## Facts

- Iran and the United States litigated consolidated intergovernmental “A” cases before the Iran–United States Claims Tribunal concerning U.S. compliance with the 1981 Algiers Declarations.
- The Algiers Declarations required the United States to terminate U.S.-court proceedings by U.S. persons against Iran and its state enterprises, nullify attachments and judgments, prohibit further litigation, and channel covered claims to binding arbitration before the Tribunal.
- Iran alleged the United States implemented these obligations through measures (including Executive Order 12294 and related regulations) that often suspended proceedings rather than definitively terminating them, allowing some litigation to remain capable of revival in U.S. courts.
- Iran also contended the United States failed to terminate certain proceedings after claims were transferred to the Tribunal and inadequately addressed litigation naming Iranian officials.
- In a 1998 partial award, the Tribunal interpreted the termination obligation as requiring more than a stay or suspension in circumstances where proceedings could later resume, and it found breaches in certain respects, while leaving damages for later determination.
- The 2014 final award addressed Iran’s remaining requests for monetary compensation based on the earlier breach findings.

## Issues

1. Whether Iran proved that the United States’ established noncompliance with the Algiers Declarations caused compensable injury to Iran.
2. Whether Iran proved the existence and amount of damages with sufficient specificity, rather than relying on generalized assertions of harm from continued or suspendable litigation.
3. Whether any continued U.S.-court proceedings involving Iranian officials produced compensable loss attributable to a failure to terminate covered cases.

## Decision

- The Full Tribunal largely rejected Iran’s monetary claims and dismissed Iran’s remaining compensation requests (including the set commonly described as the “Thirteen Claims”).
- The Tribunal held that Iran did not carry its burden to establish a sufficient causal link between the proven breaches and specific, quantifiable damages.
- The Tribunal declined to award substantial monetary relief, treating the dispute as one where breach had been identified earlier but compensable consequences were not proven in the damages phase.

## Legal Principles

- Under General Principle B of the General Declaration, the United States must terminate covered U.S.-court proceedings against Iran and its state enterprises, nullify attachments and judgments, prohibit further litigation based on such claims, and ensure disposition through binding arbitration under the Claims Settlement Declaration.
- Measures that merely suspend proceedings, leaving them capable of revival, may be inconsistent with the duty to terminate proceedings and prohibit further litigation when they do not conclusively end the litigation in U.S. courts.
- A claimant seeking compensation must prove (i) the existence of damage, (ii) causation linking the damage to the breach, and (iii) a reasonably certain measure of the loss; breach findings alone do not establish compensable damages.
- Generalized or speculative harm from systemic nonconformity is insufficient for monetary relief absent case-specific proof that the complained-of conduct caused identifiable loss.

## Conclusion

The Tribunal’s final award denied Iran significant compensation, concluding that although earlier proceedings had identified certain U.S. implementation measures as inconsistent with the Algiers Declarations’ termination obligations, Iran failed to prove that those breaches caused specific, quantifiable damages warranting a monetary award.


Islamic Republic of Iran v. United States, Final Award No. 602-A15 (IV)/A24-FT (Iran-U.S. Cl. Trib. July 2, 2014)