tax Transparency: Improving the transparency of tax systems and reducing the complexity of ownership structures will help foreign banks and investors comply with regulations.
• Expanding Tax Treaties: Strengthening the tax treaty network will reduce double taxation and improve the business environment.
• Reforming Domestic Taxes: Reducing taxes on cross-border transactions and improving the efficiency of the tax system will enhance Iran's attractiveness to international investors.

Conclusion

The Islamic Republic of Iran faces significant challenges in re-connecting with the global financial system due to ongoing sanctions and deficiencies in its AML/CFT framework. However, the JCPOA has provided some relief, and progress has been made in re-establishing correspondent banking relationships. Further reforms in AML/CFT, monetary policy, and fiscal management are essential to ensure sustainable economic growth and re-integration into the global economy. International cooperation, transparency, and alignment with global standards will be key to overcoming these challenges.