TSG IntelBrief: Sanctioning Iran’s Revolutionary Guard
March 6, 2017

Sanctioning Iran’s Revolutionary Guard


Bottom Line Up Front:

• The Trump administration is reportedly considering designating Iran’s Islamic Revolutionary Guard Corps (IRGC) as a Foreign Terrorist Organization (FTO).

• Such a move would affirm the U.S. tilt to a harder line on Iran but have little material effect on the IRGC’s operations; the IRGC and Iran are already subject to numerous terrorism-related sanctions.

• Designating the IRGC as an FTO would not necessarily derail the multilateral nuclear agreement, but could provoke an Iranian backlash including Shi’a militia attacks on U.S. forces in the region.

• Naming the IRGC an FTO could also set back the prospects for Iran’s President Hassan Rouhani to win reelection in May.


The Trump administration reportedly is considering naming Iran’s Islamic Revolutionary Guard Corps (IRGC) as a Foreign Terrorist Organization (FTO), a move that would put the IRGC—at least symbolically—on par with organizations such as al-Qaeda, the so-called Islamic StateLebanese HizballahHamasIraqi Shi’a militias, Kashmiri jihadist groups, Palestinian militant groups, and several dozen others. An IRGC designation would represent the first application of the FTO list to a duly-constituted military organization of a foreign government. Such a move would represent a clear departure from the intent of the original 1996 law that created the FTO list, which established that the designation only apply to non-state groups, not to agencies or entities of foreign governments. Using that law to designate the IRGC as an FTO could potentially open the floodgates for calls to designate other governmental agencies that support anti-U.S. activities and groups, including Pakistan’s Inter-Services Intelligence Directorate (ISI), North Korea’s military, and Russian intelligence.

Designating the IRGC as an FTO would reflect the Trump administration’s shift back to the standard U.S. view of Iran since the country’s 1979 revolution—that Iran is an adversary whose regional activities must be countered, and which must be subjected to the strictest economic sanctions possible. This shift—encapsulated by the administration’s February 1 statement putting Iran ‘officially on notice’—departs from the Obama administration’s view of Iran as a potential partner in resolving regional conflicts. In concert with the 2015 multilateral nuclear deal, the Obama administration lifted most U.S. sanctions on Iran’s economy, but no U.S. sanctions on the IRGC or any of its commanders or subordinate units were lifted. Iran also remains on the U.S. list of state sponsors of terrorism. An IRGC FTO designation would therefore not add any significant new sanctions that are not already in place—sanctions that have thus far had little material effect on the IRGC’s operations. An FTO designation for the IRGC would not conflict with U.S. commitments in the Iran nuclear agreement, which places no restriction on any new U.S. sanctions on the IRGC or Iran’s support for terrorism, Iran’s human rights practices, or its missile development. 

Whereas designating the IRGC as an FTO would have little practical effect on the organization, the costs of such a step could be significant. The IRGC-Qods Force (IRGC-QF) and the U.S. military are tacitly, although not directly, cooperating in Iraq to push Islamic State forces out of the country. The U.S. military trains and advises the Iraqi security forces, and the IRGC-QF arms and advises some of the 100,000 Iraqi Shi’a militia fighters that are assisting the Iraqi military. Naming the IRGC as an FTO could trigger an Iranian backlash that would not only derail this tacit cooperation, but provoke Iran to agitate its Shi’a militia allies to attack U.S. forces. Iran-backed Shi’a militias were responsible for over 500 U.S. combat deaths during the 2003 to 2011 U.S. occupation of Iraq.

As many Iraqi Shi’a recruits are loyal to Iran, such a move by the U.S. could also set back efforts by Iraqi Prime Minister Haider al-Abadi to integrate the Shi’a militias into the formal government military structure. In Syria, an FTO designation could cause the IRGC and its Shi’a allies to try to attack U.S. military advisers in northern Syria. The IRGC could also direct the forces of its closest ally, Lebanese Hizballah, to try to attack U.S. forces in Syria. Hizballah could even lash out against its main enemy, Israel, as retaliation for an IRGC designation. The IRGC has supplied Hizballah with over 100,000 rockets and missiles that Israeli security officials view as a significant threat to Israeli population centers. These potential risks appear to have caused U.S. Secretary of Defense James Mattis, Secretary of State Rex Tillerson, and the Chairman of the Joint Chiefs of Staff General Joseph Dunford to argue against designating the IRGC as an FTO.

In addition, the designation of the IRGC as an FTO could have adverse political consequences inside Iran. President Hassan Rouhani, who engineered the nuclear compromise, is running for reelection in May. Even though he has fulfilled his promise of achieving an easing of international sanctions, hardliners are mobilizing to try to defeat him in the vote. An IRGC designation as an FTO could undermine Rouhani’s claim to have prevented the imposition of any new Western sanctions since the nuclear deal was finalized. The designation could also cause the IRGC and its internal security militia, the Basij, to mobilize in support of Rouhani’s election opponents. The IRGC has been known to intervene in the past by leafletting and organizing transportation of likely conservative voters, including in the 2005 election that unexpectedly brought Mahmoud Ahmadinejad into office. A Rouhani electoral defeat could remove existing restraints on Iran’s regional policies and potentially even cause the nuclear deal to unravel.


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