U.K. Iran Policy Recommendations

The Anglo-American bond is based on common interests and values. This should enable the two nations to develop a shared, robust strategy to thwart Iran’s malign activities at home and abroad.

In light of Iran’s supply of lethal weaponry to Russia for use against an EU candidate country Ukraine, its sponsorship of terrorism, and its human rights abuses, the U.K. government should pursue new effective policies, including: designating the Islamic Revolutionary Guard Corps (IRGC) as a proscribed terrorist organization; leading an effort in the U.N. Security Council to snapback sanctions on Iran under U.N. Security Council Resolution 2231; downgrading diplomatic relations with Tehran; and sanctioning Iran’s top leadership.

A Shared History

Iran’s leadership has consistently labeled the U.K. as the “Old Fox” while America has been known as the “Great Satan” in regime lore. Relations over the past four decades have been peppered by malicious Iranian activities targeting British interests. At its founding in 1979, militants assaulted the British as well as the American embassies in Tehran. In 1987, during the height of the Iran-Iraq War, when Tehran accused London of supporting Saddam Hussein’s war effort, Iranian agents kidnapped and beat Edward Chaplin, the first secretary of the British interests section at the Swedish embassy in Tehran. In 2007, the IRGC detained Royal Navy sailors patrolling the Persian Gulf. In 2011, Iranian protesters stormed the United Kingdom’s embassy in Tehran—an incident which the British ambassador claimed was “with the acquiescence and the support of the state.”

In recent years, the United Kingdom has arrested Iranian proxies for attempted assassinations and other terrorist threats on British soil, including the stockpiling of bomb-making materials on the outskirts of London in 2015. Relations have worsened markedly since 2019, which saw Iran detain a British-flagged tanker in response to marines detaining an Iranian tanker destined to illegally export oil to Syria’s Assad regime. Iran continues to jail American and British dual-nationals who have been imprisoned on trumped-up charges without due process, including Morad Tahbaz. In January 2020, Iran went as far as arresting the British ambassador for his attendance at a vigil for the victims of the IRGC’s downing of a Ukrainian jetliner.

That is not to mention the serious threats against Iranian diaspora media networks like Iran International TV in London over 2022 and 2023, where IRGC-linked hostile surveillance teams and other threats have prompted the need for police protection for its senior executives and staff. As the director-general of MI5 recently revealed, the U.K. government has “seen at least ten” potential kidnapping or assassination threats against British or U.K.-based individuals perceived as enemies of the regime since January 2022 alone. There was a significant escalation in January 2023, when Tehran executed Alireza Akbari, a British-Iranian dual-national who was a former regime official. Akbari was reportedly lured back to Tehran by his old friend the Secretary of the Supreme National Security Council (SNSC) Ali Shamkhani and later detained. British officials assess this is the first time since the 1980s when the Iranian government has executed a dual-national.

It is therefore in Britain’s interests to take a tougher approach on Iran, especially given that negotiations over reviving the Joint Comprehensive Plan of Action (JCPOA) of 2015 appear dead. As the chair of the UK House of Commons Foreign Affairs Committee Alicia Kearns recently said, “no more can Iran set the parameters for our relationship.”

Recommendations:

1. Designation of the IRGC as a Proscribed Terrorist Organization

In an unprecedented move, the U.S. government designated the IRGC as a foreign terrorist organization (FTO) in April 2019. Adding the IRGC to this hall of infamy was the first time Washington styled a state organ as an FTO—and despite the many doomsday predictions which followed, it did not produce a war. The United States had previously sanctioned the IRGC as a terrorist organization under existing authorities like Executive Order 13224. But the FTO decision represented a force multiplier in the existing U.S. sanctions architecture against Iran by criminalizing the knowing provision of material support to the IRGC with extraterritorial reach.

The United Kingdom maintains a similar list of proscribed terrorist organizations. Pursuant to the Terrorism Act of 2000, the home secretary is charged with proscribing such organizations if he/she “believes it is concerned in terrorism, and it is proportionate to do.” Accordingly, this means the organization “commits or participates in acts of terrorism; prepares for terrorism; promotes or encourages terrorism (including the unlawful glorification of terrorism); or is otherwise concerned in terrorism.”

The IRGC clearly meets these criteria, given its record in threatening British nationals dating back to the 1980s. News accounts indicate that elements of the IRGC were responsible for the abduction and assault on U.K. diplomat Edward Chaplin in 1987. In 2007, Shiite militants, under the direction of the IRGC, kidnapped British computer expert Peter Moore and murdered four British security guards in Iraq. In 2016, 40 Iranian state media outlets contributed $600,000 as a bounty for the death of British-American author Salman Rushdie on the anniversary of Ayatollah Ruhollah Khomeini’s fatwa against Rushdie for his publication of The Satanic Verses.  One of the outlets, Fars News Agency, is affiliated with the IRGC and committed $30,000 alone to the bounty, and Iran’s supreme leader’s own website has affirmed the 1989 Khomeini fatwa. In the summer of 2022, this incitement likely led to the stabbing of Rushdie in New York, where he lost sight in one eye and use of a hand. The culprit in the case sympathized with IRGC leadership—including the late Quds Force Commander Qassem Soleimani and its proxy Hezbollah—and may even have had contact with the IRGC. This incident caused the U.S. government to sanction the 15 Khordad Foundation, subordinate to Khamenei’s office, which maintains a multi-million dollar bounty on Rushdie to this day. That’s not to mention the IRGC’s seizure of the Stena Impero and the attempted impoundment of the British Heritage in 2019 or the IRGC’s Aerospace Force’s droning of the Mercer Street in July 2021, which resulted in the death of a U.K. national.

Any of these incidents would fall under the United Kingdom’s definition of terrorism.[1] The Chaplin abduction involved “serious violence against a person” given his severe beating.  It was also “designed to influence the government” for the purpose of “advancing a political cause” given Iran’s accusations of British complicity in Saddam Hussein’s onslaught during the Iran-Iraq War. Ditto for the seizure of Peter Moore, which endangered his life, and was likely committed to intimidate U.K. forces stabilizing Iraq. Salman Rushdie’s experience is also terrorism since the Khomeini fatwa and Khamenei’s affirmation were threats of action which endangered his life; they were intended to intimidate the public’s free expression; and were undertaken “for the purpose of advancing a religious cause.” IRGC satellites—including a member of Hezbollah—have attempted to kill Rushdie in the past, including Mustafa Mahmoud Mazeh, a Hezbollah member, who died when a book bomb he wanted to use to target Rushdie exploded in a London hotel in 1989. Hezbollah had vowed to carry out the Khomeini fatwa.

The capture of the Stena Impero and attempted apprehension of the British Heritage is also terrorism—it involved the use and threat of action which involves serious damage to property—the vessels—and created a serious risk to the health or safety of a section of the public. This piracy was also designed to influence the government—specifically its lawful seizure of the Grace 1—and was undertaken for the purpose of advancing a political cause—namely the Islamic Republic’s desire for political retribution and intimidation of the government of the United Kingdom to provide Tehran with the sanctions relief it is desperately seeking. The IRGC’s attack on the Mercer Street likewise meets the definition of terrorism as the launch of a lethal drone at the Mercer Street merchant vessel resulted in the death of two European nationals and was a “deliberate and targeted attack,” according to G7 foreign ministers. It was designed to influence the public given the ship’s perceived connection to Israel.

The last consideration is whether the proscription would be proportionate.[2] Such a designation would be entirely proportionate. The U.K. government has already led the way in joining the United States in proscribing Hezbollah, in its entirety, as a terrorist organization in March 2019.  Hezbollah is a satellite of the IRGC. Some estimates indicate Iran in recent years has supplied Hezbollah with over $800 million annually—accounting for over three-quarters of the organization’s budget. The same goes for Bahrain’s al-Ashtar Brigades, an Iranian proxy, which is proscribed by both the U.S. and U.K. governments. Indeed, in the past, the United Kingdom has sanctioned the IRGC’s top brass in their individual capacities—Hossein Salami, the IRGC’s commander-in-chief, and Qassem Soleimani, the former head of its Quds Force, have both appeared on its financial sanctions target list. If the home secretary has found Hezbollah and the al-Ashtar Brigades to be threats to the United Kingdom, their patron, the IRGC, surely shares that status. Likewise, if Britain has a history of sanctioning senior IRGC commanders, the militia’s characterization as a terrorist organization is appropriate. 

Lastly, one of the factors the U.K. government is required to consider is “the need to support other members of the international community in the global fight against terrorism.”  Supporting the U.S. government’s groundbreaking decision to name the IRGC as an FTO—and in the process thwarting the IRGC’s enduring threat to the United Kingdom and transnational repression—is in Britain’s national interests. Indeed, there’s growing support for such a move—in 2023 the U.K. House of Commons unanimously passed a resolution calling for its proscription. 

2. SnapBack Sanctions

U.N. Security Council Resolution 2231 enshrined and endorsed the JCPOA. Despite the U.S. withdrawal from the JCPOA, Resolution 2231 remains in effect. The international arms embargo imposed on Iran under Resolution 2231 expired on October 18, 2020. This means that the supply, sale, or transfer of any guns, howitzers, mortars, battle tanks, armored combat vehicles, combat aircraft, attack helicopters, warships, and missiles or missile systems to or from Iran no longer requires U.N. Security Council approval. U.N. member-states are also no longer obligated to prevent such arms-transfers from Iran. The expiration of this arms embargo is already having immediate destabilizing effects, providing Iran and Russia legal cover to transfer lethal drones and potentially soon surface-to-surface missiles for use against civilians and critical infrastructure in Ukraine. According to press reports, Russia may in turn be poised to send Iran Sukhoi Su-35 fighter jets, which would have been prohibited had the U.N. arms embargo on Iran remained in effect. Likewise, by October 18, 2023, Resolution 2231’s restrictions on Iran’s missile program expire. It is this very provision which London and its allies are relying on to hold Iran accountable for its proliferation of drones to Russia as models like the Shahed-136 that are being sent to Moscow are embargoed under the resolution.

UANI has been warning of these JCPOA sunsets for years. Such expirations directly threaten U.K. security. Hossein Salami, the IRGC’s commander-in-chief, warned in 2017 that Iran is prepared to increase the range of its missiles to greater than 2,000 kilometers, threatening Britain and potentially the United States. Salami said, “[i]f we have kept the range of our missiles to 2,000 kilometers, it’s not due to lack of technology… We are following a strategic doctrine…So far we have felt that Europe is not a threat, so we did not increase the range of our missiles. But if Europe wants to turn into a threat, we will increase the range of our missiles.” Resolution 2231’s sunsets only enable such blackmail. 

Given the deep freeze in the negotiations over reviving the JCPOA and the urgency of the war in Ukraine, the U.K. government should support snapback sanctions which would restore the pre-JCPOA international arms restrictions architecture, like U.N. Security Council Resolution 1929.[3] The JCPOA, in its current form, should be declared dead.

3. Diplomatic Isolation

The U.K. government currently maintains full diplomatic relations with Iran. London’s ambassador to Iran is Simon Shercliff, while Iran maintains representation at the chargé d'affaires level. There are reportedly around 10-15 Iranian diplomats in the United Kingdom. In addition, the U.K. government allows the Islamic Center of England to operate, despite serving as effectively a representative office of Iran’s supreme leader on British soil. Its director, Seyed Hashem Moosavi, was appointed directly by Khamenei. British media exposed how the Islamic Center of England was given £100,000 from a Covid-19 aid program sponsored by the U.K. government.

This is not to mention the troubling reports that schoolchildren were given special classes honoring the late Quds Force Commander Qasem Soleimani, who had the blood of British troops on his hands. The Jewish Chronicle reported mosques in London, Luton, Birmingham, and Manchester, which all have charitable status and are entitled to U.K. tax breaks, “organized the events including at least two where children were encouraged to learn about Soleimani’s life.” There are additional concerning indications, reported by The Jewish Chronicle, that The Islamic College (ICL), affiliated with Middlesex University, may be linked to Al-Mustafa International University. Al-Mustafa International University is a recruiting ground for the IRGC’s Quds Force, and the U.S. government has levied terrorism sanctions on the university. According to the U.S. Treasury Department, “the IRGC’s Quds Force uses Al-Mustafa University to develop student exchanges with foreign universities for the purposes of indoctrinating and recruiting foreign sources. Al-Mustafa has facilitated unwitting tourists from western countries to come to Iran, from whom IRGC Quds Force members sought to collect intelligence.” This is all the more concerning given the active Iranian terror threats on U.K. soil.

The U.K. Charity Commission, in turn, has opened a statutory inquiry into the Islamic Center of England over serious governance concerns. Nevertheless, the United Kingdom clearly has allowed Iran’s regime a permissive environment for influence operations. Downgrading diplomatic relations and shuttering Khamenei’s representative office should be a first step in reducing the Iranian regime’s European footprint. The U.K. government has a long history of engaging in such moves. In 1989, after Khomeini’s fatwa was issued calling for the killing of Salman Rushdie, Britain broke diplomatic relations. In 1990, after partial diplomatic relations were restored, the U.K. government accused Iran of engaging with the outlawed Irish Republican Army (IRA), which resulted in the expulsion of diplomats. Given the assassination and kidnapping plots hatched by the Iranian state targeting individuals residing in the United Kingdom over the last year, that should provide enough impetus to declare discrete Iranian diplomats personae non-grata and to withdraw the British ambassador from Tehran. The incidents in 1989 and 1994 provide the precedents.

4. Sanctioning the Khamenei Family and President Ebrahim Raisi

The U.K. government should also personally sanction Iran’s Supreme Leader Ayatollah Ali Khamenei, his son Mojtaba Khamenei, and President Ebrahim Raisi for human rights abuses. The U.S. government has already sanctioned all three of these men under Executive Order 13876, which targets the Office of Iran’s Supreme Leader and his appointees. The U.K. government has in the past sanctioned Russia’s President Vladimir Putin and Syria’s President Bashar al-Assad. There is no reason why Iran’s supreme leader should be treated any differently given his singular role in the four decades of the Islamic Republic’s bloodstained rule. Additionally, the U.K. government has even sanctioned the wife of Bashar al-Assad—Asma al-Assad, who holds U.K. citizenship. Mojtaba Khamenei, who wields great influence in his father’s office and holds no U.K. citizenship, should be similarly sanctioned. There have been allegations that Mojtaba was linked to a $1.6 billion bank account that the U.K. government seized in 2009.

Conclusion

Along with the special relationship between the United States and the United Kingdom comes a special responsibility to jointly combat global threats such as Iran. With likely greater foreign policy latitude, Brexit provides the United Kingdom with an opportunity for a reset on Iran policy. The Islamic Republic, rather than acting like a normal country, remains a radical cause. These recommendations will go a long way in recognizing that truth and dealing with it effectively.

 

Endnotes

1. Terrorism, according to the Terrorism Act of 2000, “means the use or threat of action which: involves serious violence against a person; involves serious damage to property; endangers a person’s life (other than that of the person committing the act); creates a serious risk to the health or safety of the public or section of the public; or is designed seriously to interfere with or seriously to disrupt an electronic system.  The use or threat of such action must be designed to influence the government or an international governmental organisation or to intimidate the public or a section of the public, and must be undertaken for the purpose of advancing a political, religious, racial or ideological cause.”
2.  According to the U.K. criteria, “In considering whether to exercise this discretion, the Secretary of State will take into account other factors, including: the nature and scale of an organisation’s activities; the specific threat that it poses to the UK; the specific threat that it poses to British nationals overseas; the extent of the organisation’s presence in the UK; and the need to support other members of the international community in the global fight against terrorism.”
3. Instead of “calls upon” standard adopted by U.N. Security Council Resolution 2231, Resolution 1929 stated, “Iran shall not undertake any activity related to ballistic missiles capable of delivering nuclear weapons, including launches using ballistic missile technology, and that States shall take… necessary measures to prevent the transfer of technology or technical assistance to Iran related to such activities.”