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The US Neutrality Acts of 1935 and 1936 https://en.wikipedia.org/wiki/Neutrality_Acts_of_1930s which imposed an arms embargo on belligerents did not apply to civil wars. (It had been assumed that such wars, unlike international ones, created little risk of US involvement, so there was no need to change the historic policy of allowing private businesses to sell arms to the recognized government.) So when the Spanish Civil War broke out, the Roosevelt administration resorted to a "moral embargo" (i.e., moral suasion on US businesses not to do what they had a legal right to do) According to Robert Divine (*The Illusion of Neutrality*):

"Throughout the fall of 1936, American manufacturers and exporters scrupulously observed the moral embargo. In late December, however, several individuals applied for permission to export airplanes to the Spanish government. Unable to withhold export licenses legally, the State Department announced on December 28 that it had granted permission to Robert Cuse, a New Jersey scrap-dealer, to sell over $2 million worth of airplane parts and engines to the Loyalists. The Department had tried hard to dissuade Cuse, but he firmly demanded his rights. At a press conference the next day, President Roosevelt denounced Cuse's action as legal but unpatriotic.

"This breach of the moral embargo led to a series of hasty conferences between Roosevelt, State Department officials, and congressional leaders. Roosevelt had originally intended to ask Congress to include discretionary power to embargo arms to civil wars when it tackled the general problem of neutrality revision. Now the President, fearing the shipment of war materials from the United States would undermine the efforts of the European Non-intervention Committee, decided to ask for immediate action by Congress on a civil war embargo when it convened on January 5..."

https://archive.org/stream/illusionofneutra030798mbp#page/n183/mode/2up

Even if he had wanted to, it would have been politically impossible for FDR to have avoided an arms embargo to Spain once the "moral embargo" failed. Only *one* member of the House of Representatives voted against the embargo--John Toussaint Bernard, https://en.wikipedia.org/wiki/John_Bernard_(American_politician) a Farmer-Laborite from Minnesota. Bernard was an interesting character: He was the only Corsican-born American ever elected to Congress AFAIK. He was very close to the Communist Party, appointed open Party members to his staff, and was the only congressman to insert articles from the *Daily Worker* into the Congressional Record. (Decades later, he would be the only ex-Congressman ever to become an open member of the Party.) He had an excellent singing voice and sometimes startled his congressional colleagues by launching into the *Internationale* in Washington DC restaurants. (Harvey Klehr, *The Heyday of American Communism*, p. 291) "Minnesota Communist leader Nat Ross, who claimed to have convinced Bernard to run for Congress, maintained that the Communist Party's national leaders pushed Bernard into taking positions that isolated him from his constituency. Earl Browder explained how this could have been done when he commented that Bernard was 'a good man but a man who let other people completely do his thinking.'" https://books.google.com/books?id=fRTH9n7djt4C&pg=PA30 Not very surprisingly, he was only a one-term Congressman. He was defeated in 1938, partly as a result of a general public backlash in Minnesota against Communist influence in the Farmer Labor Party, and in part because the AFL was displeased by his open favoritism toward the CIO--he was even employed while a Congressman by the Steel Workers Organizing Committee. When someone like John Toussaint Bernard is the *only* vote against the Spanish arms embargo, there isn't much chance of defeating it...

BTW, as for whether FDR should have imposed the moral embargo in the first place, remember that it was approved not only by isolationists but also by most advocates of collective security, who saw it as a form of cooperation with the Non-Intervention Committee organized by the UK and France. And not incidentally, a presidential election was coming up, and FDR wanted the Catholic vote. Maybe by favoring the sale of arms to the Spanish Republic he could have taken a handful of votes away from Earl Browder, but that would hardly have compensated. (Whether American Catholics were really as pro-Franco as they were stereotyped didn't really matter politically as long as they were *thought* to be. Besides, even Catholics--and others--with serious objections to Franco might frown on sales of arms to the left-wing and anticlerical Republic.) In any event, the lack of a moral embargo would simply have led to quicker congressional enactment of a mandatory embargo by veto-proof majorities.

For these reasons, I have in the past dismissed any "what if the US had not embargoed arms to Spain" questions as politically implausible. However, what I did not realize was that there is a separate question: "What if the US had later lifted the embargo on arms to Spain?" For there *was* a very serious movement to do this--which, to my surprise, had the backing of "Mr. Neutrality" himself, Gerald Nye, often considered the epitome of isolationism.

What happened basically is that people realized that "non-intervention" was not working.

"The adamant refusal of the House Foreign Affairs Committee to reopen the subject of general neutrality legislation finally led those favoring revision to concentrate on one issue the Spanish arms embargo. Though Congress had voted overwhelmingly for the embargo on Spain in January, 1937, the course of the Civil War created growing doubts about the wisdom and fairness of this policy. Increasing evidence that Germany and Italy were supplying guns, planes, and even troops to Franco's forces indicated that the British and French efforts at limiting the war had failed. Since the American embargo was based largely on the idea of co-operating with the non-intervention policy of the European democracies, many Americans now felt that the United States should abandon the embargo and revert to its traditional policy of selling arms to the established government, in this case the Spanish Loyalists. The first sign of the growing dissatisfaction with the embargo came in March, 1937, when Senator Nye introduced a resolution suggesting that the Spanish arms embargo be extended to include other nations participating in the civil war. Secretary Hull, who feared that any open American recognition of German and Italian aid to Franco would undermine the British and French efforts at non-intervention, strongly opposed this measure, and his views prevailed. On June 2, 1937, following an announcement by President Roosevelt that the American policy toward the Spanish Civil War remained unchanged, the Senate Foreign Relations Committee tabled the Nye resolution...

"The demand for applying the arms embargo to Italy and Germany gave way in the spring of 1938 to a new attempt to repeal the embargo on Spain. Liberal groups, passionately sympathetic to the Loyalists, pointed to the injustice in denying arms to the established government of Spain and charged that the American policy aided the Fascist cause; ". . . failure to act," wrote the editors of the *Nation*, "so encourages the fascist powers that it constitutes a clear challenge not only to peace but to the philosophy on which all decent international relations must rest." Even the *New Republic*, which staunchly defended the neutrality act, favored an exception for Spain. A wide variety of prominent Americans, from Henry L. Stimson to Norman Thomas, backed the drive for repeal of the embargo. College faculties, left-wing popular front organizations, Protestant clergymen, and the international wing of the peace movement all added their voices to the cause. The crusade for repeal reached substantial proportions when Senator Nye introduced a resolution proposing that the United States lift the embargo on the Loyalists, as the established government, but continue to deny the export of arms to the Rebels. To guard against provocative incidents, Nye included a cash-and-carry provision for all arms exports to the Spanish Loyalists. With the most outspoken champion of neutrality legislation now leading the demand for repeal, the prospects for a change in policy suddenly appeared favorable.

"The Nye resolution placed the Roosevelt administration in a serious dilemma. Though public opinion polls showed that most Americans were indifferent to the outcome of the Spanish Civil War, the conflict had created intense partisanship among small but vocal sections of the population. In general, liberal groups, which strongly supported the New Deal, sided with the Loyalists, while the Catholic hierarchy, as well as many Catholic laymen of Irish and Italian descent, favored Franco's Rebels. Both groups represented important segments of the political coalition on which Roosevelt had risen to power. Confronted with a choice which inevitably would alienate some of his political supporters, Roosevelt hesitated. In a private press conference with newspaper editors in April, he defended the embargo on the grounds that any change would aid the Rebels, who Roosevelt claimed now controlled the seaports of Spain. In a private conversation with Secretary of the Interior Harold L. Ickes on May 1, Roosevelt repeated this defense of his policy, but Ickes scoffed at it, feeling that Roosevelt was trying to evade the issue. The next week, Roosevelt departed on a Caribbean fishing cruise, leaving the difficult Spanish problem for the State Department to study.

"Though the discussions inside the State Department remain shrouded in mystery, there is substantial evidence that Hull and his advisers reached a tentative decision to support repeal of the embargo for both belligerents in the Spanish war. In their syndicated newspaper column, Drew Pearson and Robert S. Allen reported that the top officials of the State Department reached this conclusion at a conference on May 3, 1938. Two days later, the *New York Times* published a front-page story asserting that the administration had not only decided to support the Nye resolution, but that it had lined up sufficient votes to assure passage of the measure in both houses of Congress. This report alarmed the pro-Franco elements in the United States, and when Roosevelt returned to Washington on May 9, a great controversy was raging. The President conferred with Secretary Hull, and then met with a number of congressional leaders, including McReynolds and Sam Rayburn, House majority leader, who both indicated their opposition to the Nye resolution. 87 When the Senate Foreign Relations Committee met on May 13, Senator Pittman read a letter from Hull firmly opposing repeal of the Spanish arms embargo. Stating that the embargo had been enacted by Congress to prevent incidents that might involve the United States in the Spanish Civil War, Hull declared that repeal "would still subject us to unnecessary risks we have so far avoided. We do not know what lies ahead in the Spanish situation. The original danger still exists." Hull then suggested that instead of dealing with questions of neutrality revision piecemeal, the committee should undertake a broad study of the whole problem.

"The Senate Foreign Relations Committee immediately followed the administration's recommendation and tabled the Nye resolution by a vote of 17 to 1. This action effectively killed the hopes of liberals for repeal of the Spanish arms embargo. In bitter editorials, the *Nation* and the *New Republic* denounced the administration. Calling Hull's letter to Pittman "one of the most reactionary state papers in history," the liberal journals accused Roosevelt and Hull of submitting to pressure from both the Catholic hierarchy in the United States and the appeasers in the British Foreign Office. Both charges contain some substance, but there were other considerations that influenced Roosevelt's decision. The State Department, and especially Cordell Hull, hoped to establish closer relations with England and France by upholding their non-intervention policy. Hull also feared that a determined effort to alter neutrality legislation would create a dangerous controversy in Congress. Probably the dominant consideration related to the domestic political scene. With the New Deal coalition disintegrating after the Supreme Court fight, Roosevelt did not dare endanger the large Catholic vote that was vital to the Democratic political machine. By retaining the embargo, he only antagonized liberals who would continue to support his domestic reform program, not on the basis of personal loyalty, but out of conviction and principle..."

FDR later called the embargo a "grave mistake" according to Harold Ickes. [1] (According to Divine, "Ickes reports Roosevelt making this remark at a cabinet meeting on January 27, 1939." https://archive.org/stream/illusionofneutra030798mbp#page/n243/mode/2up) If he had come out for repeal in 1938, it is possible that repeal would have passed. What would the consequences have been?

I used to think that those consequences would be minimal. The Spanish Republic's problems, I thought, were not caused by an arms shortage; it got plenty of arms from the Soviet Union and--despite "non-intervention"--illegally from the western democracies. Halifax was later to write of the Non-Intervention Committee, "I doubt whether a single man or gun less reached either side in the war as a result of its activities." (Walter Krivitsky, a Soviet agent who defected, later wrote that "Such is the nature of the munitions trade that we even bought arms in Nazi Germany....The director of the German firm was interested in nothing but the price, the bank references and the legal papers of consignment." https://books.google.com/books?id=Vridb83sKIAC&pg=RA2-PA1908 Krivitsky would later be found dead in a Washington, DC hotel in 1941--a "suicide"...) However, a reading of Gerald Howson's *Arms for Spain: The Untold Story of the Spanish Civil War* has made me re-think this. Howson's conclusion was (pp. 250-1):

"Arms could *not* 'always be obtained for gold or hard currency': on the contrary, the Republicans rarely obtained more than a fraction of what they needed and even then only after long delays and at a terrible cost...they were faced by a wall of blackmail wherever they turned: by ministers of government, chiefs-of-staff and other officers and officials in more than thirty countries who demanded bribes of between £5,000 ($25,000) and £45,000 ($275,000) a time, in 1937 money, for their signatures on dubious export licenses. Below them were officials down to harbour- and station-masters who not only demanded bribes but found pretexts to delay transportation in order to charge accumulating 'storage fees,' of which one, it may be remembered, rose to as much as £10,000 ($50,000). How often, too, the ministers and officials changed their minds, found ways to withhold delivery of the material and to refuse to return the money! And below them again were the arms dealers, brokers and other go-betweens. Yet such behaviour appears trivial beside that of the Soviets, whose defrauding of the Spanish government of millions of dollars, by secretly manipulating the exchange rates when setting the prices for the goods they were supplying, belied everything they professed to stand for..."

So would it have made any difference if the Republic had been able to get arms from the US, arms whose prices would not have to be inflated by bribes? I don't know, because realistically it seems that the earliest the embargo could be lifted was 1938, and that might be too late for the Republic. OTOH, given the outrage over the bombing of Guernica, it's not *totally* inconceivable that--with the backing of people like Senator Nye, who had been noted for their devotion to neutrality--he could have gotten it lifted in 1937 if he had not been preoccupied and weakened by the court-packing fiasco. And would lifting the embargo really have hurt FDR in the 1938 elections? I doubt it. According to Divine, "A Gallup poll, taken in January, 1937, showed that 66 per cent of the people interviewed sympathized with neither side in the Spanish Civil War, 22 per cent with the Loyalists, and 12 per cent with the Rebels. A Fortune poll taken three months later gave almost identical results." https://archive.org/stream/illusionofneutra030798mbp#page/n239/mode/2up/ And one doubts that even most of the 12 percent who sympathized with Franco were one-issue voters.

In any event, one person evidently not persuaded that the arms embargo was insignificant was General Franco. He praised Roosevelt for a policy which he viewed as "a gesture we Nationalists will never forget." https://books.google.com/books?id=z9ZKDgAAQBAJ&pg=PA209

[1] FDR never acknowledged this publicly, though. As Richard Hofstadter noted in *The American Political Tradition,* "Editing his public papers in 1941, Roosevelt insisted that it was 'useless to argue' that Spain was the proper place for the European democracies to have stopped the aggressor nations. As for the United States, its people were unwilling to risk 'the slightest chance of becoming involved in a quarrel in Europe which had all the possibilities of developing into a general European conflict.' Further, he said, the fascists had more shipping than the Republican government, and if American goods had been available to both sides the fascists would probably have bought more. This was a shifty argument. The United States was not limited to the alternative of selling to both sides or neither. It would have been more consistent with American precedent, 'international law,' and American treaty obligations to continue normal economic relations with a government recognized de jure and to embargo shipments to a revolutionary faction." In any event, even selling arms to both sides might have been a net benefit to the Republic, given the point Howson makes about how much harder a time it had getting arms than Franco's forces did. See https://quod.lib.umich.edu/p/ppotpus/4926313.1937.001/270?page=root;size=100;view=image for FDR's 1941 comments.
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