Trump’s Iran policy: an advanced case of nuclear hypocrisy

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On 5 May last year Donald Trump signed an order pulling the United States out of the Iran nuclear agreement, and announced the re-imposition of sanctions. Walking away from the deal was one of the more contentious foreign policy promises of his presidential campaign. Enthusiastically backed by Tea Party types, many Republicans expressed reservations. Trump claims the deal was a bad one, not tough enough. Opponents on both sides of Congress have argued that the constraints imposed by the agreement successfully slowed Iran’s ability to develop nuclear weapons; US withdrawal frees Iran from such restrictions. American decertification has already led to calls for the re-establishment of a nuclear weapons programme from some sections of Iran’s political and theocratic establishments.

Eric Lorber at the Centre for a New American Security is typical of those who argue that Trump’s course of action poses considerable risks: ‘it would be difficult to reconstitute a campaign of economic pressure that brought Iran to the bargaining table in the first place. That campaign, which began in earnest in the mid-2000s, took ten years of legislative and executive action, outreach to foreign governments, and continued Iranian intransigence to have a significant impact. If the United States walked away from the agreement, our European and Asian partners have made clear that they would be unlikely to rejoin any such years-long campaign in the hopes of striking a better bargain. In such a situation, Iran would be freed from the constraints on its nuclear programme.’i

But for Trump and the supporters of his withdrawal policy, constraining Iran’s nuclear programme is not the only – perhaps not even the main – objective. He seeks to reinforce American influence in the Middle East by weakening its strongest opponent, Iran, and giving a boost to regional allies such as Israel and Saudi Arabia. Trashing the nuclear agreement, however, could end up doing the opposite – magnifying the ‘unintended consequences’ that have dogged successive western interventions in the Middle East. Sanctions could bring Iranians back onto the streets and President Rouhani’s government to its knees, but with no guarantee of a US-friendlier replacement. Either way, dramatic changes in US-Iran relations will have a knock-on effect across the region, in circumstances where Middle East politics are already in flux.

What’s the big deal?

The Joint Comprehensive Plan of Action (JCPOA) was signed in July 2015 between Iran and the five permanent members of the UN Security Council (US, China, Russia, UK, France) plus Germany, concluding two years of intensive negotiations by the Obama administration. Nuclear-related sanctions against Iran were lifted in return for strict limits on its ability to develop nuclear weapons.ii

The agreement guards against Iran developing a secret nuclear arms programme by requiring it to:

  • restrict uranium enrichment;

  • limit the numbers and types of centrifuges in operation, which separate out the different uranium isotopes;

  • substantially reduce the size of its enriched uranium stockpiles;

  • render inoperable the Arak heavy-water reactor, a type capable of producing a weapons-grade plutonium by-product; and

  • permit wide-ranging inspections by the International Atomic Energy Agency (IAEA), the UN’s nuclear watchdog.

Iran does not possess nuclear weapons; even US security agencies accept this is the case. Iranian nuclear development dates back to the 1950s, begun with assistance from the US Atoms for Peace programme. In 1970, Iran ratified the nuclear Non-Proliferation Treaty (NPT) which gives all signatories the right to pursue civil nuclear power for peaceful purposes. US claims that Iran has violated the terms of the NPT have never been satisfactorily proved.

All parties to the JCPOA agree that Iran was meeting its obligations when the US withdrew from the agreement in May this year. IAEA inspectors have repeatedly confirmed this, as have official US sources including the Department of Defence. Kelsey Davenport, Director for Non-Proliferation Policy at the Arms Control Association, is one among many who believe: ‘Without question, Iran is meeting its commitments under the deal.’iii The Council on Foreign Relations points out: ‘President Trump’s decision to withdraw from the landmark agreement jeopardises the unprecedented visibility international inspectors now have into Iran’s nuclear programme.’iv

Widely regarded as a landmark agreement, the JCPOA was a bright spot in the bleak landscape of nuclear arms control. Take the NPT as an example. The Treaty’s objective is to prevent the spread of nuclear weapons and technology. It requires non-nuclear states to refrain from pursuing nascent military nuclear uses which their civilian nuclear programmes might offer. But it leaves the nuclear weapons states to hone and modernise their arsenals. Since it opened for signature in 1968 the NPT’s primary achievement has been … 50 years-worth of talking.

Trump’s strategy unveiled

If the JCPOA is as effective as supporters claim, then why scrap it? The Middle East Forum hits the nail on the head: the accord was not in US interests because it doesn’t constrain Iran’s ‘malignant activities on the regional level’.v Secretary of State Pompeo spelled this out at length in a speech made shortly after decertification.vi Like Trump, Pompeo is a long-time exponent of trashing the deal because the ‘weak provisions’ of the JCPOA ‘merely delayed’ Iran’s capability. The Trump administration is only prepared to end sanctions if Iran agrees to:

  • permanently and verifiably abandon in perpetuity any military dimension of its nuclear programme;

  • stop enrichment and never pursue plutonium reprocessing;

  • provide the IAEA with unqualified access to all sites throughout the entire country; and

  • halt development of nuclear-capable ballistic missile systems.

Such demands are more than draconian; no self-respecting sovereign state could freely accept them; and any government that tried would face the wrath of its population. But Trump’s stipulations don’t stop at Iran’s nuclear programme. Pompeo enumerated a series of wider conditions intended to neutralise Iranian influence throughout the region. Before sanctions are lifted. Iran must also:

  • withdraw all forces under Iranian command throughout the entirety of Syria;

  • permit the disarming, demobilisation and reintegration of Shia militias in Iraq;

  • end support for Hezbollah in Lebanon, Hamas in Israel and the Occupied Territories, and the Houthi in Yemen;

  • stop attacking Israel;

  • stop firing missiles into Saudi Arabia and the United Arab Emirates;

  • put an end to its interference in international shipping and destructive cyber attacks; and

  • release all detained US citizens and those of US partners and allies.

The money released by lifting sanctions was ‘fuelling proxy wars’, Pompeo said: ‘The regime has been fighting all over the Middle East for years. After our sanctions come in force, it will be battling to keep its economy alive.’ In an increasingly globalised environment, however, unilateral sanctions could face some serious obstacles – even when they’re imposed by the world’s biggest economy. A key study in 1997, for example, found that unilateral US sanctions achieved their foreign policy goals only 13% of the time.vii

Responses to decertification

Formally speaking, the JCPOA is a multilateral agreement and remains in force despite unilateral US withdrawal. Rouhani and his ministers are looking to other JCPOA signatories to uphold the agreement and not give in to American sanctions. US withdrawal, they say, sends a message to the world that global disputes cannot be resolved through negotiation and diplomacy.

Russia has committed to remain part of the accord and said it will seek to protect its economic relationship with Iran. A statement posted on the Russian foreign ministry website when sanctions kicked in said Russia ‘will do everything necessary in the interests of preserving and fully implementing’ the JCPOA, and was ‘taking appropriate measures on a national level to protect trade and economic cooperation with Iran’.viii Another JCPOA signatory, China has also signalled its intention to defend its growing links with Iran. As sanctions got underway, a government statement asserted: ‘China’s commercial cooperation with Iran is open and transparent, reasonable and fair, not violating any United Nations Security Council resolutions. China’s lawful rights should be protected.’ix

Iran is seeking support from Europe too. The announcement that the US was withdrawing from the agreement also brought some sharp ripostes:

  • The EU’s Foreign Affairs High Representative Federica Mogherini hit out at Trump’s ‘impulse to destroy’ and called on the international community to preserve the deal.

  • German Chancellor Merkel said the agreement had been approved by the UN Security Council and should not be ‘unilaterally terminated’. She is now engaged in rounds of discussions with Iran, Russia and other signatories about what to do.

  • French President Macron ‘regretted’ the US withdrawal. His Foreign Minister insists ‘the deal is not dead’.

  • Reacting to Trump’s decertification, Britain’s then Foreign Secretary Boris Johnson said the UK remains ‘strongly committed’ to the agreement. In August his successor Jeremy Hunt signed a joint statement with other EU foreign ministers promising to help protect European companies from sanctions.

Europe finds itself in a stand-off with the United States over decertification. But sanctions are designed to make it as difficult as possible for the EU to maintain the economic relations with Iran, on which continuation of a nuclear agreement rests. The stakes are high, and European business is sceptical about the EU’s ability to nullify the force of US sanctions.

What price sanctions?

When the first tranche kicked in on 7 August, Trump tweeted: ‘Anyone doing business with Iran will NOT be doing business with the United States.’ He wasn’t kidding. A further, tougher set of sanctions is due to come into effect on 5 November. Germany and France in particular have significant economic ties with Iran, but sanctions are already taking a toll:

  • the German car maker Daimler has announced it will halt its business activities in Iran;

  • Total, the French oil giant, has said it is shelving a multi-billion dollar investment there;

  • Air France suspended all flights to Iran from 18 September; and

  • British Airways followed suit on 22 September.

The first round of sanctions is aimed at Iran’s financial sector transactions and trade in precious metals, as well as its automotive industry and some industrial processes. The second tranche will hit transactions between Iran’s Central Bank and foreign financial institutions, including petroleum-related transactions – energy, shipping, shipbuilding, and port operations.

Secondary sanctions are far-reaching, providing for hefty fines and restricted access to the US for businesses that flout them. Trump aims to bar any company that does business in Iran from doing business in the United States, and to prevent companies which do business in the USA from doing business with any company that does business with Iran. The EU has introduced new legislation designed to limit the potential damage to European companies conducting legitimate business with Iran. These ‘blocking laws’ provide for legal action by customers against businesses that disregard EU law. This legislation seeks to make it illegal, for example, for banks to withdraw services from companies doing business with Iran.

Chinese and Russian businesses are less likely to bend to sanctions. The People’s Republic of China (PRC) is one of Iran’s top petroleum customers, buying around $15 billion-worth of crude oil annually. On the same day sanctions came into force, a delegation from Sinopec, the state-owned China Petroleum and Chemical Corporation was reportedly in Tehran negotiating a $3 billion investment in the Yadavaran oil field. The PRC has been increasing imports of Iranian oil since US sanctions were lifted in January 2016 under the newly operational JCPOA.

US nuclear policy

Compare and contrast Trump’s attempted destruction of the landmark Iran nuclear agreement to his plans for the United States’ own nuclear weapons programme, highlighted by his National Security Strategy (NSS) and Nuclear Posture Review (NPR). Far from exercising restraint, it’s full steam for the biggest nuclear arsenal in the world. The Trump administration is planning to expand its nuclear reach in some chilling new directions:

  • the potential use by the US of its nuclear weapons in ‘significant non-nuclear strategic attacks’. In other words, the Pentagon will now considering using nuclear strikes in conventional war fighting situations.

  • ploughing ahead with the development of new generation, so-called low-yield nuclear weapons – smaller and more accurately targeted nukes, which recent technological advances now make possible. The US atomic bombs dropped on Japan in 1945 – killing around 250,000 people and destroying much of Hiroshima and Nagasaki – would be considered ‘low-yield’ according to this cockeyed terminology.

Trump clarified his approach to foreign and security policy at the end of his first year in office, when he published the US National Security Strategy 2017. National security is reviewed periodically; NSS statements are the means by which an American president addresses key security concerns and outlines what his administration intends to do about them. Trump describes his as ‘an America First National Security Strategy’.x

As you might expect, the tone he adopts differs considerably from that of Obama, who published two NSSs, in 2010 and 2015, reflecting their contrasting presidential styles. Obama talks about ‘confronting climate change’ and ‘seeking stability and peace in the Middle East and North Africa’; Trump refers to ‘embracing energy dominance’ and highlights ‘peace through strength’. But there are some real policy differences too.

Perhaps unsurprising in view of his unilateral action on the Iran nuclear agreement, Trump gives less weight to joint endeavours with US allies or the contributions of a rules-based international order. The UN and its agencies, the EU, the Organization for Security and Cooperation in Europe (OSCE) etc – even the NATO military alliance – receive less attention in NSS 2017. There is, too, a discernible shift in his approach to the Middle East. Trump places greater emphasis on the Israel-Palestine conflict and Israel-Iran relations. The NSS says: ‘For generations the conflict between Israel and the Palestinians has been understood as the prime irritant preventing peace and prosperity in the region. Today, the threats from jihadist terrorist organisations and the threat from Iran are creating the realisation that Israel is not the cause of the region’s problems.’

Security concerns change with the changing course of events. But the underlying stratagems of successive administrations, Republican and Democrat alike, share considerable continuity. Even Trump’s keynote slogan, America First, is old wine in a new bottle. The term was coined as long as three decades ago, after the dissolution of the Soviet Union. In early 1992 the New York Times published extensive leaks from a classified Pentagon policy document.xi It asserted that ‘the US political and military mission in the post-cold war era will be to ensure that no rival superpower is allowed to emerge in Western Europe, Asia, or the territory of the former Soviet Union’. The Pentagon made the case ‘for a world dominated by one superpower’ which maintained supremacy by ‘sufficient military might to deter any nation or group of nations from challenging US primacy’. It was dubbed the America First strategy.

A similar thread can be traced through successive US security policies right up to the present. Many of the US’s 1992 adversaries are still around in 2018; though in line with the PRC’s growing strength and importance, the NSS 2017 places a greater and more hawkish emphasis on US posture vis-à-vis China.

In keeping with Trump’s predilection for force majeure, the Nuclear Posture Review 2018 adopts a more aggressive stance towards potential conflicts, suggesting nuclear weapons will be playing a more important role in Trump’s foreign policy. They ‘may be used in extreme circumstances to defend the vital interests of the United States’. But those circumstances are no longer limited to ‘deterring nuclear threats’. A new policy unveiled in the NPR, foresees the US using nuclear weapons in ‘significant non-nuclear strategic attacks’ –that is, in conventional warfare. The NPR identifies two types of security threat:

  • an unprecedented range and mix of threats, including conventional, chemical, biological, nuclear, space, cyber, and violent non-state actors’; and

  • the re-emergence of Russia, China and North Korea as the US’s long-term strategic competitors and ‘Iranian nuclear ambitions’ are a cause for concern.

Accordingly, the US intends to develop an array of nuclear weapons ‘tailored’ to meet these different circumstances and flexible enough to do so. The US will continue work on a new generation of weapons that are more accurate but of lower yield – making them more ‘usable’. This strategy suggests Pentagon hawks are already at work on scenarios that include fighting and ‘winning’ a limited nuclear war.

And its impact on Middle East relations

Trump’s withdrawal from the Iran nuclear deal is deeply entwined with changing regional relationships – the rise of post-revolution Iran, cooling relations with Saudi Arabia after 9/11, and most important of all the position of Israel, the US’s most important strategic ally in the Middle East.

Israel

Israel is the only state in the Middle East with nuclear weapons, believed to be nuclear capable since 1967. No Israel government has ever admitted this, nor has Israel signed the NPT. We know because of the brave actions of Mordechai Vanunu, a nuclear technician who leaked details of Israel’s nuclear weapons programme to the British media in 1986. He was abducted by Mossad, the Israeli secret service, tried behind closed doors, and spent 18 years in an Israeli jail, mostly in solitary confinement. Far from attempting to denuclearise Israel, the US provides massive military aid to Israel.

Two years ago Israel signed a new military-aid agreement with the US, described as the biggest commitment of its kind in American history.xii It took place in 2016 under the Obama administration, despite his cool relations with the Israeli government. The deal runs for 10 years and is worth $38 billion over that period, an increase of around 27% on the previous military aid agreement of 2007. The Congressional Research Service describes Israel as ‘the largest cumulative recipient of US foreign assistance since World War II’.

The 2016 package was seen in part as redressing US-Israel relations following the Iran nuclear agreement which had come on stream at the beginning of the year, after IAEA inspectors confirmed Iran’s compliance. Harshly critical, President Netanyahu called the JCPOA an ‘historic mistake’. ‘Even with the deal in place, and taking the nuclear-weapon capability of Iran off the table at least for the next 10 to 15 years, there are still considerable destabilising activities that Iranians are pursuing in the region that are not consistent with US or Israeli interests or objectives,’ he had said.

Israel regards Iran as its chief protagonist. Since the Islamic Revolution of 1979, successive Israeli governments have considered the Islamic Republic an existential threat to the state of Israel. According to Yossi Cohen, head of Mossad, Israel’s National Intelligence Agency: ‘As long as the current regime exists, with the nuclear agreement or without it, Iran will continue to serve as the main threat to Israel’s security.’xiii

Trump’s presidential election campaign was in progress while the military aid to Israel was under negotiation. He promised to further strengthen US relations with Israel. Since coming to office, Trump has closed down the PLO’s Washington mission, cut off funds to UNRWA, the UN Relief and Works Agency for Palestine Refugees, stopped US aid to the West Bank, and – a clear signal to the Middle East and the world of where US loyalties lie – recognised Jerusalem as the capital of Israel and relocated the American embassy there.

Syria

A decade of US-led military interventions failed to strengthen America’s hold in the Middle East. The Arab uprisings of 2011 and the war in Syria that followed further destabilised US influence.

Israel and Syria had observed an uneasy peace since the end of the Arab-Israeli war of 1973. The Syrian conflict changed that. Russia enjoys a stable, long-time alliance with Syria, and used its Security Council veto to block sanctions and the possibility of military intervention against Assad. Iranian-backed militias provided valuable support to President Assad’s forces. Israel has clashed with Hezbollah and Iranian forces on a number of occasions. One of the first reported incidents took place in January 2013, when Israeli aircraft attacked a Syrian convoy transporting Iranian weapons to Hezbollah. Similar skirmishes occurred in 2014-15.

In 2014, the US launched air attacks against government forces, Russia joined the war a year later, and Israel stepped up its intervention. In March 2017, Syria launched anti-aircraft missiles at the Israeli-controlled Golan Heights, and in May this year, Israel carried out a large-scale rocket attack on Iranian infrastructure targets in Syria, after Iranian-backed forces fired on Israeli troops in the Golan Heights. But after more than seven years of fighting, with Russian and Iranian assistance, Assad is bringing the country back under government control, at least for the present. Assad’s military success represents a severe setback, and loss of prestige, for the United States. Defeating Iran’s strategic ally was seen by many in the west as the means of clearing a US path to Tehran. As this phase of the Syrian conflict moves to a conclusion, that ambition is no further forward.

Assad, however, has achieved his objective at a terrible cost. In seven years of war, the population of Syria has dropped from a little over 21 million to around 18 ¼ million. Over 500,000 are estimated to have died as a direct result of the fighting; at least 100,000 were civilians, and around 25,000 were children. Half the population has been forcibly displaced. The majority are now living in terrible conditions in camps across the Middle East and North Africa.xiv

The economic impact of the conflict is devastating. A World Bank report calculated the war had resulted in a cumulative loss of $226 billion gross domestic product (GDP) by early 2017 – four times Syria’s annual GDP at the start of the war. Entire cities have been reduced to rubble; over a quarter of the country’s housing stock is thought to have been destroyed, along with half Syria’s medical and education facilities. Hafez Ghanem, Middle East Vice-President of the World Bank, has said: ‘The war in Syria is tearing apart the social and economic fabric of the country. The number of casualties is devastating, but the war is also destroying the institutions and systems that societies need to function, and repairing them will be a greater challenge than rebuilding infrastructure – a challenge that will only grow as the war continues.’xv

Air attacks by the west have proved insufficient to shift the military balance, but ground troops aren’t an option. Trump wants a way out of this military conflict. Further crashing the Iranian economy with sanctions, and making withdrawal of Iranian forces from Syria a prerequisite for lifting them is an alternative means of bring Assad down.

Saudi Arabia

Alongside Israel and Iran, Saudi Arabia completes the trio of Middle East powers that dominate the region. Saudi Arabia is a long-time ally of the United States, but an opponent of Israel. Concerned about Iranian expansionism after the revolution of 1979, Saudi Arabia nowadays regards Iran as its arch-enemy. That hostility has deepened, as the regional instability that followed US intervention grew. Saudi’s relations with the United States cooled considerably after 9/11, but since the end of the decade it has attempted to smooth relations with Israel and, largely unsuccessfully, draw the US into a conflict with Iran. In this realignment that followed the rise of Al-Qaeda, Saudi foreign policy has shifted away from diplomacy and more towards military interventions, fracturing the alliances among the Gulf states.

The installation of King Salman in 2015, who then nominated Muhammad bin Salman as his successor, has handed de facto control of Saudi policy to the Crown Prince. Following Trump’s election, Muhammad bin Salman seized the opportunity to re-establish good relations, with an early visit to the US. Madawi Al-Rasheed explains: ‘Muhammad ibn Salman succeeded in establishing a momentary strong rapport with President Donald Trump and his administration, thanks to… the promise to inject funds into the US economy.’xvi

Saudi Arabia has a history of intervention in Yemen, but when it led an invasion of the country in March 2015, it presented its military aggression as a defensive measure necessary to protect its borders from Iranian expansion. Another Trump condition for removing sanctions on Iran is that Rouhani ends his end support for the Houthis and stops firing missiles into Saudi Arabia and its Gulf ally, the United Arab Emirates

Back to the future?

So brief a tour of the likely influence of Trump’s policies on the complexity of events in Iran and the Middle East is inevitably sketchy. A though-going analysis of US economic, political and military interventions in the region would require a book and a better-equipped author to write it. I hope, however, that what you’ve read demonstrates two basic hypotheses. First, that however it is dressed up and by whichever president, US policy rarely strays far from protecting American imperial interests, and that it does so with little concern for the consequences that US actions might have on the peoples and countries concerned. And second, that far from deterring aggression and keeping the peace, nuclear weapons are every bit as much an instrument for maintaining US primacy as they were when Trump’s predecessor took the decision to drop atomic bombs on a war-exhausted Japan, already suing for peace, and with as little thought for their impact on the millions of citizens in that region. But that, I suppose, is a story for another time….

Carol Turner is a vice-chair of the Campaign for Nuclear Disarmament.

This article is available in Transform #5

iNOTES

Eric B Lorber, ‘President Trump and the Iran Nuclear Deal’, Foreign Policy at https://foreignpolicy.com/2016/11/16/president-trump-and-the-iran-nuclear-deal/

ii The full text of the Joint Comprehensive Plan of Action is available at https://www.state.gov/e/eb/tfs/spi/iran/jcpoa/

iii Kelsey Davenport, ‘Trump’s Reckless Violation of the Iran Deal Jeopardizes US National Security’, Time, 9 May 2018 at http://time.com/5271040/trump-reckless-violation-iran-deal-national-security/

iv Zachary Laub, ‘The Impact of the Iran Nuclear Agreement’, Council on Foreign Relations, 8 May 2018 at https://www.cfr.org/backgrounder/impact-iran-nuclear-agreement

v ‘Spotlight: The Iran Nuclear Deal’, Middle East Forum at https://www.meforum.org/

vi Mike Pompeo, ‘After the Deal: A New Iran Strategy’, The Heritage Foundation, 21 May 2018 at https://www.s tate.gov/secretary/remarks/2018/05/282301.htm

vii Kimberly Ann Elliott, Evidence on the Costs and Benefits of Economic Sanctions, Peterson Institute for International Economics, speech of 23 October 1997 at https://piie.com/commentary/testimonies/evidence-costs-and-benefits-economic-sanctions

viii David Reid, ‘Russia slams US sanctions against Iran, promises to save nuclear deal’, CNBC, 7 August 2018 at https://www.cnbc.com/world/?region=world

ix South China Morning Post, ‘China says its business and energy ties with Iran don’t harm other countries’, 11 August 2018 at https://www.scmp.com/news/china/diplomacy-defence/article/2159285/china-says-its-business-and-energy-ties-iran-dont-harm

x President Donald Trump, National Security Strategy of the United States of America, White House, December 2017 at https://www.whitehouse.gov/wp-content/uploads/2017/12/NSS-Final-12-18-2017-0905.pdf

xi Patrick E Tyler, ‘Pentagon’s New world Order: Pentagon Draws Up Plan for US Dominance of the Post-Cold War World’, International Herald Tribune, 9 March 1992

xii Emma Green, ‘Why Does the United States Give So Much Money to Israel?’, The Atlantic, 15 September 2016 at https://www.theatlantic.com/international/archive/2016/09/united-states-israel-memorandum-of-understanding-military-aid/500192/

xiii Jerusalem Post, ‘Mossad Chief: Iran is main threat to Israel with or without nuclear deal’, 21 March 2017 at https://www.jpost.com/Middle-East/Iran-News/Mossad-chief-Iran-is-main-threat-to-Israel-with-or-without-nuclear-deal-484766

xiv Figures estimated from World Bank, Statistica, and other sources.

xv ‘War has cost $226 billion to Syria economy’, Economic Times, 10 Jul 10 2017 at

https://economictimes.indiatimes.com/news/defence/war-has-cost-226-billion-to-syria-economy-world-bank/articleshow/59532701.cms

xvi Madawi Al-Rasheed (ed), Samlan’s legacy: the dilemmas of a new era in Saudi Arabia, Hurst and Co, 2018, page 235.

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