US Should Designate Iran’s IRGC, Qods Force as Foreign Terrorist Organizations, Lawmakers Told

By Patrick Goodenough | October 26, 2017 | 4:21am EDT
Iranian President Hasan Rouhani takes part in a national gathering of Islamic Revolutionary Guard Corps (IRGC) commanders on September 16, 2013. (Photo: Iranian presidency)

( – The Trump administration should designate Iran’s Islamic Revolutionary Guard Corps (IRGC) – Qods Force as a foreign terrorist organization (FTO), and if the regime’s behavior worsens, should consider applying that punitive designation to the IRGC in its entirety, U.S. lawmakers were told Wednesday.

“Today, right now, let’s designate the Qods Force as an FTO and [Maj. Gen.] Qassem Soleimani as its head,” United Against Nuclear Iran (UANI) chief executive officer Mark Wallace told hearing of the House Foreign Affairs subcommittee on the Middle East and North Africa.

“Let’s start pressuring and convincing companies and businesses around the world that if you do business that touches on the IRGC and its Qods Force, that you run the risk of doing business with a foreign terrorist organization,” he said. “That would provide quite a chill in my opinion.”


The IRGC is a military force that is also deeply immersed in many key sectors in Iran, with experts estimating that it could control as much as one-third of the country’s total economy.

The Qods Force is the IRGC’s external operations division, responsible for terror operations abroad. U.S. commanders blame it for the deaths of some 500 U.S. military personnel at the hands of proxy Shi’ite militias during the Iraq war.

It is heavily involved in the Syrian civil war, fighting alongside its Lebanese ally Hezbollah to keep President Bashar al-Assad in power. The Qods Force under Soleimani is also hard at work extending Iran’s influence over Iraq, under the cover of the campaign against ISIS.

Wallace, a former U.S. ambassador to the United Nations for Management and Reform, was testifying before a hearing on “next steps” after President Trump’s recent Iran policy announcement.

In his announcement Trump decertified Iranian compliance with its obligations under the nuclear deal, but also said the U.S. Treasury Department would designate the IRGC for terrorist activity (as required by the Countering America’s Adversaries Through Sanctions Act, which the president signed over the summer.)

The Treasury designation is under Executive Order 13224, a post-9/11 tool designed to disrupt funding to terrorists. (The Qods Force has been designated under E.O. 13224 since 2007, but now the entire IRGC is targeted.)

The steps against the IRGC brought strong criticism and threatening rhetoric from Tehran. Foreign Minister Javad Zarif, an ostensible moderate in the Iranian political context, tweeted in response that Iranians were “all IRGC.”

FTO designation, which falls under the Immigration and Nationality Act (INA), would be a more significant step than the Treasury actions, however.

None of the 60 groups currently listed as FTOs are the official armed forces of a sovereign state. Designating the IRGC as an FTO would be unprecedented.

Wallace in his written testimony said it was long past time to list the Qods Force as an FTO. He noted that one of the Iraqi Shi’ite militias which serves as a proxy for the Qods Force, Kata’ib Hezbollah, has been listed as an FTO since 2009.

Wallace said that designating the Qods Force “provides the U.S. additional leverage in influencing Iranian and European behavior.”

“Down the line, if Iranian behavior remains unchanged or gets worse, Washington should consider designating the IRGC as a whole as an FTO,” he added.

Addressing the panel, he conceded that “some of our allies would have heartburn about that, because the IRGC technically runs the military of Iran – it would be the first time that we had taken such an action.”

“But I advocate that we should consider that.”

Annual State Department reports on global terrorism place Iran at the top of the list of terror-sponsoring states, with the IRGC and its Qods Force blamed for most of that activity.

Legislative criteria for FTO designation are clear-cut. Section 219 of the INA requires a group to be (a) a foreign organization; (b) that “engages in terrorist activity or terrorism, or retains the capacity and intent to engage in terrorist activity or terrorism”; (c) if that activity threats U.S. nationals or U.S. national security.

FTO designation would have far-reaching implications, given the IRGC’s involvement across key industries and sectors in the Iranian economy.

Foreign companies doing business in Iran would risk heavy penalties including fines and lengthy prison terms should they violate FTO-related restrictions, which apply not just to the targeted organizations but also to “agents” – including entities acting even indirectly on behalf of the organization concerned.

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