Whatever pain COVID-19 inflicts, it offers a golden opportunity for Washington lobbyists committed to tough sanctions against Iran. ‘Regime change’ or ‘regime collapse’, they say, is now within grasp if only the United States stands firm.
United States sanctions have not just spawned a proliferating industry profiting lawyers, bureaucrats and “expert” consultants. They have created an opaque maze around which “bullet points” bounce from lobby groups and “think tanks” to the media to government, becoming “facts” through repetition and circular sourcing.
Leading the Iran intervention lobby is the Foundation for Defense of Democracies (FDD). Its CEO Mark Dubowitz is tireless on Twitter and in the media. As the pandemic helps blur any line between opinion and facts, FDD can more easily market its paid advocates as “experts” purportedly moved solely by evidence.
On April 5, FDD published a “research memo” entitled “Should the United States Lift Sanctions on Iran to Address Its Coronavirus Outbreak?” The answer, unsurprisingly, was no.
The memo opens with the claim that “Iran is the epicenter of the coronavirus in the Middle East.” This reflects “the regime’s mismanagement” of the response and failure to “take precautionary measures.”
Iran spread COVID-19 to Lebanon, FDD claims, based on credible reports that the virus arrived with an infected air passenger from Iran. Why single out Lebanon? Because one of Iran’s top regional allies, Hezbollah, is in the government. So the FDD memo quotes May Chidiac, a Lebanese journalist and former cabinet member, blaming Hezbollah for delays in stopping flights from Iran. The FDD memo notes, apparently without irony, that Chidiac herself tested positive for COVID-19 after returning from Paris.
All epicenters are equal, but some are more equal than others. At the time the FDD memo was published, COVID-19 cases in the U.S. were surging and so was the death toll. Of course, FDD didn’t call the U.S. an “epicenter” nor criticize President Trump for “mismanagement” or the failure to “take precautionary measures.”
But whether or not Iran stands alone in corruption or mismanaging COVID-19, should the U.S. ease sanctions against Iran for the pandemic’s duration, as suggested by the World Health Organization (WHO)? Should President Donald J. Trump respond positively to an open letter from 24 former senior diplomats and defense officials from European and the U.S. asking his administration to mitigate sanctions in order to save “potentially the lives in hundreds of thousands” in Iran and worldwide?
FDD says no. This is firstly because Iranian President Hassan Rouhani reportedly claimed Iran can produce everything it needs for COVID-19. Similar claims have been made, with equal credibility, by many leaders round the world: Trump has been especially forthright in pooh-poohing international co-operation.
Secondly, Iranians actually want sanctions. Dubowitz, who has apparently never visited Iran, understands how all Iranians think. “The Iranian people know this is the wrong time to give sanctions relief to this regime,” he tweeted in a video on March 27.
FDD also claims that U.S. sanctions don’t target humanitarian goods, asserting that Iran’s response to COVID-19 has been unaffected by U.S. sanctions. As evidence, FDD says European Union pharmaceutical exports to Iran declined only 5 percent (€738 million to €698 million) in the “first full year after the re-imposition of U.S. sanctions in 2018,” a period when total EU exports nearly halved (€8.9 billion in 2018 to €4.5 billion).
Given that the U.S. ramped up sanctions in November 2018, six months after Trump withdrew from the JCPOA in May, FDD contends that a year-on-year comparison of 2018 to 2019 “provides a good, though imperfect, approximation of the sanctions’ impact.”
But the European Commission web page shows that EU exports to Iran had already fallen in 2018 as businesses anticipated an escalation in U.S. sanctions even before Trump abandoned the JCPOA. EU pharmaceutical exports to Iran in 2016 came to €888 million before falling to €750 million in 2019, a drop of 16 percent and three times the figure cited by the FDD.
Moreover, an October 2019 report by Human Rights Watch (HRW) found that U.S. exemptions for humanitarian goods did not offset the reluctance of either U.S. or European companies and banks to risk U.S. sanctions by exporting or financing humanitarian goods
The HRW report concluded that sanctions since 2018 “pose a serious threat to Iranians’ right to health and access to essential medicines” and have “almost certainly contributed to documented shortages — ranging from a lack of critical drugs for epilepsy patients to limited chemotherapy medications for Iranians with cancer.”
Earlier this month, HRW was more specific, pointing out in a news release that the definition of drugs under U.S. export regulations “excludes certain vaccines, biological and chemical products, and medical devices — including medical supplies, instruments, equipment, equipped ambulances, institutional washing machines for sterilization, and vehicles carrying medical testing equipment. This means that some of the equipment crucial to fighting the virus, such as decontamination equipment, and full-mask respirators, require a special license.”
HRW cited research by the Washington Post showing that the rate of approvals by the U.S. Treasury for special licenses for the export of medicine and medical devices to Iran had declined by over 50 percent during the first quarter of 2016 to 10 percent during the first quarter of 2019 – a drastic decline that makes it very difficult to conclude that U.S. sanctions have had no impact on Iran’s response to COVID-19.
What of FDD’s call for any aid to Iran to go through “reliable” NGOs? Relief International, an NGO operating in Iran with a U.S. Treasury license, has itself complained that international aid to Iran during the early part of the crisis was hampered by delays in clarifying legal issues over sanctions.
In a detailed letter to the Lancet, Britain’s most authoritative peer-reviewed medical journal, published April 6, five public health experts in London and Tehran, including a deputy Iranian health minister, wrote: “Even before COVID-19, Iran's health system was feeling the effect of the sanctions. Their impact is now severe because they restrict the government’s ability to raise funds or to import essential goods. Of the ten countries with the highest number of recorded cases of COVID-19 to date, Iran is the poorest.”
“Essential medicines and medical equipment are technically exempt from sanctions, but their availability is restricted by the effect of sanctions…reducing manufacturing and trade capacity, and on foreign exchange,” according to the letter. “Consequently, although approximately 184,000 hospital and primary health-care staff are working to fight COVID-19, their efforts are thwarted by shortages of test kits, protective equipment, and ventilators. WHO has provided crucial supplies, sufficient equipment for 31,000 workers, but supplies are still substantially short of what is needed.”
The five authors backed the easing of U.S. sanctions for the pandemic’s duration, citing a likely fall in world economic growth: “The harsh obstacles presented by US sanctions mean that Iran could bear a disproportionate share of this fiscal and health shock, leading to its probable economic collapse and inability to contain the virus that has implications for the entire world.”
But collapse may suit the FDD. Eric Edelman, FDD senior advisor, recently argued in Foreign Affairs that “economic collapse” leading to “regime change” should be a goal of U.S. policy.
While FDD’s arguments sit uneasily with some of the findings of public-health professionals, they are often echoed in official U.S. documents. On the same day that the Lancet article was published, for example, the State Department released a “fact sheet” entitled “Iran’s Sanctions Relief Scam.”
It began by quoting President Trump’s words of five days before: “I think the Iranian [people] love America. I think they’d love to be free…They love what we stand for…if they need help with respect to the virus, we have the greatest medical professionals in the world. We’d love to send them over.”
The “fact sheet” continues: “New graffiti in a Tehran suburb reads ‘The Islamic Republic in Iran is the real coronavirus.’”
“Iran’s slick foreign influence campaign to obtain sanctions relief is not intended for the relief or health of the Iranian people but to raise funds for its terror operations. Since 2012, the regime has spent over $16 billion to fund its terror proxies abroad while Iranian healthcare services have remained woefully underfunded,” the document claims.
This $16 billion figure, which is also quoted in FDD’s memo, goes unexplained. Even if true, the total compares unfavorably with the amount of weaponry Washington transferred to Iran’s chief regional rivals, including the more than $30 billion the U.S. has provided Israel in military aid and nearly $22 billion in actual arms transfers to Saudi Arabia and the United Arab Emirates during the same period (not including existing contracts to sell tens of billions of dollars more in arms to the latter two countries both of which have been accused of war crimes and crimes against humanity in their five-year-old mlitary intervention in Yemen’s civil war).
Away from the Washington DC regime change lobby scene, what is the situation on the ground in Iran?
Those I spoke with paint a mixed picture. Some criticized government officials, the security forces, and the many Iranians who took off on holiday to the Caspian during the pandemic. But some also praised the professionalism and commitment of health workers – a contrast in Iran, as elsewhere during the pandemic, to leaders eager to blame others.
Djavad Salehi-Isfahani, Professor of Economics at Virginia Tech, paid tribute to the sacrifices and achievements of Iran’s health workers in Foreign Policy in March:
“Iran’s health sector has a distinguished past under the Islamic Republic. Three decades ago, Iranian health professionals fought to reduce infant and maternal mortality in rural areas. Their success…helped raise the country’s life expectancy to levels that more developed countries enjoy. The professionals that generation trained are today on the frontlines of the fight to contain the new coronavirus.”
Salehi-Isfahani goes on to wonder if these same health-workers – who like other professional Iranians are keen to engage internationally - will emerge eventually from the pandemic with more influence in their country’s future. Many have already died. Their cause seems poorly served by Washington lobbyists demanding collapse.
Two years ago on Feb. 24, 2022, the world watched as Russian tanks rolled into the outskirts of Kyiv and missiles struck the capital city.
Contrary to initial predictions, Kyiv never fell, but the country today remains embroiled in conflict. The front line holds in the southeastern region of the country, with contested areas largely focused on the Russian-speaking Donbas and port cities around the Black Sea.
Russian President Vladimir Putin, having recognized the Russian-occupied territories of Donetsk and Luhansk as independent days before the invasion, has from the beginning declared the war a “special military operation” to “demilitarize and denazify” Ukraine. His goals have alternated, however, between existential — bringing all of Ukraine into the influence of Russia — and strategic — laying claim to only those Russian-speaking areas in the east and south of the country.
It is in the latter that Russia has been much more successful. Yet after two winters of brutal fighting and hundreds of thousands of casualties on both sides, as of the end of 2023 Russia only laid claim to 18% of Ukraine’s territory, as compared to 7% on the eve of the war and 27% in the weeks after the invasion.
Meanwhile, the West’s coffers have been opened — and, as some say, drained — to help Ukraine’s government, led by President Volodymyr Zelensky, defend itself against Moscow.
Regardless, Ukraine’s military forces have been wholly depleted as they compete with a much more resourced and populous Russia. While Ukraine’s military campaign was able to take advantage of Russian tactical mistakes in the first year, its much-heralded counteroffensive in 2023 failed to provide the boost needed not only to rid the country of the Russian occupation, but also to put Kyiv in the best position to call for terms.
If anything, as Quincy Institute experts Anatol Lieven and George Beebe point out in their new brief, “there is now little realistic prospect of further Ukrainian territorial gains on the battlefield, and there is a significant risk that Ukraine might exhaust its manpower and munitions and lay itself open to a devastating Russian counterattack.”
The only and best solution, they say, is to drive all sides to the negotiating table before Ukraine is destroyed.
The narrative of the war — how it began, where it is today — is well documented. On the second anniversary of Russia’s full-scale invasion, RS thought it might be instructive to look at the numbers — weapons, aid, polling, population, and more — that illustrate the cost and the contours of the conflict over 24 months, and counting.
The U.S. Congress has allocated a total of $113 billion in funding related to the war. The vast majority of this money went directly to defending Ukraine ($45.2 billion in military aid) and keeping its government and society functioning ($46 billion in economic and humanitarian aid). Other funds went to rearming allies ($4.7 billion) and expanding U.S. military operations in Europe ($15.2 billion).
After two years of war, that funding has dried up. The Biden administration, which once shipped two or three new weapons packages each month, has not sent Ukraine a major arms shipment since Dec. 27, 2023. As Congress struggles to pass an additional $60 billion in Ukraine-related funding, observers increasingly believe that aid package may have been the last.
The Pentagon has sent at least 3,097,000 rounds of artillery to Ukraine since Russia’s invasion. Most of those (2,000,000) have been 155 mm shells, the standard size used by the U.S. and its NATO allies. For perspective, that’s about 95,000 tons of 155 mm ammunition alone.
Despite ramping up military manufacturing, the U.S. still only produces about 340,000 155 mm shells per year, meaning that Ukraine has been firing rounds at three times the rate of American production.
Washington has also given Kyiv 76 tanks, including 31 Abrams tanks and 45 Soviet-era T-72Bs. Ukraine has received 3,631 American armored vehicles of various types, from infantry fighting vehicles to personnel carriers and medical trucks.
Meanwhile, Ukraine has made use of 39 American-made HIMARS, a mobile rocket launcher that has become famous for its utility in the war. As for smaller arms, the U.S. has sent at least 400,000,000 grenades and bullets in the past 24 months.
The war has killed at least 10,378 civilians and injured an additional 19,632, according to the UN. More than three in four non-combatant casualties occurred in areas held by the Ukrainian government, indicating that Moscow is responsible for the lion’s share of civilian harm.
When it comes to military casualties, good data still remains hard to come by and estimates are sometimes wildly different. Neither Russia nor Ukraine have offered detailed, public indications of the war’s impact on their soldiers.
The U.S. estimated in August that 70,000 Ukrainian soldiers had died and an additional 100,000 to 120,000 had been injured, putting the number of total casualties at over 170,000. Russia, for its part, claimed in November that 383,000 Ukrainian soldiers had been killed or wounded.
On the other side, the United Kingdom estimates that Russia has suffered at least 320,000 casualties, with 50,000 deaths among Russian soldiers and 20,000 deaths among Wagner Group mercenaries. Washington said in December that Moscow had suffered 315,000 casualties, though American officials did not provide a breakdown of deaths and injuries.
The United Nations estimates that the Ukrainian population (the entire country within internationally recognized borders), which totaled 43.5 million people in 2021, dropped to 39.7 million in 2022 as war swept through the country’s east. This trend continued into 2023, as the population dropped to 36.7 million — the lowest level since Ukraine became independent in 1990.
As of January, 6.3 million Ukrainians have become refugees abroad, with another 3.7 million displaced internally. As the frontlines have settled, Ukraine’s population has slowly started to grow again, reaching 37.9 million in early 2024. Meanwhile, demographer Elena Libanova estimates that only 28 million of those people live within areas currently under Ukrainian government control (outside of Crimea and the Donbas).
Two new polls that came out within the last week illustrate the complexities of Americans’ feelings toward the war in Ukraine and the U.S. role in it.
First, a Pew poll published February 16 found that a large majority of Americans (74%) see the war between Russia and Ukraine as somewhat (30%) or very important (43%) to U.S. interests. And another survey, from the Harris Poll and the Quincy Institute, which publishes Responsible Statecraft, found that Americans broadly support a U.S.-led negotiated end to the conflict.
But the past few months in Washington have been largely focused on U.S. aid to Ukraine, specifically whether Congress will pass President Biden’s request for roughly $60 billion for Kyiv’s fight against Russia.
According to Pew, in March 2022, 74% of Americans said U.S. aid to Ukraine was “just right” or “not enough.” In December 2023, that same survey found that just 47% said the same. The biggest change came from Republicans: 49% said in March, 2022 that U.S. aid was “not enough,” while just 13% said the same in December.
Meanwhile, Gallup found in August 2022 that 74% of Americans said U.S. aid to Ukraine was “about right” (36%) or “not enough” (38%). Those numbers came down slightly in Gallup’s latest track on this question in October, 2023, with 58% saying U.S. aid was about right (33%) or not enough (25%).
There have been several attempts to bring nations together to outline talks to end the war. Russia and Ukraine engaged in five rounds of talks in Belarus and Turkey shortly after the invasion, but the talks collapsed amid allegations of Russian war crimes and Western pressure on Kyiv to keep fighting.
Since then, the belligerents have spoken directly about secondary issues, like Black Sea shipping and prisoner swaps. Ukraine, meanwhile, laid out a “10-point peace plan” that has formed the basis for five international summits, none of which included Russia. These took place in Copenhagen, Denmark, in June 2023; in Jeddah, Saudi Arabia, in August 2023; in Malta in October, 2023; in Riyadh, Saudi Arabia, in December 2023; and Davos, Switzerland, in January of this year.
Since the start of the war, Congress has passed four aid packages for Ukraine, totaling $113 billion. While none of the four packages were identical and aid for Ukraine was sometimes bundled with other spending, the trends for support for Kyiv in Congress are similar to those we see in polling, particularly among congressional Republicans.
The 2022 supplemental, which became law in May 2022 and provided Ukraine with $39.34 billion in aid passed the House 368-57 and the Senate by a vote of 86-11. By September 2023, when the House voted on the Ukraine Security Assistance and Oversight Supplemental Appropriations Act, which provided Kyiv with $300 million in security assistance, it passed by a vote of 311-117, with a majority of Republican members opposing the legislation.
On February 12 of this year, the Senate voted 70-29 to pass a national security supplemental, which would provide approximately $60 billion in aid for Kyiv alongside money for Israel and partners in the Indo-Pacific. The bill has not yet been voted on in the House.
Ben Armbruster, Blaise Malley, Connor Echols and Kelley Vlahos contributed reporting. Graphics by Khody Akhavi.
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A woman lays flowers at the monument to the victims of political repressions following the death of Russian opposition leader Alexei Navalny, in Moscow, Russia February 16, 2024. REUTERS/Stringer
President Biden was entirely correct in the first part of his judgment on the death of Alexei Navalny: “Putin is responsible, whether he ordered it, or he is responsible for the circumstances he put that man in.” Even if Navalny eventually died of “natural causes,” his previous poisoning, and the circumstances of his imprisonment, must obviously be considered as critical factors in his death.
For his tremendous courage in returning to Russia after his medical treatment in the West — knowing well the dangers that he faced — the memory of Navalny should be held in great honor. He joins the immense list of Russians who have died for their beliefs at the hands of the state. Public expressions of anger and disgust at the manner of his death are justified and correct.
The problem comes with the other part of Biden’s statement, that “[Navalny’s death] is a reflection of who [Putin] is. And it just cannot be tolerated.” If he had said “approved,” “justified,” or “defended,” that would have been absolutely right. But “tolerated”? What can Biden do in response, that he has not done already?
The U.S. president has promised major new sanctions intended to “cut Russia off from the world economy” — but that requires Washington to control the world economy. Economic sanctions against Russia in response to the invasion of Ukraine have failed, and even strengthened the Russian economy and the state’s grip on it. They cannot be significantly extended, because this would damage and infuriate countries that are dependent on Russian energy exports, including India, a key U.S. partner. As to sanctions against Russian individuals part of or linked to the Russian regime, there are already thousands of them, and they have had no effect whatsoever.
Statements like Biden’s are both pointless and dangerous. For the spoken or unspoken implication is that it is impossible to deal with Putin. But like it or not, Putin is the president of Russia. To all appearances, he will remain so for a considerable time to come, and will hand over to a successor of his own choosing. The Biden administration has said that it wants Ukrainian victory (whatever that now means), but it has also said that it believes that the war will end in negotiations, and following the failure of last year’s Ukrainian offensive, is now reported to be moving in this direction.
Who does Biden think that he will negotiate with, if not Putin? Seeking talks on an end to the Ukraine war does not imply approval of Putin’s crimes or his invasion of Ukraine, any more than the Eisenhower administration’s negotiation of an end to the Korean War implied approval of the North Korean regime and its invasion of South Korea.
By its own account, the Biden administration has supposedly made the promotion of democracy around the world a central part of its diplomacy, with the clear implication that only democratic governments that respect human rights are truly legitimate. Actual U.S. diplomacy does not work like this and never has; not because of American imperialist or capitalist wickedness, but because the world does not work like this.
Nobody should be required to like or admire the governments of Abdel Fattah Al-Sisi, Mohammed Bin Salman or Narendra Modi (though we might well wish that U.S. officials had been less effusive in their praise of them). Like Putin, they are however the heads of their countries’ governments, and likely to remain so. You deal with Saudi Arabia and India — and you have to deal with Saudi Arabia and India — you deal with MBS and Modi.
The other thing to be wary of in the outpouring of outrage at the death of Navalny, is that this is already being used to build a strategy of greatly increased Western official support for the Russian opposition. Many (not all) people and groups in the Russian liberal opposition are personally and politically admirable. Some, like Navalny, have shown tremendous courage. To say this is quite different from believing that they are ever likely to form the government of Russia, and that the U.S. should base its policy towards Russia on the hope that this will be so.
The sad truth is that the Ukraine war has placed the Russian liberal opposition in a politically impossible position. Having been largely chased into exile by Putin, they are dependent on Western support. This means however that their principled opposition to the Russian invasion can be portrayed by the Russian government — and is seen by many ordinary Russians — as treason in time of war. As with the Iranian, Chinese, and other oppositions, official support from Washington only allows the ruling regimes to paint the name “traitor” in brighter colors.
A combination (differing from individual to individual) of idealism, dependence on the West and hatred of Putin means that instead of advocating a compromise peace in Ukraine, many Russian oppositionists have — willingly or unwillingly — identified themselves with Ukrainian and Western positions that explicitly demand complete Russian defeat.
And while not many Russians wanted the war, not many Russians want to see Russia defeated. As I have remarked before, even many Americans who strongly opposed the war in Vietnam were outraged when Jane Fonda went to Hanoi. If she stood a chance of being elected to any office in the U.S. before that trip, she certainly didn’t afterwards.
Any hope of rebuilding liberalism in Russia (and indeed Ukraine, albeit to a much lesser extent) therefore requires an end to the war. For some degree of authoritarianism is a natural accompaniment to every war, and regimes all over the world have exploited this to increase their own power. Equally importantly, mass support for Putin is critically dependent on the general belief that the West intends not just to defeat Russia but to cripple it as a state, and that to prevent this it is essential to support the government.
For the moment at least, this has eclipsed previously widespread resentments —which Navalny channeled — at regime corruption. No amount of Western or Russian opposition propaganda can change this Russian picture. Peace might, if it is given a chance.
For the third year in a row, globally, the number of investors in nuclear weapons producers has fallen but the overall amount invested in these companies has increased, largely thanks to some of the biggest investment banks and funds in the U.S.
“As for the U.S., while there is, like past years, indeed a dominance, and total financing from U.S.-based institutions has increased, the total number of U.S. investors has dropped for the third year in a row (similar to our global findings), and we hope to see this number will continue to fall in the coming years,” Alejandar Munoz, the report’s primary author, told Responsible Statecraft.
In 2023, the top 10 share and bondholders of nuclear weapons producing companies are all American firms. The firms — Vanguard, Capital Group, State Street, BlackRock, Wellington Management, Fidelity Investments, Newport Group, Geode Capital Holdings, Bank of America and Morgan Stanley — held $327 billion in investments in nuclear weapons producing companies in 2023, an $18 billion increase from 2022.
These companies are also profiting from the enormous government contracts they receive for developing and modernizing nuclear weapons.
“All nuclear-armed states are currently modernizing their nuclear weapon systems,” says the annual “Don’t Bank on the Bomb” report from PAX and ICAN. “In 2022, the nine nuclear-armed states together spent $82.9 billion on their nuclear weapons arsenals, an increase of $2.5 billion compared to the previous year, and with the United States spending more than all other nuclear powers combined.”
American weapons companies are some of the biggest recipients of contracts for nuclear weapons. Northrop Grumman and General Dynamics are “the biggest nuclear weapons profiteers,” according to the report. Combined, the two American weapons manufacturers have outstanding nuclear weapons related contracts with a combined potential value of at least $44.9 billion.
Those enormous government contracts for nuclear weapons, alongside contracts for conventional weapons, have helped make nuclear weapons producers an attractive investment for American investment banks and funds.
“Altogether, 287 financial institutions were identified for having substantial financing or investment relations with 24 companies involved in nuclear weapon production,” says the report. “$477 billion was held in bonds and shares, and $343 billion was provided in loans and underwriting.”
The report notes that while the total amount invested in nuclear weapons has increased, the number of investors has fallen and trends toward firms in countries with nuclear weapons.
ICAN and PAX suggest that concentration may be a result of prohibitions on nuclear weapons development for signatories to the Treaty on the Prohibition of Nuclear Weapons (TPNW), a 93 signatory treaty committing to the ultimate goal of the total elimination of nuclear weapons. The report says:
The TPNW comprehensively prohibits the development, manufacturing, testing, possession, use and threat of use of nuclear weapons, as well as assistance with those acts. For companies that build the key components needed to maintain and expand countries’ nuclear arsenals, access to private funding is crucial. As such, the banks, pension funds, asset managers and other financiers that continue to invest in or grant credit to these companies allow for the production of inhumane and indiscriminate weapons to proceed. By divesting from their business relationships with these companies, financial institutions can reduce available capital for nuclear weapon related activities and thereby be instrumental in supporting the fulfilment of the TPNW’s objectives.
Susi Snyder, managing director of the Don’t Bank on the Bomb Project, told Responsible Statecraft that even U.S. banks, like Pittsburgh based PNC Bank, are facing shareholder pressure to divest from nuclear weapons and that the tide may be shifting as shareholders in U.S. companies grow increasingly sensitive to investments in nuclear weapons.
“For three years shareholder resolutions have been put forward at PNC bank raising concerns that their investments in nuclear weapon producers are a violation of the Treaty on the Prohibition of Nuclear Weapons (TPNW), and that they are not in line with the bank's overall human rights policy guidelines,” she said.