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Yawn: The IRGC becomes an FTO

On Monday, the State Department issued a press release:

Intent To Designate the Islamic Revolutionary Guards Corps as a Foreign Terrorist Organization

Media Note

Office of the Spokesperson

Washington, DC

April 8, 2019

Today, the Secretary of State announced his intent to designate the Islamic Revolutionary Guard Corps (IRGC), including its Qods Force, as a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act. This designation is a historic step to counter Iran-backed terrorism around the world.

The IRGC – primarily through its Qods Force – is the primary arm of the Iranian government that carries out and directs Tehran’s dangerous and destabilizing global terrorist campaign. The IRGC provides funding, equipment, training, and logistical support to a broad range of terrorist and militant organizations, totaling approximately one billion dollars annually in assistance. The IRGC has also been directly involved in terrorist plotting, malign activity and outlaw behavior in many countries, including Germany, Bosnia, Bulgaria, Kenya, Bahrain, and Turkey, among others.

This designation will have a significant impact. It is the first time that the United States has designated a part of another government as an FTO. This action underscores that the Iranian regime’s use of terrorism makes it fundamentally different from any other government. Iran employs terrorism as a central tool of its statecraft; it is an essential element of the regime’s foreign policy. This designation also gives the United States Government additional tools to counter Iranian-backed terrorism. It will increase the financial pressure and isolation of Iran, and starve the government of resources it could devote to its terrorist pursuits.

Other governments and the private sector will also be on notice about the full scope of the IRGC’s malign activities. The IRGC is integrally woven into the Iranian economy, operating front companies and institutions around the world that engage in both licit and illicit business activity. The profits from what appear to be legitimate business deals could end up unwittingly supporting Iran’s terrorist agenda.

The United States will continue to increase the financial pressure and raise the costs on the Iranian regime for its embrace of terrorism, until Tehran abandons this malign behavior.

and a fact sheet:

Designation of the Islamic Revolutionary Guard Corps

Fact Sheet

Office of the Spokesperson

Washington, DC

April 8, 2019

The State Department intends to designate as a Foreign Terrorist Organization (FTO) the Islamic Revolutionary Guard Corps (IRGC) in its entirety, including the Qods Force. This is a historic step to counter Iran-backed terrorism around the world.

  • On April 15, the IRGC will be added to the State Department’s FTO list, which includes 67 other terrorist organizations including Hizballah, Hamas, Palestinian Islamic Jihad, Kata’ib Hizballah, and al-Ashtar Brigades.

  • The IRGC FTO designation highlights that Iran is an outlaw regime that uses terrorism as a key tool of statecraft and that the IRGC, part of Iran’s official military, has engaged in terrorist activity or terrorism since its inception 40 years ago.

  • The IRGC has been directly involved in terrorist plotting; its support for terrorism is foundational and institutional, and it has killed U.S. citizens. It is also responsible for taking hostages and wrongfully detaining numerous U.S. persons, several of whom remain in captivity in Iran today.

  • The Iranian regime has made a clear choice not only to fund and equip, but also to fuel terrorism, violence, and unrest across the Middle East and around the world at the expense of its own people.

  • The Iranian regime is responsible for the deaths of at least 603 American service members in Iraq since 2003. This accounts for 17% of all deaths of U.S. personnel in Iraq from 2003 to 2011, and is in addition to the many thousands of Iraqis killed by the IRGC’s proxies.

  • This action is a significant step forward in our maximum pressure campaign against the Iranian regime. We will continue to increase financial pressure and raise the costs on the Iranian regime for its support of terrorist activities until Tehran abandons this unacceptable behavior.

The IRGC, with the support of the Iranian government, has engaged in terrorist activity since its inception 40 years ago.

  • The IRGC—most prominently through its Qods Force—has the greatest role among Iran’s actors in directing and carrying out a global terrorist campaign.

    • In recent years, IRGC Qods Force terrorist planning has been uncovered and disrupted in many countries, including Germany, Bosnia, Bulgaria, Kenya, Bahrain, and Turkey.

    • The IRGC Qods Force in 2011 plotted a brazen terrorist attack against the Saudi Ambassador to the U.S. on American soil. Fortunately, this plot was foiled.

    • In September 2018, a U.S. federal court found Iran and the IRGC liable for the 1996 Khobar Towers bombing which killed 19 Americans.

    • In 2012, IRGC Qods Force operatives were arrested in Turkey for plotting an attack and in Kenya for planning a bombing.

    • In January 2018, Germany uncovered ten IRGC operatives involved in a terrorist plot in Germany, and convicted another IRGC operative for surveilling a German-Israeli group.

  • The IRGC continues to provide financial and other material support, training, technology transfer, advanced conventional weapons, guidance, or direction to a broad range of terrorist organizations, including Hizballah, Palestinian terrorist groups like Hamas and Palestinian Islamic Jihad, Kata’ib Hizballah in Iraq, al-Ashtar Brigades in Bahrain, and other terrorist groups in Syria and around the Gulf.

  • In addition to its support of proxies and terrorist groups abroad, Iran also harbors terrorists within its own borders, thereby facilitating their activities. Iran continues to allow Al Qaeda (AQ) operatives to reside in Iran, where they have been able to move money and fighters to South Asia and Syria. In 2016, the U.S. Treasury Department identified and sanctioned three senior AQ operatives residing in Iran and noted that Iran had knowingly permitted these AQ members, including several of the 9/11 hijackers, to transit its territory on their way to Afghanistan for training and operational planning.

The IRGC FTO designation is a significant step forward in our maximum pressure campaign against the Iranian regime. 

  • This new FTO designation builds upon previous sanctions, sends a clear message to the world that the Administration is committed to exerting maximum pressure on the Iranian regime, and shines a spotlight on those in the IRGC who engage in terrorist activities.

    • It builds upon previous sanctioning of more than 900 Iran-related individuals, entities, aircraft, and vessels by this Administration for human right abuses, censorship, ballistic missile program, malign cyber activities, support to terrorism, or associations with the Government of Iran.

    • Since January 19, 1984, Iran has been designated a State Sponsor of Terrorism (SST) for providing support for acts of international terrorism. As a result of this designation, Iran is subject to a number of sanctions and restrictions, including restrictions on U.S. foreign assistance; a ban on defense exports and sales; exports controls of dual use items; and miscellaneous financial and other restrictions.

    • In 2017, the Department of the Treasury designated the IRGC as a Specially Designated Global Terrorist pursuant to its counterterrorism sanctions authority (Executive Order 13224) for its activities in support of the IRGC-Qods Force, which was previously designated in 2007 under this same authority for providing support to a number of terrorist groups, including Hizballah and Hamas.

    • The IRGC is also currently designated pursuant to various Executive Orders, including sanctions designations in 2007 for its support to Iran’s ballistic missile and nuclear programs, and in 2011 and 2012 in connection with Iran’s human rights abuses.

For further information, please contact Alexander Vagg at or (202)647-1845.

announcing that, on top of being on the SDN List under the IFSR Iranian sanctions program, and as a SDGT (specially designated global terrorist), the Iranian Revolutionary Corps (IRGC) was being designated a Foreign Terrorist Organization (FTO).

As a compliance matter, this change is meaningless: the IRGC was already subject to both primary and secondary sanctions under both the counter terrorism and Iranian sanctions programs. Additionally, any party who helped them evade sanctions could be added to the Foreign Sanctions Evaders (FSE) List.

It kind of reminds me of this quote from the first Mission: Impossible movie:

If you’re dealing with a man who has crushed, shot, stabbed, and detonated five members of his own IMF team, how devastated do you think you’re gonna make him by hauling Mom and Uncle Donald down to the county courthouse?

Somehow, I’m not sure how naming and shaming a group who has already been demonized (not necessarily unfairly) advances the US strategic foreign policy goals.


State Department Press Release, Fact Sheet

Categories: Iranian Sanctions State Department Updates


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