Gruesome details of the possible premeditated killing of Saudi journalist Jamal Khashoggi by Saudi state actors are gradually being revealed. This has invited inevitable comparisons between the brutality of Saudi Arabia to its regional rival, Iran.

While the comparisons have prompted a fair number of social media snipes and tu quoque arguments, the parallels here are important to consider for a range of reasons.

Primary among them are the lessons it imparts for how the international community’s handling of Tehran’s own practice of killing dissidents abroad during the 1980s and 1990s should provide every incentive for a more robust response from the United States and other involved actors to the events involving Khashoggi.

Following the 1979 revolution, top Iranian officials perpetrated a campaign of extrajudicial killings of the regime’s political opponents around the globe. As of 2011, that number was at 162 and included such high-profile assassinations as: the Kurdish Democratic Party of Iran leader Abdul Rahman Ghassemlou in Vienna in 1989; the former Prime Minister and National Front politician Shapour Bakhtiar outside of Paris in 1991; and Kazem Rajavi, the brother of the Mujahedin-e Khalq leader Massoud Rajavi in a suburb of Geneva in 1990.

While there is evidence to show that Iran is beginning to extend its brutal long arm yet again—with the murky circumstances surrounding the killings of Iranian television executive Saeed Karimian in Istanbul in April 2017 and Ahvazi activist Ahmad Mola Nissi in The Hague in November 2017—up until recently the program was on a “hiatus” of sorts since the late 1990s.

Indeed, up until recent allegations of extraterritorial meddling, the last political killing outside of Iran that can be linked directly to Tehran was of Reza Mazlouman, deputy leader of the Flag of Freedom Organization, who was murdered in Paris in May 1996.

Which brings us to the question of why the drop-off since 1996? Arguably, Iran finally abandoned its campaign of overseas assassinations in large part because of growing international pressure over its activities.

At first, the global response to the spate of killings—sanctioned by those at the very top of the Iranian government—had much to be desired in the way of severity and a demand for accountability. While this predated the delivery of information in real time and social media outrage, authorities were nonetheless accused of moving too slowly in some cases, and outright botching investigations in others, or worse still, allowing perpetrators to escape under diplomatic cover.

While the initial response to many of these killings certainly did not go far enough, arguably the trial of the Mykonos murders in Germany—which met for a total of 246 sessions, heard 176 witnesses and lasted three and a half years—was a key factor in curbing Tehran’s “adventures” abroad. 

The Mykonos murders refers to an incident in September 1992, at the Mykonos Restaurant in Berlin, where Ghassemlou’s successor, Sadegh Sharafkandi, and three others were shot and killed.

The trial resulted in German authorities ruling that the Iranian government was “directly involved” in the Mykonos murders. In March 1996, a chief German federal prosecutor took the unprecedented step of issuing an international arrest warrant for Ali Fallahian, Iran’s Minister of Intelligence at the time.

Also implicated in other extraterritorial killings, Fallahian is now the subject of no less than three international arrest warrants. Since November 2007, he has been the subject of an Interpol Red Notice, making him one of the world’s highest profile fugitives from justice. 

To be sure, Fallahian remains an influential figure in Iranian politics but the warrants against him have restricted his movements abroad. At the moment, given the limp statements of world leaders, and smiling photo ops with US Secretary of State Mike Pompeo and Saudi Arabia’s Crown Prince Mohammed bin Salman, it’s hard to imagine similar decisive action being taken towards the Crown Prince or any Saudi officials.

But leaders must move in that direction. The decision to dispatch a Saudi hit team to take out Khashoggi in the Istanbul consulate—legal question over the special status of a consulate aside—is a flagrant violation of international laws that sets a dangerous precedent if unchecked.

Specifically, it’s an exercise in operational and psychological intimidation: a message to all dissidents seeking refuge abroad that the regime’s long reach is not limited by national boundaries.

However, there remains a bright spot of hope. The fact that the Kingdom now appears to be shifting its story to admit that Khashoggi died under interrogation, or that Khashoggi died after a fist-fight in the consulate, after previously maintaining a full-throttled denial for days of any involvement, shows that pressure works. 

In this case the pressure came in the form of powerful companies pulling out of a high-profile investment summit, known as “Davos in the Desert,” happening later this week in Riyadh—nonetheless that message was no doubt heard. 

The financial power that the world yields in the Saudi case is even more potent as a pressure lever than similar moves could ever have been in the case of Iran, which by the 1980s was already being treated as a pariah state and cut off from the world’s economy.

Given that financial bargaining chip, now is the time for world leaders to stop their equivocations and state that this brutality beyond borders will not be condoned. For guidance, they can look to the Iran example and what further assassinations would have gone unchecked had legal action not be taken.

The idea that the international community bears responsibility for abuses that occur within borders, just as much as violations that cross borders and are “international” by definition, may remain controversial in some corners. But certainly, demanding accountability and justice for what appears to be a brutal, targeted hit of a dissident outside of the Kingdom’s contiguous borders should not be in dispute. The world must respond swiftly—or risk setting a precedent for the stifling of free thought it will soon regret.

Gissou Nia is a human rights lawyer and board chair of the Iran Human Rights Documentation Center. Follow her on Twitter: @GissouNia.

Image: The grave of Shapour Bakhtiar in Montparnasse Cemetery in Paris, France (seculardemocrat.org)