Legal regulation of the currency exchange market in Iran: a Hayekian analysis

ABSTRACT

Hayek contends that good money is not available when the central bank is under political pressure, and the government dictates its decisions. As an illustration, the Central Bank of Iran, in accordance with the government’s concern, has actively interfered in the currency market to maintain the value of the money. This attempt was weakened by the U.S. sanctions. In another vein, legislators modified Combatting the Smuggling of Commodities and Foreign Exchange Law to tighten the freedom of currency exchange. The law imposes severe penalties on those who keep, carry, and sell currencies that do not fall within the definition of legal currency exchange. This paper contends that although such measures might temporarily suppress demands, they are unlikely to make a controllable currency market. Based on Hayek’s theory of money, the government’s budget deficit and unrestrained printing of money have also exacerbated the situation that promotes bad money.

KEYWORDS:

• Currency fluctuations
• exchange rate
• law
• Hayek
• catallaxy
• Iran

Acknowledgements

I would like to thank Professor Jonathan Crowe, Holli Edwards, and Shirley Brown for their positive insights. All mistakes that remain are my own.

Disclosure statement

No potential conflict of interest was reported by the author(s).

Notes

1 Mises in Human Action confirms that Whatley is the first scholar who used Catallactics or Science of Exchanges. See Ludwig von Mises, Human Action (4th edn, Yale University Press 1996) 3.

2 Richard Whately, Introductory Lectures on Political Economy (2nd edn, B Fellowes 1832) 6–9.

3 Mises (n 1) 233–234.

4 ibid 202.

5 M Hashem Pesaran, ‘The Iranian Foreign Exchange Policy and the Black Market for Dollars’ (1992) 24 International Journal of Middle East Studies 101, at 101.

6 Djavad Salehi Esfahani, ‘The Role of External Shocks in Iran’s Inflation’ <https://djavadsalehi.com/2021/06/17/the-role-of-external-shocks-in-irans-inflation/> accessed 10 June 2022.

7 Business Insider, ‘Iran’s Riyal Plunges to Record Low After U.S. Sanctions’ (Business Insider, 2 January 2012) <https://www.businessinsider.com/irans-riyal-plunges-to-record-low-after-us-sanctions-2012-1> accessed 10 June 2022.

8 For instance, the Supreme Leader of Iran in one of the official meetings with the cabinet mentioned that: ‘On the issue of the economy, Khamenei stressed again for the administration to focus on domestic production, calling it the key to resolving the issues of unemployment and inflation … ’ Al-monitor, ‘Iran’s Khamenei Calls for Making Economy Independent’ (Al-monitor, 24 August 2020) <https://rb.gy/vdwo5> accessed 5 July 2022.

9 Frank Shostak, ‘Currency Devaluation and Economic Growth’ <https://mises.org/library/currency-devaluation-and-economic-growth> accessed 5 July 2022.

10 Friedrich von Hayek, Denationalisation of Money (Institute of Economic Affairs 1978) 21.

11 ibid.

12 Henry C Simons, ‘Rules versus Authorities in Monetary Policy’ (1936) 44 Journal of Political Economy 1, 3.

13 For example, the ex-head of the Judiciary during the first wave of currency depreciation in 2012 said that ‘some of the problems in the foreign currency and gold markets are created by groups linked to the regime's enemies’. He added that these groups ‘have made the market volatile by creating various websites that fabricate rates for foreign currency and gold’. Eyder Peralta, ‘Iran Warns That Major Currency Speculators Could Face Death Penalty’ (NPR, 2 February 2012) <https://www.npr.org/sections/thetwo-way/2012/02/02/146287375/iran-warns-that-major-currency-speculators-could-face-death-penalty> accessed 25 May 2022.

14 ‘During 2011–2015, U.S. secondary sanctions contributed to the shrinking of Iran’s economy as its crude oil exports fell by more than 50 per cent and it could not access its foreign exchange assets held abroad’. See Kenneth Katzman, ‘Iran Sanctions’ (Congressional Research Service Report 2022) 1. Eventually, Iran agreed on the nuclear talk which resulted in an agreement among China, France, Germany, the United Kingdom, the United States, and Russia to cease some nuclear activities and part of financial sanctions and asset freeze will be lift or suspended in return. See ‘Joint Comprehensive Plan of Action’ (entered into force 14 July 2015).

15 Efficacy of sanctions should be differentiated from their effects. Although sanctions might not result in political or behavioural changes, they enormously affect sanctioned countries’ socio-economic situation and policies. See Nicholas Mulder, The Economic Weapon (Yale University Press 2022) 296. For instance, one can suspect that Iranian government exercised a set of indigenous policies, called resistance economy, to lower economic pressures arising from the U.S. sanctions. See Siyasatha-ye Koli-e Eghtesad-e Moghavemati [General Policies of Resistance Economy].

16 Frank D Graham, Exchange Prices, and Production in Hyper-Inflation: Germany, 1920–1923 (Princeton University Press 1930) 149.

17 Marketa Hulpachova, ‘Iran’s Economy Struggles to Support Ahmadinejad’s Ill-Conceived Housing Vision’ (The Guardian, 30 January 2014) <https://www.theguardian.com/world/iran-blog/2014/jan/30/irans-economy-struggles-to-support-ahmadinejads-ill-conceived-housing-vision> accessed 1 June 2022. It seems that the government does not want to learn any lesson from the past. Recently, the government announced that 4,000,000 houses will be built by 2026. See Tehran Times, ‘President Orders Start of Building 1,000,000 National Housing Movement Units’ (Tehran Times, 17 May 2022) <https://www.tehrantimes.com/news/472688/President-orders-start-of-building-100-000-National-Housing-Movement> accessed 1 June 2022.

18 Referring to Keynes to contextualise this decision does not necessarily mean that Iran’s economy is ruled by Keynesian approach.

19 GR Steele, The Economics of Friedrich Hayek (2nd edn, Palgrave Macmillan 2007) 20.

20 Zachary D Carter, The Price of Peace; Money, Democracy, and the Life of John Maynard Keynes (Random House 2020) 268.

21 ibid 456, 457.

22 Sarwat Jahan, Ahmed Saber Mahmud and Chris Papageorgiou, ‘What is Keynesian Economics?’ (2014) 51 Journal of Finance and Development 53, at 53.

23 Steele (n 19) 20.

24 Although Mises and Hayek are considered Austrian economists, it cannot be conceived that their monetary theories are the same or based on similar assumptions. Both economists reject the neutrality of money, but their foundations differ. In this article, the Hayekian view on monetary theory is articulated. However, Mises’ relevant literature sheds light on the issue.

25 Friedrich von Hayek, Law, Legislation, and Liberty, Vol 2 (Routledge 1998) 110.

26 ibid 107, 108.

27 ibid 109.

28 ibid.

29 Mises (n 1) 233.

30 ibid 234.

31 ibid 240.

32 ibid 253.

33 Hayek (n 10) 63.

34 Anthony M Endres, ‘Currency Competition: A Hayekian Perspective on International Monetary Integration’ (2009) 41 Journal of Money, Credit and Banking 1251, 1254.

35 Mises (n 1) 401.

36 Steele (n 19) 184–85.

37 Roger W Garrison, ‘Hayekian Trade Cycle Theory: A Reappraisal’ (1986) 6 Cato Journal 437, 440.

38 Manfred E Streit, ‘Cognition, Competition, and Catallaxy: In Memory of Friedrich August von Hayek’ (1996) 4 Constitutional Political Economy 223, 254.

39 Steele (n 19) 185.

40 ‘ … oil prices that jumped from $50 a barrel in 2005 to $140 in 2008, injected the oil revenue into the national budget to boost the economy, bring the so-called social justice, and increase the purchasing power of citizens, especially the poverty affected working class’. See Tohid Atashbar, ‘Iranian Disease: Why a Developing Country’s Government Did Not Listen to Economists’ Advices’ (2013) 72 American Journal of Economics and Sociology 732, 738.

41 Friedrich von Hayek, The Constitution of Liberty (University of Chicago Press 2011) 457–78. Also, Hayek began his Nobel Prize lecture with highlighting inflation: ‘the economists are at this moment called upon to say how to extricate the free world from the serious threat of accelerating inflation which, it must be admitted, has been brought about by policies which the majority of economists recommended and even urged governments to pursue’. Fiedrich von Hayek, ‘The Pretence of Knowledge’ (11 December 1974) <https://www.nobelprize.org/prizes/economic-sciences/1974/hayek/lecture/> accessed 5 July 2022.

42 Carter (n 20) 452.

43 ibid 271.

44 John Maynard Keynes, The General Theory of Employment, Interest, and Money (Palgrave Macmillan 2018) 143.

45 Carter (n 20) 271, 272.

46 ‘Keynes v Hayek in China’ (The Economist, 17 November 2011) <https://www.economist.com/news/2011/11/17/keynes-v-hayek-in-china> accessed 4 April 2023.

47 ‘John Maynard Keynes’ (The Economist, 26 November 2013) <https://www.economist.com/free-exchange/2013/11/26/john-maynard-keynes> accessed 4 April 2023.

48 Abba P Lerner, ‘Mr Keynes’ General Theory of Employment, Interest and Money’ (2013) 152 International Labour Review 36, 45.

49 Carter (n 20) 456.

50 Joseph T Salerno and others, ‘Two Views on Neutral Money: Wieser and Hayek versus Menger and Mises’ (2020) 27 The European Journal of the History of Economic Thought 682, 692.

51 Hayek (n 10) 82.

52 Salerno and others (n 50) 691.

53 Hayek (n 10) 113–14.

54 For detailed information about money neutrality see Ravi Batra, ‘Neutrality and Non-Neutrality of Money in a Classical-Type Model’ (2002) 7 Pacific Economic Review 489, at 489.

55 Thorsten Polleit, ‘The Fallacy of the (Super)Neutrality of Money’ (Mises, 23 October 2009) <https://mises.org/library/fallacy-superneutrality-money> accessed 1 June 2022.

56 Steele (n 19), Carter (n 20) 61.

57 Mises transplants purchasing power of money into the marginal utility theory, claiming that ‘the purchasing power that informs the decisions of potential individual demanders of money is the purchasing power that they expect to reside in units of money that they may acquire’. See Israel M Kirzner and others, Ludwig von Mises: The Man and His Economics (Liberty Fund 2019) 89.

58 Hayek (n 10) 84.

59 Notwithstanding this, further occurrences such as the 1982 recession called economists’ attention to the partial impacts of large injections of money on the inflation rate. See Batra (n 54) 490.

60 Friedrich von Hayek, Monetary Theory and the Trade Cycle (N Kaldor and HM Croome tr, Sentry Press 1933) 108.

61 Steven Horwitz, ‘Hayek on the Neutrality of Money’ in Steven Horwitz (ed), Studies in Austrian Macroeconomics (Emrland Group 2016) 63.

62 ibid 67–68.

63 ibid 72.

64 ibid 65.

65 Salerno and others (n 50) 697–98.

66 Frank Shostak, ‘Money Isn't Neutral: Why Economic Stabilization Schemes Are Counterproductive’ (Mises, 24 March 2021) <https://mises.org/wire/money-isnt-neutral-why-economic-stabilization-schemes-are-counterproductive> accessed 12 July 2022.

67 Friedrich von Hayek, Good Money, part 1, (Routledge 1999) 228.

68 ibid 230.

69 ibid 238–39.

70 Friedrich von Hayek, Prices and Production and Other Works (Ludwig von Mises Institute 2008) 185–86.

71 Otmar Issing, ‘Hayek – Currency Competition and European Monetary Union’ (27 May 1999) available at: <https://www.ecb.europa.eu/press/key/date/1999/html/sp990527.en.html> accessed 17 July 2022.

72 Antony P Mueller, ‘The Return of the Anguish of Central Banking: Why the Fed and Inflation Go Hand in Hand’ (Mises, 23 June 2022) <https://mises.org/wire/return-anguish-central-banking-why-fed-and-inflation-go-hand-hand> accessed 12 July 2022.

73 This book was firstly published in 1978, while Hayek published the Constitution of Liberty in 1960. This period shows his distance from the preliminary idea of independent monetary policy.

74 See Issing (n 71) 72.

75 Article 5: ‘CBI shall at any time have at its disposal the following assets, equivalent to one hundred per cent of the notes issued, as backing: 1- Gold, in accordance with Article 6. 2- Foreign exchange, in accordance with Article 7. 3- Securities and bonds in accordance with Articles 8 and 9’.

76 ‘The foreign exchange assets … consist of: a. Convertible foreign bank-notes, acceptable to CBI; b. Foreign exchange claims falling due in not more than six months; c. Any payments made under relevant statutes to the International Monetary Fund, the International Bank for Reconstruction and Development and similar or affiliated institutions as quota or subscription; d. Securities issued or guaranteed by official international organizations or their affiliate institutions; e. Securities issued or guaranteed by foreign States; f. Receivables from abroad in foreign exchange or Rials convertible to foreign exchange, acquired through the implementation of international agreements for payment and/or barter, within the limits provided in such agreements; g. Commercial instruments in convertible foreign exchange, falling due in not more than six months, drawn on foreign persons, natural or legal, bearing three credible signatures, one necessarily that of the ceding bank; h. Foreign bonds and securities convertible to currencies acceptable to CBI; i. The balance of special Drawing Rights holdings with the International Monetary Fund, in accordance with the relevant laws’.

77 Hayek (n 41) 451–53.

78 ibid 454.

79 Simons (n 12) 5. Hayek in the Constitution of Liberty refers to that essay from Simons to highlight the importance of strict rules on monetary policy and independent monetary authority. See Hayek (n 41) 461.

80 Simons (n 12) 29.

81 International Monetary Fund, ‘Regional Economic Outlook. Middle East and Central Asia’ no. 0258-7440, at Statistical Appendix, Table 16, available at: <https://www.imf.org/-/media/Files/Publications/REO/MCD-CCA/2021/October/reo-october-2021-english.ashx> accessed 21 July 2022.

82 Hayek (n 41) 454.

83 At this point, Hayek quotes ‘in the long run we are all dead’ from Keynes (John Maynard Keynes, A Tract on Monetary Reform (Macmillan 1924) 80) to ascribe inflationary bias to the short-term view among economists. See Hayek (n 41) 460.

84 Hayek (n 41) 461.

85 ibid 465.

86 Murray N Rothbard, Classical Economics An Austrian Perspective on the History of Economic Thought, vol 1 (Edward Elgar 1995) 445–56.

87 William J Baumol, ‘Entrepreneurship: Productive, Unproductive, and Destructive’ (1990) 98 Journal of Business Venturing 893, 918.

88 Peter J Boettke and Ennio Piano, ‘Baumol’s Productive and Unproductive Entrepreneurship after 25 Years’ (2016) 5 Journal of Entrepreneurship and Public Policy130, 131.

89 EC Pasour, ‘Rent Seeking: Some Conceptual Problems and Implications’ (1987) 1 The Review of Austrian Economics 123, 135.

90 ibid 137.

91 ‘Appeal of Unproductive Activities Should be Eradicated to Fulfill New Year’s Motto: Samsami’ (Iran Daily, 2 April 2022) <https://irandaily.ir/News/320702.html> accessed 15 July 2022.

92 ‘Strategic Pattern of Protecting the Production, no. 16582’ (Economic Studies Office 2019) 9.

93 Former US President Richard Nixon, ‘The Implementation of His New Economic Policy’ (15 August 1971) available at: <https://www.presidency.ucsb.edu/documents/address-the-nation-outlining-new-economic-policy-the-challenge-peace> accessed 30 July 2022.

94 Mises (n 2) 232.

95 In 2017, the government owned approximately 80 per cent of the currency in the country. See Majidreza Hariri, ‘Failure of Government’s Scenario in the Currency Market’ (Jahane Sanat, 27 December 2017) <https://jahanesanat.ir/?p=88837> accessed 24 June 2022.

96 Glen Biglaiser and David Lektzian, The Effects of Economic Sanctions on Targeted Countries’ Stock Markets (2020) 46 International Interactions 526, 530.

97 See Katzman (n 14).

98 ‘The President … impose sanctions pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) with respect to the Central Bank of Iran’. FY2012 National Defense Authorization Act, tit C USC § 1245.

99 ‘The government responded with a crackdown in which some money traders were arrested’. See Rick Gladstone, ‘Iran Currency Falls Further on Concerns Over Bank’ (New York Times, 22 January 2013) <https://www.nytimes.com/2013/01/23/world/middleeast/iran-currency-falls-further-on-concerns-over-bank.html> accessed 23 June 2022.

100 Keith Johnson and Robbie Gramer, ‘Trump’s Big Iran Oil Gamble’ (Foreign Policy, 22 April 2019) <https://foreignpolicy.com/2019/04/22/trumps-big-iran-oil-gamble-sanctions-waivers-end-pompeo-trump-iranian-oil-exports-imports-what-impact-political-economic-diplomacy/> accessed 24 June 2022.

101 H Elif Ture and Ali Reza Khazaei, ‘Determinants of Inflation in Iran and Policies to Curb It’ (IMF Working Paper. Middle East and Central Asia Department. 2022) 15.

102 World Trade Organisation, ‘Trade Profiles 2022’ (2022) 174.

103 Prima facie, this article does not consider other shocks such as covid19 pandemic or Russia-Ukraine war which had their unique repercussions on the economy in global scale.

104 Yong-Shik Lee, ‘Political Governance, Law, and Economic Development’ (2019) 12 Law and Development Review 323, 346.

105 IMF <https://data.imf.org/?sk=85b51b5a-b74f-473a-be16-49f1786949b3>.

106 NIMA is an online currency system under the CBI’s supervision in which exporters should supply their foreign currency and approved importers are allowed to purchase them.

107 Es’haq Jahangiri, ‘Dollar to be 42,000 Rials from Tuesday’ (9 July 2018) <https://www.president.ir/EN/103849> accessed 24 June 2022.

108 Maziar Motamedi, ‘Why does Iran Have Three Foreign Exchange Rates?’ (Aljazeera, 2 July 2019) <https://www.aljazeera.com/economy/2019/7/2/why-does-iran-have-three-foreign-exchange-rates> accessed 25 June 2022.

109 Struan Stevenson, ‘Iran's Corruption May Block IMF Coronavirus Aid’ (UPI, 17 April 2020) <https://www.upi.com/Top_News/Voices/2020/04/17/Irans-corruption-may-block-IMF-coronavirus-aid/9881587124974/> accessed 24 June 2022.

110 ‘Government Changes Import Subsidy Allocation System’ (Financial Tribune, 11 May 2022) <https://financialtribune.com/articles/113454/government-changes-import-subsidy-allocation-system> accessed 7 April 2023.

111 Maziar Motamedi, ‘Free-Falling Rial Leaves Iranians Worried about Financial Future’ (Aljazeera, 2 March 2023) available at: <https://www.aljazeera.com/economy/2023/3/2/iran-rial-depriciation> accessed 7 April 2023.

112 Mohsen Tavakol, ‘Iran’s economy and the burden of multiple exchange rates’ (Atlantic Council, 12 May 2020): <https://www.atlanticcouncil.org/blogs/iransource/irans-economy-and-the-burden-of-multiple-exchange-rates/> accessed 26 June 2022.

113 ‘CBI Has a New Boss as Rial Falls to Record Low’ (Financial Tribune, 31 December 2022) <https://financialtribune.com/articles/business-and-markets/116599/cbi-has-a-new-boss-as-rial-falls-to-record-low> accessed 7 April 2023.

114 Henry Rome, ‘Iran’s Currency Collapse May Not Lead to Diplomatic Desperation’ (Washington Institute, 7 March 2023) <https://www.washingtoninstitute.org/policy-analysis/irans-currency-collapse-may-not-lead-diplomatic-desperation> accessed 7 April 2023.

115 By comparing Iran’s GDP per capita with Türkiye during this period, it is revealed that before tightening sanctions in 2011, the index was relatively alike in both countries, but after the first sanctions shock, a gap occurred which was aggravated by the second sanctions shock. See <https://data.worldbank.org/indicator/NY.GDP.PCAP.PP.CD?locations=IR-TR>.

116 See n 115. The list consists of 63 purposes such as tuition fee, medical cost, subscription fees of international journals, travellers with valid overseas flights (500 euro), and so forth. See Donya-e-Eqtesad, ‘List of Recognised Services for Receiving the Currency in the Currency and Gold Exchange Centre’ available at: <https://tinyurl.com/4frpj78y> accessed 7 April 2023.

117 ‘CBI Launches Currency, Gold Exchange Center’ (Tehran Times, 21 February 2023) <https://www.tehrantimes.com/news/482154/CBI-launches-currency-gold-exchange-center> accessed 7 April 2023.

118 World Bank Data <https://data.worldbank.org>.

119 International Monetary Fund, ‘Regional Economic Outlook; Middle East and Central Asia’ (2022) Table 21.

120 Dominic Dudley, ‘Iran Says $7 Billion in Frozen Funds About to Be Returned to Tehran’ (Forbes, 11 April 2022) <https://www.forbes.com/sites/dominicdudley/2022/04/11/iran-says-7-billion-in-frozen-funds-about-to-be-returned-to-tehran/?sh=594cd8d320f5> accessed 10 June 2022.

121 ‘Impact of Fiat Money’ (Eghtesadonline, 1 August 2020) <https://www.en.eghtesadonline.com/Section-iran-business-69/33044-impact-of-fiat-money> accessed 19 June 2022.

122 Hayek (n 41) 399–400.

123 CBI <https://tsd.cbi.ir/DisplayEn/MostReq.aspx>.

124 ‘Minimum Wages to Rise 57.4 per cent in Fiscal 2022-23: Labor Minister’ (Financial Tribune, 12 March 2022) <https://financialtribune.com/articles/domestic-economy/112849/minimum-wages-to-rise-574-in-fiscal-2022-23-labor-minister> accessed 27 June 2022.

125 Ture and Khazaei (n 101) 15.

126 Hayek (n 67) 187–99.

127 ibid 210–12.

128 Hayek (n 70) 79.

129 Hayek (n 10) 96–97.

130 Arthur F Burns, ‘The Anguish of Central Banking’ (1987) 73 Federal Reserve Bulletin 687, 688–91.

131 ibid 692.

132 Hayek (n 10) 96–97.

133 ibid 98.

134 Hayek (n 67) 146.

135 Supreme Audit Court <https://www.dmk.ir/page-news/fa/0/dorsaetoolsnewspanel/4849-G0>.

136 Hayek (n 67) 105.

137 Mises (n 2) 426–27.

138 ibid 427.

139 Murray N Rothbard, The Mystery of Banking (2nd edn, Ludwig von Mises Institute 2008) 67–68.

140 ibid.

141 Friedrich von Hayek, Good Money, part 2 (Routledge 1999) 122. Gresham’s law is that the bad money drives out the good. However, Hayek contends that Gresham’s law is only applicable in a situation with only two available currencies. In a system with multiple available currencies or items for an exchange, people opt for the good money which drive out the bad. ibid.

142 Graham (n 16) 50.

143 For instance, Iran citizens bought 7189 from Turkey in 2020. See Turkish Statistical Institute, ‘House Sales Statistics, No 37464’ (2021) available at: <https://data.tuik.gov.tr/Bulten/Index?p=House-Sales-Statistics-December-2020-37464&dil=2> accessed 10 June 2022.

144 Morteza Abdolhosseini, ‘$171 billion Capital Flight in 16 years’ (Farhikhtegan, 21 October 2021) <https://fdn.ir/62239> accessed 4 April 2022.

145 ‘Iran Limits Amount of Foreign Currency People Can Keep’ (Radio Farda, 9 January 2020) <https://en.radiofarda.com/a/iran-limits-amount-of-foreign-currency-people-can-keep/30660734.html#:~:text=Many%20people%20have%20turned%20their,worth%20of%20hard%20currency%20cash.> accessed 3 July 2022.

146 Mises (n 2) 427.

147 ‘Iranian CBI governor said he would defend Iran’s ailing currency against speculation without injecting hard cash into the market, after the currency fell to historic lows this week’. See ‘Iran Central Bank Chief Vows to Fight Speculation against Currency’ (Reuters, 27 June 2020) <https://www.reuters.com/article/iran-economy-rial-centralbank-idINKBN23Y06L> accessed 2 June 2022.

148 Saeed Kamali Dehghan, ‘Mahmoud Ahmadinejad: Iran’s Currency Crisis due to Psychological War’ (The Guardian, 3 October 2012) <https://www.theguardian.com/world/2012/oct/02/ahmadinejad-iran-currency-psychological-war> accessed 5 July 2022.

149 ‘Iran Supreme Leader Calls for Action to Face Economic War’ (Reuters, 12 August 2018) available at: <https://www.reuters.com/article/iran-nuclear-economy-khamenei-idINL5N1V20FM> accessed 8 July 2022.

150 ‘Rouhani: Enemies Will Fail to Destroy Iranian Economy’ (Iran Daily, 5 July 2020) <https://irandaily.ir/News/271081.html?catid=3&title=Rouhani--Enemies-will-fail-to-destroy-Iranian-economy> accessed 8 July 2022.

151 Graham (n 16) 83.

152 Article 2 of the law of Combatting the Smuggling of Commodities and Foreign Exchange.

153 Graham (n 16) 83.

154 ibid 84.

155 Yong-Shik Lee, ‘General Theory of Law and Development: An Overview’ (2019) 12 Law and Development Review 351, 375.

156 Ruhollah Khomeini, Sahifeh-ye Imam (An Anthology of Imam Khomeini’s Speeches, Messages, Interviews, Decrees, Religious Permissions, and Letters) vol. 20, (The Institute for Compilation and Publication of Imam Khomeini’s Works 2008) 426–27.

157 Friedrich von Hayek, Law, Legislation, and Liberty, Vol. 1 (Routledge 1998) 56–57.

158 ibid.

159 ‘The Currency Market Analysis: Evaluation of the Government’s Actions and Reform Recommendations, no. 22018827’ (Economic Studies Office 2023) 2.

160 Hayek (n 41) 465.

161 CBI <https://tsd.cbi.ir/DisplayEn/MostReq.aspx>.