U.S. To Designate the IRGC, Affiliates as Terrorists

President Donald Trump signed wide-ranging Congressional sanctions against Iran, North Korea and Russia last week. Known as the Countering America’s Adversaries Through Sanctions Act, the law’s Iran section requires the president to extend a terrorism designation pursuant to Executive Order (E.O.) 13224 to Iran’s Islamic Revolutionary Guard Corps (IRGC) and its foreign agents and affiliates by Nov. 1.

The law’s Sec. 105 (3) states, “The IRGC, not just the IRGC-QF [the Qods Force, the Guard’s extraterritorial branch], is responsible for implementing Iran’s international program of destabilizing activities, support for acts of international terrorism, and ballistic missile program.”

E.O. 13224 is an authority aimed at freezing the assets of terrorists and their supporters, while isolating them from the US financial and commercial systems, according to Treasury.

In 2007, the US designated the Qods Force for terrorism pursuant to the same order.

Guard-owned companies would be eligible for designation as supporters of terrorism. The Revolutionary Guard has deeply penetrated key sectors of the Iranian economy, drawing on these resources to generate funds and support its military and civilian programs. For instance, a front company for the Qods Force, the Headquarters for the Restoration of Holy Shrines, raises funds and develops shrines in Iraq to project soft war and act as a pipeline for the force’s operations. Hundreds of companies, including major corporations traded on the Tehran Stock Exchange, are controlled by Revolutionary Guard foundations and a network of current and former Guardsmen.

Companies and foundations owned by the supreme leader that fund the Revolutionary Guard’s proxies would also be eligible for designation. According to Western intelligence reports, the supreme leader’s foundations provide financial support to Lebanese Hezbollah, which the US has classified as a terrorist group. Abdallah Safieddine, Hezbollah’s representative in Iran, told a reporter in 2012 that his organization receives funding directly from the supreme leader and his conglomerate.

The latest American law appears to require the president to designate the Guard’s external network, as well. Per Sec. 105 (3) (b), the administration must designate “foreign persons” that are “agents” or “affiliates” of the corps. US law defines “agent of a foreign power” as a person who “acts for or on behalf of a foreign power,” which meets the definition for Tehran’s proxies that do its bidding.

Shiite-jihadist groups constitute the overwhelming majority of the Revolutionary Guard’s foreign legion. A number of these militias, such as Lebanese Hezbollah, the Iraqi Hezbollah Brigades and more recently the Bahraini Ashtar Brigades, have already been designated for terrorism. But there at least 40 militias that are not. Many are Iraqi-based groups, and include Afghans, Pakistanis, and Syrians. The numbers are in the tens of thousands. The IRGC is estimated to have trained, funded or armed 65,000 Iraqis, according to a scholar who spoke with Buzz Feed. Director of National Intelligence Dan Coats recently estimated that Iran “manages as many as” 10,000 Afghans, Pakistani and Iraqis in Syria to support Syrian president Bashar al Assad.

Revolutionary Guard commanders have threatened US bases in the Middle East should the US execute the terrorism designation. Chief commander Jafari warned late last month that the US “has to close down all its bases within 1,000 kilometers of Iran and it should realize that it will pay a high price for its miscalculation.” The Armed Forces General Staff chief Major General Mohammad Bagheri said the designation would pose “major risks” to US bases and troops in the region.

“Do they think that the region would remain safe for them when they call our people, corps, and government terrorists?” declared the chief of the Basij Organization, Qolam-Hossein Qeibparvar.

The Guard has attempted to frame this sanction as an action to harm the Iranian people in order to shape the narrative and bolster support.

The Revolutionary Guard’s threat to US bases is real, but these public statements should be taken with a grain of salt. The Guard Corps may attempt to expand its asymmetric strategy while falling below the threshold of a direct attack. During the wars of Iraq and Afghanistan, the Revolutionary Guard provided material assistance to militants targeting American soldiers and in Iraq directly oversaw attacks. It continues to harass the US Navy in the Persian Gulf on a frequent basis. Between May and June, Guard-led militants and Iranian drones challenged a US deconfliction zone near Tanf, Syria, triggering American strikes. Revolutionary Guard commanders, however, have a long record of issuing exaggerated statements to project an image of strength and to deter. Given the immense disparity in conventional capabilities with the US, the Guard prefers to avoid direct military confrontation, which would surely ensue following an attack on US forces.

In the latest law, Congress affirmed the Revolutionary Guard’s proliferation designation pursuant to E.O. 13382 and took an additional step to declare Iran’s missile program an “unusual and extraordinary threat” pursuant to the International Emergency Economic Powers Act. The Revolutionary Guard’s Aerospace Forces are in charge of Iran’s strategic missile force. Congress is expressing its concern about the long-term, potential trajectory of the missile program and advancements in intercontinental-ballistic-missile (ICBM) capability. The US administration is furthermore required to provide assessments of Iran’s chemical and biological weapons capabilities.

Last week’s law also requires the secretaries of State, Defense and Treasury and the Director of National Intelligence to jointly develop and submit to Congress within six months a strategy for deterring Iran’s conventional and asymmetric activities that threaten the US and its allies. The administration is to incorporate a coalition of US allies in this effort.

For the first time, the law has directed the administration to include the Treasury Secretary in the National Security Council.

The president is required to designate any entities that sell heavy weaponry and provide a range of arms assistance to Iran. As a UN arms ban expires on Iran in 2020, Congress is seeking to deter the sales of such weapons to Iran. Congress grants the president the authority to waive this if and when he/she determines that Tehran no longer supports terrorism or presents a threat to the US.

Amir Toumaj is a Research Analyst at Foundation for Defense of Democracies.

This article first appeared at FDD's The Long War Journal.