Mark Dubowitz, of the Foundation for Defense of Democracies, with tongue in cheek, explained to me why the administration acted yesterday: "To demonstrate that the administration can be proactive and not just reactionary on sanctions and to deal with the criticism that Congress has forced the administration into adopting the most forceful measures which, after initially rejecting, the administration is now embracing enthusiastically and touting their efficacy."
He nevertheless welcomed the move, however belated, which will "crack down on the various ways in which the Iranians are using payment channels both inside and outside the formal financial system in order to get access to the hard currency from oil sales that are the economic lifeblood of the regime." He argued:
The administration should take the next step of designating Iran's entire energy sector as a zone of primary proliferation concern, which would automatically blacklist every activity, transaction, mechanism, workaround, and entity used by Iran to sell its oil.
By doing so, the U.S. government will stay ahead of the Iranian regime's relentless drive to find new ways to do an end run around U.S. measures.
Also, today's designation of Kunlun under CISADA is a welcome step because it targets China's main financial conduit for Iranian oil purchases and prohibits Kunlun from setting up new banking relationships with U.S. banks. But, to be more effective, since Kunlun has no current U.S. banking relationships, and is therefore immune to U.S. pressure, the administration needs to encourage the EU to designate Kunlun and demand that SWIFT immediately expel Kunlun from the SWIFT network. That will get the attention of Kunlun, its Chinese parent company CNPC, and all of Iran's other extraterritorial bankers.
In other words, why the heck aren't we at full throttle now on all available sanctions?