Treasury Deserves Commendation for Expanding Sanctions on Iran’s Islamic Revolutionary Guard Corps

On October 31, the U.S. Treasury Department Office of Foreign Asset Control (OFAC) updated its Specially Designated Nationals (SDN) List, applying new sanctions to several individuals and entities affiliated with Iran’s Islamic Revolutionary Guard Corps (IRGC) for their role in supporting the IRGC’s terroristic and ballistic missile proliferation activities. The latest actions build upon the Trump administration’s announcement on October 13 that it was designating the IRGC as a terrorist group pursuant to Executive Order (E.O.) 13224.

Prior to October 13, the IRGC was sanctioned in its entirety in 2007, 2011, and 2012 under  E.O.s 13382, 13553, and 13606 respectively for its human rights and non-proliferation abuses. OFAC’s October 13th designation rightfully corrected an existing anomaly in U.S. policy, whereby the IRGC’s Quds Force –its foreign expeditionary arm—was designated under Executive Order 13224 for its support of terrorism, while the IRGC itself was not. In reality, there is no meaningful distinction between the IRGC and the Quds Force, as both ultimately report to the supreme leader, and the organizations frequently share resources and personnel.

Treasury Secretary Steven Mnuchin affirmed the hollowness of the distinction in an October 13th statement, recognizing the central role the IRGC has played in Iran becoming the world’s foremost state sponsor of terrorism, and stating that the designation was a result of the IRGC’s provision of support for the “IRGC-Quds Force, the key Iranian entity enabling Syrian President Bashar al-Assad’s relentless campaign of brutal violence against his own people, as well as the lethal activities of Hizballah, Hamas, and other terrorist groups.”

The IRGC’s designation under Executive Order 13224 is a crucial and commendable component of the Trump administration’s comprehensive Iran strategy which the president articulated on October 13. Trump’s strategy centers on correcting shortcomings in the Joint Comprehensive Plan of Action (JCPOA) which will allow Iran to dramatically shrink its breakout time toward a nuclear weapon when key provisions sunset, and on renewing America’s commitment to pushing back against Iran’s malign efforts to destabilize the Middle East, which Iran has rapidly accelerated since the nuclear deal went into effect.

OFAC’s October 13th designation of the IRGC and subsequent October 31st expansion of sanctions targeting the IRGC are wholly consistent with the letter and spirit of the JCPOA. Guidance issued by the Obama administration on Implementation Day of the deal made clear that “the USG retains the authority to continue imposing sanctions under authorities not included within the scope of section 4 of Annex II, including those used to address Iran’s: support for terrorism, support for persons involved in human rights abuses in Syria or for the Government of Syria, support for persons threatening the peace, security, or stability of Yemen, human rights abuses, and ballistic missile program.”

The October 31st expansion of sanctions most notably targets the IRGC Air Force, the Al-Ghadir Missile Command (which exercises operational control of Iran’s ballistic missile program), the Research and Self-Sufficiency Jihad Organization (which is responsible for research and development of Iran’s ballistic missile program), and the Aerospace Force Self Sufficiency Jihad Organization (which is involved in Iran's ballistic missile research and flight test launches).

The sanctions also targeted IRGC commander Mohammad Ali Jafari and four senior officers. Jafari has commanded the IRGC, the most powerful element of Iran’s security services and the primary instrument of preserving and expanding the Islamic Revolution, since 2007. During his tenure, Jafari has overseen the expansion of Iran’s ballistic missile program, the brutal suppression of domestic dissent, and the acceleration of Iran’s meddling in Iran, Syria, and Yemen. Jafari’s deputy, Brigadier General Mohammad Hejazi, was also designated on October 31. Hejazi, who previously served as commander of the IRGC’s basij paramilitary force, is an ultra-hardliner who has played a leading role in violently stifling reformist efforts such as the 1999 Tehran student protests and 2009 Green Movement.

Designating the IRGC was perhaps the most important leverage available to the U.S. to contain Iran’s support for terrorism and expansionist goals, a move which Iran sought to prevent with characteristic bluster that belied its obvious concern. Prior to OFAC’s actions, IRGC commander Mohammad Ali Jafari, warned the U.S. against targeting the IRGC on October 8, stating, “As we’ve announced in the past, if America’s new law for sanctions is passed, this country will have to move their regional bases outside the 2,000 km range of Iran’s missiles.” The Trump administration’s decision to expand sanctions against the IRGC, which opaquely exerts pervasive control over virtually all sectors of the Iranian economy, underscores the risk global businesses face trading and investing in Iran.

Jordan Steckler is a research analyst at United Against Nuclear Iran (UANI)