Iran Deal: U.S. Sanctions on the IRGC

Since 2007, the United States has sanctioned the Islamic Revolutionary Guard Corps (IRGC)—as well as its proxies and foreign companies that support it—under at least eight executive orders and six laws. “Of the 107 sanctions the Biden administration has imposed on Iran, 86 of those – some three-quarters – have been applied against the IRGC or its proxies,” State Department Spokesperson Ned Price said on May 10, 2022. The executive orders and laws include:

  • Executive Order 13224 in 2001: President George W. Bush signed Executive Order 13224, which authorized the blocking of assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism. The order, issued less than two weeks after the 9/11 attacks, extended to any country, entity or individual that provided support to terrorists. It originally did not specify the IRGC.

    In 2007, the United States first designated the IRGC’s Qods Force, which has carried out Iran’s foreign operations and coordinates with regional militants. The Qods Force—also officially described as IRGC-QF—“provides material support to the Taliban, Lebanese Hizballah, Hamas, Palestinian Islamic Jihad, and the Popular Front for the Liberation of Palestine-General Command (PFLP-GC),” the State Department announcement said.

    “The Qods Force is the Iranian regime’s primary instrument for providing lethal support to the Taliban. The Qods Force provides weapons and financial support to the Taliban to support anti-U.S. and anti-Coalition activity in Afghanistan. Since at least 2006, Iran has arranged frequent shipments of small arms and associated ammunition, rocket propelled grenades, mortar rounds, 107mm rockets, plastic explosives, and probably man-portable defense systems to the Taliban. This support contravenes Chapter VII UN Security Council obligations. UN Security Council resolution 1267 established sanctions against the Taliban and UN Security Council resolutions 1333 and 1735 imposed arms embargoes against the Taliban. Through Qods Force material support to the Taliban, we believe Iran is seeking to inflict casualties on U.S. and NATO forces.

    “The Qods Force has had a long history of supporting Hizballah’s military, paramilitary, and terrorist activities, providing it with guidance, funding, weapons, intelligence, and logistical support. The Qods Force operates training camps for Hizballah in Lebanon’s Bekaa Valley and has reportedly trained more than 3,000 Hizballah fighters at IRGC training facilities in Iran. The Qods Force provides roughly $100 to $200 million in funding a year to Hizballah and has assisted Hizballah in rearming in violation of UN Security Council Resolution 1701… In addition, the Qods Force provides lethal support in the form of weapons, training, funding, and guidance to select groups of Iraqi Shi’a militants who target and kill Coalition and Iraqi forces and innocent Iraqi civilians.

    In 2017, the United States again invoked Executive Order 13224 to designate the entire IRGC for supporting terrorism. “The IRGC has played a central role to Iran becoming the world’s foremost state sponsor of terror. Iran’s pursuit of power comes at the cost of regional stability, and Treasury will continue using its authorities to disrupt the IRGC’s destructive activities,” Treasury Secretary Steven Mnuchin said. 

    “The IRGC has provided material support to the IRGC-QF, including by providing training, personnel, and military equipment.  The IRGC has trained IRGC-QF personnel in Iran prior to their deployments to Syria, and has deployed at least hundreds of personnel from its conventional ground forces to Syria to support IRGC-QF operations.  IRGC personnel in Syria have provided military assistance to the IRGC-QF, and have been assigned to IRGC-QF units on the battlefield, where they provide critical combat support, including serving as snipers and machine gunners.

    “Additionally, the IRGC has recruited, trained, and facilitated the travel of Afghan and Pakistani nationals to Syria, where those personnel are assigned to, and fight alongside, the IRGC-QF.  The IRGC also has worked with the IRGC-QF to transfer military equipment to Syria.  The IRGC used both IRGC bases and civilian airports in Iran to transfer military equipment to Iraq and Syria for the IRGC-QF.”
     
  • Executive Order 13382 in 2005: President Bush signed Executive Order 13382, which blocked the property of any people or entities involved in proliferation of weapons of mass destruction (WMD), which include chemical, biological or nuclear weapons. It also prohibited financial transactions between Americans and any person or entity sanctioned.

    In 2007, the United States designated the IRGC for proliferation of WMD or for developing delivery systems for them. “The IRGC has been outspoken about its willingness to proliferate ballistic missiles capable of carrying WMD. The IRGC’s ballistic missile inventory includes missiles, which could be modified to deliver WMD. The IRGC is one of the primary regime organizations tied to developing and testing the Shahab-3. The IRGC attempted, as recently as 2006, to procure sophisticated and costly equipment that could be used to support Iran’s ballistic missile and nuclear programs.”
     
  • Executive Order 13438 in 2007: President Bush issued Executive Order 13438, which authorized the Treasury Department to block property of individuals who threatened stabilization efforts in Iraq.

    In 2008, the Treasury Department sanctioned two Qods Force officers under the order for fueling violence in Iraq. The Qods Force “provides lethal support in the form of weapons, training, funding, and guidance to select groups of Iraqi Shia militants who target and kill Coalition and Iraqi forces and Iraqi civilians,” according to the Treasury announcement.
     
  • Executive Order 13553 in 2010: President Barack Obama issued Executive Order 13553, which blocked the property of individuals involved in human rights abuses against Iranians or people living in Iran. The order initially designated eight Iranian officials, including IRGC Commander Mohammad Ali Jafari and Deputy IRGC Commander for Intelligence Hossein Taeb.  It was later applied to entities as well as individuals.

    In 2011, United States designated the entire IRGC for human rights abuses. In a joint statement, the State Department and the Treasury said, “The IRGC is responsible for the serious human rights abuses that have occurred since the contested June 12, 2009 presidential election, including the violent crackdowns on protests and the mistreatment of political detainees held in a ward of Tehran’s Evin prison controlled by the IRGC.”

    Adam Szubin, director of the Office of Foreign Assets Control, added, “Today’s action exposes Iran’s willingness to turn the machinery of the state, at its highest levels, against its own people to violently suppress their democratic aspirations,” “As long as this denial of basic human rights continues, we will remain vigilant in our efforts to isolate those responsible from the international financial system.
     
  • Executive Order 13572 in 2011: In an action focused on Syria and Iran, President Obama issued Executive Order 13572, which sanctioned the Qods Force, the Syrian General Intelligence Directorate and three Syrian officials for human rights abuses after the Syrian crackdown on protesters during the Arab uprising. Iran was included for providing military support to the Assad regime. 
     
  • Executive Order 13606 in 2012: President Obama issued Executive Order 13606, which sanctioned the entire IRGC for human rights abuses in both Iran and Syria. The executive order “sends a clear message that the United States condemns the continuing campaigns of violence and human rights abuses against the people of Syria and Iran by their governments and provides a tool to hold accountable those who assist in or enable such abuses through the use of information and communications technology,” according to the Treasury Department.

    It specifically identified Iran for cyber operations, including the IRGC’s Center for Inspecting Organized Crimes (CIOC) that oversees Iran’s cyber security. “The CIOC has taken an active role in identifying and arresting protesters involved in the 2009 post-election unrest, particularly those individuals active in cyber space,” the Treasury said. The CIOC has forcefully suppressed anyone seeking to carry out “cultural operations” against the Islamic Republic via the Internet.” It also monitors Persian-language sites. The CIOC’s official website is called Gerdab (www.gerdab.ir), a Farsi word for whirlpool.
     
  • Executive Order 13694 in 2015: President Obama issued Executive Order 13694, which authorized sanctions on individuals and entities responsible for or complicit in cyber activities that threaten the national security, foreign policy, or economic health or financial stability of the United States.

    In 2018, the Treasury Department sanctioned the Mabna Institute, a hacker network in Iran that worked for the IRGC. The Mabna Institute “conducted massive, coordinated cyber intrusions into computer systems belonging to at least approximately 144 United States-based universities, in addition to at least 176 universities located in 21 foreign countries.”
     
  • Executive Order 13848 in 2018: President Donald Trump signed Executive Order 13848, which authorized sanctions on any foreign individuals for interfering in a U.S. election.

    In 2020, the United States designated the IRGC and the Qods Force for interfering in the 2020 presidential election. “The Iranian regime uses false narratives and other misleading content to attempt to influence U.S. elections,” Secretary Steven Mnuchin said. The Treasury Department said that Iran had targeted the U.S. electoral process “with brazen attempts to sow discord among the voting populace by spreading disinformation online and executing malign influence operations aimed at misleading U.S. voters. Components of the Government of Iran, disguised as news organizations or media outlets, have targeted the United States in order to subvert U.S. democratic processes.”
     
  • Foreign Terrorist Organizations List in 1997: The Antiterrorism and Effective Death Penalty Act of 1996 — established under the Immigration and Nationality Act of 1952 — authorized the Secretary of State to designate a group as a foreign terrorist organization (FTO).

    In 2019, the Trump administration designated the entire IRGC as a Foreign Terrorist Organization. The IRGC “actively participates in, finances, and promotes terrorism as a tool of statecraft,” President Donald Trump said. “The IRGC is the Iranian government’s primary means of directing and implementing its global terrorist campaign.”

    “This designation will be the first time that the United States has ever named a part of another government as a FTO,” he said. “It underscores the fact that Iran’s actions are fundamentally different from those of other governments. This action will significantly expand the scope and scale of our maximum pressure on the Iranian regime. It makes crystal clear the risks of conducting business with, or providing support to, the IRGC. If you are doing business with the IRGC, you will be bankrolling terrorism.”

 

Under provisions in Congressional legislation, the executive branch has also sanctioned dozens of individuals and entities for doing business with or supporting the IRGC. The laws include:

  • Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) of 2010: Congress amended the 1996 Iran Sanctions Act to include the new CISADA, which imposed sanctions on any company or economic entity that invested in Iran's energy sector. CISADA significantly expanded the range of sanctionable activities. It also mandated new sanctions related to Iran's nuclear program. For example, CISADA has sanctioned foreign banks that conduct transactions with the IRGC or any of its agents or affiliates.

    In 2011, the State Department said that the new CISADA authorities “address the potential connection between Iran’s energy sector and its nuclear program,” as outlined in U.N. Security Council Resolution 1929, which imposed sanctions on Iran for its nuclear activities. CISADA was designed to increase pressure on Iran to return to diplomatic negotiations on Iran’s non-compliance with its international obligations.
     
  • Iran Freedom and Counter-Proliferation Act (IFCA) of 2013: Under IFCA, Congress mandated the executive branch to block the assets of any person or entity that knowingly conducted transactions with a sanctioned Iranian entity. It also authorized sanctions on any persons involved in the Iranian energy, shipping, and shipbuilding industries. 

    A statement from Treasury said that the new act authorized broad sanctions on “certain activities related to Iran’s energy, shipping, and shipbuilding sectors; the sale, supply, or transfer to or from Iran of precious and certain other metals, graphite, coal, and industrial software; the provision of underwriting services, insurance, or reinsurance to activities and persons targeted by U.S. sanctions against Iran; financial transactions involving sanctioned Iranian individuals and entities; and persons involved in the diversion of goods intended for the Iranian people.”
     
  • Iran Threat Reduction and Syria Human Rights Act (ITRSHRA) of 2012: Under ITRSHRA, the executive branch is empowered to impose sanctions on individuals and entities that conduct transactions with or provide support to the IRGC and other designated Iranian entities.

    The State Department said that the provisions allow sanctions on “activities related to Iran’s energy and financial sectors, proliferation of weapons of mass destruction, support for terrorism, and human rights abuses… These new authorities greatly increase the pressure on Iran to comply with its full range of international nuclear obligations and engage in constructive negotiations with the international community.”
     
  • Countering America’s Adversaries Through Sanctions Act (CAATSA) of 2017: Under CAATSA, the executive branch is empowered to impose new sanctions on Iran, Russia, and North Korea for aggression against the United States. The part of the law focused on Iran mandated the imposition of new sanctions on the IRGC and its affiliates for support for terrorism. CAATSA also expanded on CISADA by authorizing sanctions on human rights abusers. 

    The Congressional Research Service said that the legislation directed the President “to impose sanctions against: (1) Iran's ballistic missile or weapons of mass destruction programs, (2) the sale or transfer to Iran of military equipment or the provision of related technical or financial assistance, and (3) Iran's Islamic Revolutionary Guard Corps and affiliated foreign persons. The President may impose sanctions against persons responsible for violations of internationally recognized human rights committed against individuals in Iran. The President may temporarily waive the imposition or continuation of sanctions under specified circumstances.”
     
  • Department of State, Foreign Operations, and Related Programs Appropriations Act of 2021: The annual foreign operations appropriations bill mandated the State Department to bar any foreign officials from entering the United States if they were involved with significant corruption or gross violations of human rights. The State Department subsequently sanctioned two IRGC interrogators for torture and or inhumane treatment of political prisoners; it banned the men and their families from entering the United States.

 

The following is a list of the specific sanctions imposed between 2007 and 2022. Each entry notes the relevant law or executive order.  

October 25, 2007 (Executive Orders 13382 and 13224)

Under Executive Order 13382, the United States sanctioned the IRGC for developing ballistic missiles capable of delivering WMD. It also designated nine IRGC-affiliated entities and individuals, two major banks, and three individuals connected to Iran’s Aerospace Industries Organization.

Under Executive Order 13224, the United States sanctioned the Qods Force for providing material support to the Taliban and other terrorist organizations. It also designated Bank Saderat as a terrorist financier.

“The U.S. Government is taking several major actions today to counter Iran's bid for nuclear capabilities and support for terrorism by exposing Iranian banks, companies and individuals that have been involved in these dangerous activities and by cutting them off from the U.S. financial system,” Treasury Secretary Henry Paulson said. 

 

January 9, 2008 (Executive Order 13438)

The United States sanctioned Ahmed Foruzandeh, Commanding Officer of the IRGC-Quds Force’s Ramazan Corps, for leading terrorist operations against Coalition Forces and Iraq Security Forces, and directing assassinations of Iraqi figures.

“Iran and Syria are fueling violence and destruction in Iraq. Iran trains, funds, and provides weapons to violent Shia extremist groups, while Syria provides safe-haven to Sunni insurgents and financiers,” the Treasury Department stated in the sanctions announcement. “Today's action brings to light the lethal actions of these individuals, and we call on the international community to stand with us in isolating them from the global economy. By committing, directing, and supporting violent attacks in Iraq, these extremists threaten peace and stability and undermine efforts to promote economic reconstruction in Iraq.”

 

September 16, 2008 (Executive Order 13438)

The United States sanctioned two entities and five individuals – including Abdul Reza Shahlai, a deputy commander of the Qods Force – for threatening the peace and stability of Iraq.

“The Qods Force provides lethal support in the form of weapons, training, funding, and guidance to select groups of Iraqi Shia militants who target and kill Coalition and Iraqi forces and Iraqi civilians,” the Treasury Department stated.

 

February 10, 2010 (Executive Order 13382)

The United States sanctioned IRGC General Rostam Qasemi and four companies affiliated with the IRGC. Qassemi, the commander of Khatam al-Anbiya Construction Headquarters, the engineering arm of the IRGC that controlled the four firms. The Treasury noted that profits from IRGC business ventures support illicit activities, including proliferation of WMD.

“As the IRGC consolidates control over broad swaths of the Iranian economy, displacing ordinary Iranian businessmen in favor of a select group of insiders, it is hiding behind companies like Khatam al-Anbiya and its affiliates to maintain vital ties to the outside world,” the Treasury Department stated.

 

June 16, 2010 (Executive Order 13382)

The United States sanctioned two IRGC commanders and four entities for proliferation of WMD. The Treasury Department designated IRGC Commander-in-Chief Mohammad Ali Jafari, IRGC Basij Resistance Force leader Mohammad Reza Naqdi, the IRGC Air Force, the IRGC Missile Command, and two companies connected to Khatam al-Anbiya.

“The IRGC plays a key role in Iran's missile program and support for terrorism and it has taken over broad portions of the Iranian economy, to the detriment of the Iranian people,” Stuart Levey, Under Secretary Levey for Terrorism and Financial Intelligence, said.

 

July 1, 2010 (Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010)

President Barack Obama signed the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), which imposed sanctions on any company or economic entity that invested in Iran's energy sector. CISADA significantly expanded the range of sanctionable activities. It also mandated new sanctions related to Iran's nuclear program. For example, CISADA has sanctioned foreign banks that conduct transactions with the IRGC or any of its agents or affiliates.

The Treasury Department said that “CISADA is consistent with the global consensus regarding Iranian behavior and is in line with the U.S. Government’s core role of protecting its domestic financial system from exposure to Iran’s illicit and deceptive financial practices.” 

 

August 3, 2010 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned four senior officers of the IRGC Qods Force for supporting terrorism. The Treasury Department also designated three men and two entities based in Lebanon and Syria for providing financial and material support to Hizballah.

“As its isolation from the international financial and commercial systems increases, the Government of Iran will continue efforts to evade sanctions, including using government-owned entities around the world that are not easily identifiable as Iranian to facilitate transactions in support of their illicit activities,” said Under Secretary for Terrorism and Financial Intelligence Stuart Levey. “Today's identifications will mitigate the risk that such entities pose to legitimate transactions.”

 

September 28, 2010 (Executive Order 13553)

President Barack Obama issued Executive Order 13553, which blocked the property of individuals involved in human rights abuses against Iranians or people living in Iran. The order initially designated eight Iranian officials, including IRGC Commander Mohammad Ali Jafari and Deputy IRGC Commander for Intelligence Hossein Taeb.

 

December 21, 2010 (Executive Orders 13382 and 13224)

Under Executive Order 13382, the United States sanctioned three entities and one man for connections to the IRGC and its efforts to proliferate WMD. The Treasury Department designated Bonyad Taavon Sepah, a wealthy foundation, and its executive director, Parviz Fattah, as well as Ansar Bank and Mehr Bank.

Under Executive Order 13224, the United States sanctioned Liner Transport Kish for providing shipping services outside of Iran in support of Hizballah on behalf of the IRGC.

“The IRGC continues to be a primary focus of U.S. and international sanctions against Iran because of the central role it plays in Iran’s missile and nuclear programs, its support for terrorism, as well as its involvement in serious human rights abuses,” the Treasury Department said in the announcement. “The U.S., UN, EU, Japan, South Korea and others have all targeted the IRGC for sanctions because of this illicit activity. With the IRGC’s expanding influence and control over broader segments of the Iranian economy – including the defense production, construction, and oil and gas industries – increasing numbers of Iranian businesses are subsumed under the IRGC’s umbrella and identified with its illicit conduct.”

 

April 29, 2011 (Executive Order 13572)

In an action focused on Syria and Iran, President Obama issued Executive Order 13572, which sanctioned the Qods Force, the Syrian General Intelligence Directorate and three Syrian officials for human rights abuses after the Syrian crackdown on protesters during the Arab uprising. Iran was included for providing military support to the Assad regime. 

 

May 11, 2011 (Executive Order 13572)

The United States sanctioned two senior IRGC Qods Force officers, Commander Qassem Soleimani and Operations Commander Mohsen Chizari, for involvement in human rights abuses in Syria. The Treasury Department also designated a cousin of President Assad and three branches of Syria’s security forces.

“The actions the Administration has taken today send an unequivocal message to President Assad, the Syrian leadership, and regime insiders that they will be held accountable for the ongoing violence and repression in Syria,” said Acting Under Secretary for Terrorism and Financial Intelligence David S. Cohen.

 

April 23, 2012 (Executive Order 13606)

President Obama issued Executive Order 13606, which sanctioned the entire IRGC for human rights abuses in both Iran and Syria. The order also designated Syrian General Intelligence Directorate (GID), the GID’s Director Ali Mamluk, Iran’s Ministry of Intelligence and Security (MOIS) Iran’s Law Enforcement Forces (LEF), the Iranian Internet service provider Datak Telecom, and the Syrian communication firm Syriatel.

The executive order “sends a clear message that the United States condemns the continuing campaigns of violence and human rights abuses against the people of Syria and Iran by their governments and provides a tool to hold accountable those who assist in or enable such abuses through the use of information and communications technology,” the Treasury Department said in the announcement.

 

July 12, 2012 (Executive Order 13382 and Executive Order 13599)

Under Executive Order 13382, the United States sanctioned IRGC Navy Commander Ali Fadavi and several companies for involvement in proliferation of WMD. Under Executive Order 13599, the United States sanctioned front companies, financial institutions and vessels connected to Iran’s national oil company.

“Today’s actions target Iran’s nuclear and missile proliferation activities, by designating entities and individuals that are part of the international procurement and nuclear proliferation operations” run by Iran’s various security services, including the IRGC, the Treasury Department said.

 

August 10, 2012 (Iran Threat Reduction and Syria Human Rights Act of 2012)

President Obama signed the Iran Threat Reduction and Syria Human Rights Act (ITRSHRA) of 2012 into law. Under ITRSHRA, the executive branch is empowered to impose sanctions on individuals and entities that conduct transactions with or provide support to the IRGC and other designated Iranian entities.   

The State Department said that the provisions allow sanctions on “activities related to Iran’s energy and financial sectors, proliferation of weapons of mass destruction, support for terrorism, and human rights abuses… These new authorities greatly increase the pressure on Iran to comply with its full range of international nuclear obligations and engage in constructive negotiations with the international community.”

 

January 2, 2013 (Iran Freedom and Counter-Proliferation Act)

President Obama signed the Iran Freedom and Counter-Proliferation Act into law. Under IFCA, Congress mandated the executive branch to block the assets of any person or entity that knowingly conducted transactions with a sanctioned Iranian entity, including the IRGC and IRGC-Quds Force. It also authorized sanctions on any persons involved in the Iranian energy, shipping, and shipbuilding industries. 

A statement from Treasury said that the new act authorized broad sanctions on “certain activities related to Iran’s energy, shipping, and shipbuilding sectors; the sale, supply, or transfer to or from Iran of precious and certain other metals, graphite, coal, and industrial software; the provision of underwriting services, insurance, or reinsurance to activities and persons targeted by U.S. sanctions against Iran; financial transactions involving sanctioned Iranian individuals and entities; and persons involved in the diversion of goods intended for the Iranian people.” 

 

February 3, 2017 (Executive Orders 13382 and 13324)

Under Executive Order 13324, the United States sanctioned an IRGC Qods Force network involved with Hizballah in Lebanon. The Treasury designated a Qods Force official based in Beirut, two of his employees, several affiliated companies, and a man who procured aviation parts for the Qods Force. “Iran’s continued support for terrorism and development of its ballistic missile program poses a threat to the region, to our partners worldwide, and to the United States,” John E. Smith, acting director of the Office of Foreign Assets Control, said.

Under Executive Order 13382, the United States sanctioned several networks and supporters of Iran’s ballistic missile program.
 

July 18, 2017 (Executive Orders 13382 and 13581)

Under Executive Order 13382, the State Department sanctioned the IRGC Aerospace Force Self Sufficiency Jihad Organization and the IRGC Research and Self Sufficiency Jehad Organization for developing ballistic missiles. Under the same authority, the Treasury Department sanctioned two networks that supported the IRGC’s development of unmanned aerial vehicles (UAVs), fast attack boats and other military equipment.

Under Executive Order 13581, which targets transnational criminal organizations, the Treasury Department designated a China-based network that provided goods or services to Iran’s military.  

 

August 2, 2017 (Countering America’s Adversaries Through Sanctions Act)

President Trump signed the Countering America’s Adversaries Through Sanctions Act, which empowered the executive branch to impose new sanctions on Iran, Russia, and North Korea for aggression against the United States. The part of the law focused on Iran mandated the imposition of new sanctions on the IRGC and its affiliates for support for terrorism. CAATSA also expanded on CISADA by authorizing sanctions on human rights abusers. 

The Congressional Research Service said that the legislation directed the President “to impose sanctions against: (1) Iran's ballistic missile or weapons of mass destruction programs, (2) the sale or transfer to Iran of military equipment or the provision of related technical or financial assistance, and (3) Iran's Islamic Revolutionary Guard Corps and affiliated foreign persons. The President may impose sanctions against persons responsible for violations of internationally recognized human rights committed against individuals in Iran. The President may temporarily waive the imposition or continuation of sanctions under specified circumstances.”

 

September 14, 2017 (Executive Orders 13382, 13224, and 13694)

Under Executive Order 13382, the United States designated one firm for supporting Iran’s ballistic missile program and the IRGC.

Under Executive Order 13224, the United States designated two airlines for aiding previously designated Iranian and Iraqi airlines that support the IRGC Qods Force. The airlines allegedly transported fighters and weapons to Syria.

Under Executive Order 13694, the United States designated two Iran-based networks responsible for malicious cyber-enabled attacks against the U.S. financial system.

“Treasury will continue to take strong actions to counter Iran’s provocations, including support for the IRGC-Qods Force and terrorist extremists, the ongoing campaign of violence in Syria, and cyber-attacks meant to destabilize the U.S. financial system,” Treasury Secretary Steven Mnuchin said.

 

October 13, 2017 (Executive Order 13224, 13382, CAATSA)

Under Executive Order 13224 and CAATSA, the United States designated the IRGC in its entirety for providing training, personnel, and military equipment to the Qods Force, its external operations arm.

Under Executive Order 13382, the United States sanctioned three Iran-based firms, two of which provided goods or services to the IRGC, as well as a China-based company for providing support to Iran’s military.

The IRGC is “the Iranian Supreme Leader’s corrupt personal terror force and militia,” President Trump said. It “has hijacked large portions of Iran's economy and seized massive religious endowments to fund war and terror abroad.”

 

March 23, 2018 (Executive Order 13694)

Under Executive Order 13694, the United States sanctioned an Iranian hacker network that targeted hundreds of U.S. and foreign universities, dozens of U.S. companies and government agencies and the United Nations. It was one of the largest state-sponsored hacking campaigns ever prosecuted by the Justice Department. 

“The IRGC outsourced cyber intrusions to The Mabna Institute, a hacker network that infiltrated hundreds of universities to steal sensitive data,” Treasury Under Secretary Sigal Mandelker said. “We will not tolerate the theft of U.S. intellectual property, or intrusions into our research institutions and universities."

 

May 10, 2018 (Executive Order 13224)

The United States and the United Arab Emirates moved to disrupt an extensive currency exchange network that helped fund the IRGC Qods Force. Under Executive Order 13224, the Treasury Department sanctioned nine Iranian individuals and companies for working on behalf of the Qods Force.

“Countries around the world must be vigilant against Iran’s efforts to exploit their financial institutions to exchange currency and fund the nefarious actors of the IRGC-QF and the world’s largest state sponsor of terror,” Treasury Secretary Steven Mnuchin said.

 

May 15, 2018 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned the governor and a senior official of the Central Bank of Iran, an Iraq-based bank and its chairman, and a key Hizballah official, all of whom had moved millions of dollars on behalf of IRGC Qods Force to Hizballah.

 

Central Bank chief Valiollah Seif “covertly funneled millions of dollars on behalf of the IRGC-QF through Iraq-based al-Bilad Islamic Bank to enrich and support the violent and radical agenda of Hizballah,” said Treasury Secretary Steven Mnuchin.

 

October 16, 2018 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned a network of some 20 businesses for providing financial support to the Basij Resistance Force, a paramilitary under the IRGC. The Treasury Department alleged that the Basij deployed child soldiers to fight in conflicts across the region.

 

“The Bonyad Taavon Basij network is an example of how the IRGC and Iranian military forces have expanded their economic involvement in major industries, and infiltrated seemingly legitimate businesses to fund terrorism and other malign activities. This vast network provides financial infrastructure to the Basij’s efforts to recruit, train, and indoctrinate child soldiers who are coerced into combat under the IRGC’s direction,” said Treasury Secretary Steven Mnuchin.

 

January 24, 2019 (Executive Orders 13224 and 13553)

Under Executive Order 13224, the United States sanctioned two Iran-backed militias active in Syria (the Fatemiyoun Division and the Zaynabiyoun Brigade), Qeshm Fars Air, and Flight Travel LLC for supporting terrorism or the IRGC Qods Force.

Under Executive Order 13553, the United States sanctioned the IRGC Qods Force, Fatemiyoun Division, and the Zaynabiyoun Brigade for human rights abuses. The Fatemiyoun Division was composed of Afghan nationals, and the Zaynabiyoun Brigade was composed of Pakistani nationals.

“The brutal Iranian regime exploits refugee communities in Iran, deprives them of access to basic services such as education, and uses them as human shields for the Syrian conflict,” said Treasury Secretary Steven Mnuchin.

 

March 26, 2019 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned 25 individuals and entities, including a network of Iran, UAE, and Turkey-based front companies, that transferred over a billion dollars and euros to the IRGC and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). The companies also procured millions of dollars’ worth of vehicles for MODAFL. Ansar Bank, which is controlled by the IRGC, used intermediaries to exchange devalued Iranian rials for dollars and euros.  

“The IRGC, MODAFL, and other malign actors in Iran continue to exploit the international financial system to evade sanctions, while the regime funds terrorism and other destabilizing activities across the region,” Treasury Secretary Steven Mnuchin said.

 

April 8, 2019 (Section 219 of the Immigration and Nationality Act)

In 2019, the Trump administration designated the entire IRGC as a Foreign Terrorist Organization. The IRGC “actively participates in, finances, and promotes terrorism as a tool of statecraft,” President Donald Trump said. “The IRGC is the Iranian government’s primary means of directing and implementing its global terrorist campaign.”

“This designation will be the first time that the United States has ever named a part of another government as a FTO,” he said. “It underscores the fact that Iran’s actions are fundamentally different from those of other governments. This action will significantly expand the scope and scale of our maximum pressure on the Iranian regime. It makes crystal clear the risks of conducting business with, or providing support to, the IRGC. If you are doing business with the IRGC, you will be bankrolling terrorism.”

 

June 7, 2019 (Executive Order 13382)

Under Executive Order 13382, the United States sanctioned Iran’s largest petrochemical holding group, Persian Gulf Petrochemical Industries Company (PGPIC), for supporting the IRGC’s engineering conglomerate, Khatam Al Anbiya Construction Headquarters. The Treasury Department also designated more than two dozen PGPIC subsidiaries.

“By targeting this network we intend to deny funding to key elements of Iran’s petrochemical sector that provide support to the IRGC,” Treasury Secretary Steven T. Mnuchin said. “This action is a warning that we will continue to target holding groups and companies in the petrochemical sector and elsewhere that provide financial lifelines to the IRGC.”

 

June 12, 2019 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned an Iraqi company and two of its associates for trafficking hundreds of millions of dollars’ worth of weapons to Iraqi militias backed by the IRGC Qods Force. The firm, South Wealth Resources Company, also moved millions of dollars to Iraq for illicit financial activity benefitting the Qods Force and Iran’s proxies.

“Treasury is taking action to shut down Iranian weapons smuggling networks that have been used to arm regional proxies of the IRGC Qods Force in Iraq, while personally enriching regime insiders,” Treasury Secretary Steven Mnuchin said. “The Iraqi financial sector and the broader international financial system must harden their defenses against the continued deceptive tactics emanating from Tehran in order to avoid complicity in the IRGC’s ongoing sanctions evasion schemes and other malign activities.”

 

June 24, 2019 (Executive Order 13876, 13224)

Under Executive Orders 13876 and 13224, the United States sanctioned eight senior commanders of Navy, Aerospace, and Ground Forces of the IRGC. Treasury Secretary Steven Mnuchin charged that the commanders were “responsible for the Iranian regime’s provocative attacks orchestrated in internationally recognized waters and airspace, as well as Iran’s malign activities in Syria.”

President Donald Trump signed Executive Order 13876, which imposed sanctions on Supreme Leader Ayatollah Ali Khamenei and his office. “The Supreme Leader of Iran is one who ultimately is responsible for the hostile conduct of the regime. He is respected within his country. His office oversees the regime’s most brutal instruments,” Trump said.

 

August 28, 2019 (Executive Order 13382)

Under Executive Order 13382, the United States sanctioned two procurement networks that supported Iran’s WMD program. One of the networks, led by Hamed Dehghan, facilitated more than 10 million dollars’ worth of proliferation-related transactions for the IRGC and Iran’s ballistic missile program.

“As the Iranian regime attempts to use complex schemes to hide its efforts to bolster its WMD program, the U.S. government will continue to thwart them at every turn,” Sigal Mandelker, Treasury Under Secretary for Terrorism and Financial Intelligence, said. “We urge governments worldwide to recognize the extraordinary lengths to which the regime in Tehran will go to conceal its behavior, and to ensure that their companies and financial institutions are not facilitating Iran's proliferation activities.”

 

August 30, 2019 (Executive Order 13224)

Under Executive Order 13244, the United States sanctioned the Iranian oil tanker, the Adrian Darya-1, for transporting 2.1 million barrels of Iranian crude oil on behalf of the IRGC Qods Force. The ship, formerly named the Grace 1, was detained by Britain off the coast of Gibraltar on July 4 for attempting to smuggle oil to Syria in violation of E.U. sanctions. The Treasury Department also designated the ship’s captain, Akhilesh Kumar, for providing support to a terrorist organization.

“Vessels like the Adrian Darya 1 enable the IRGC-QF to ship and transfer large volumes of oil, which they attempt to mask and sell illicitly to fund the regime’s malign activities and propagate terrorism,” Sigal Mandelker, Under Secretary for Terrorism and Financial Intelligence, said.

 

September 4, 2019 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned a large shipping network for providing financial support to the IRGC Qods Force and Hizballah. The Qods Force allegedly moved oil worth hundreds of millions of dollars or more through the ship managers, vessels, and facilitators.

Brian Hook, the U.S. special envoy for Iran, said that the United States would offer up to $15 million for any information that disrupts IRGC financial operations. “Today’s announcement is historic. It’s the first time that the United States has offered a reward for information that disrupts a government entity’s financial operations,” he said. “We have taken this step because the IRGC operates more like a terrorist organization than it does a government.”

 

March 26, 2020 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned 20 front companies, senior officials, and business associates based in Iran and Iraq for funneling money to the IRGC Qods Force and transferring weapons to Iraqi militias backed by Iran.

“Iran employs a web of front companies to fund terrorist groups across the region, siphoning resources away from the Iranian people and prioritizing terrorist proxies over the basic needs of its people,” Treasury Secretary Steven Mnuchin said. “The United States maintains broad exceptions and authorizations for humanitarian aid including agriculture commodities, food, medicine, and medical devices to help the people of Iran combat the coronavirus.”

 

May 20, 2020 (Executive Order 13553)

Under Executive Order 13553, the United States sanctioned a provincial commander of the IRGC, Interior Minister Abdolreza Rahmani Fazli, and seven senior officials of the Law Enforcement Forces (LEF) for human rights abuses. The LEF sent Afghan migrants in Iran to deportation centers where the IRGC reportedly coerced many into fighting for Iranian militias in Syria. And IRGC Brigadier General Hassan Shahvarpour Najafabadi was the commander of the Vali Asr Base in Khuzestan province during a brutal crackdown on protestors in November 2019.

“The Iranian regime violently suppresses dissent of the Iranian people, including peaceful protests, through physical and psychological abuse,” Treasury Secretary Steven Mnuchin said. “The United States will continue to hold accountable Iranian officials and institutions that oppress and abuse their own people.”

 

October 22, 2020 (Executive Order 13848)

Under Executive Order 13848, the United States sanctioned the IRGC, the Qods Force and Bayan Rasaneh Gostar Institute for interfering in the 2020 U.S. presidential election. The Treasury Department alleged that Iran ran disinformation campaigns to sow discord among readers via social media and messaging applications. Under the same authority, the Treasury Department designated the Iranian Islamic Radio and Television Union (IRTVU) and International Union of Virtual Media (IUVM) for amplifying false narratives and being owned or controlled by the IRGC Qods Force.

Iran used “misleading content to attempt to influence U.S. elections,” Secretary Steven Mnuchin said. “This Administration is committed to ensuring the integrity of the U.S. election system and will continue to counter efforts from any foreign actor that threatens our electoral processes.”

 

December 8, 2020 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned Hasan Irlu, an IRGC Qods Force official and Iran’s envoy to the Houthi rebels in Yemen. He was designated for acting on behalf of the Qods Force, which supports terrorist groups.  

“The brutal Iranian regime exploits refugee communities in Iran, deprives them of access to basic services such as education, and uses them as human shields for the Syrian conflict,” Treasury Secretary Steven Mnuchin said.  “Treasury’s targeting of Iran-backed militias and other foreign proxies is part of our ongoing pressure campaign to shut down the illicit networks the regime uses to export terrorism and unrest across the globe.”

 

March 9, 2021 (Department of State, Foreign Operations, and Related Programs Appropriations Act, 2021)

The United States sanctioned two IRGC interrogators in the first new sanctions imposed by the Biden administration on Iran. Ali Hemmatian and Masoud Safadri were involved in torturing political prisoners and protesters detained during anti-government protests in 2019 and 2020 sparked by a gas price hike. The moved barred them and their immediate family members from entering the United States.

“Today at the Human Rights Council in Geneva, we made clear our concerns about the abuses the Iranian government continues to perpetrate against its citizens, including the unjust detention of far too many in deplorable conditions,” Secretary of State Antony Blinken said. “The United States is committed to promoting accountability for those responsible for such actions.”

 

August 13, 2021 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned an oil smuggling network for supporting the IRGC Qods Force. An Omani oil broker used several companies, including one based in Romania and one registered in Liberia, to sell Iranian oil abroad.

“The IRGC-QF has been using revenue from Iranian petroleum sales to fund its malign activities,” Secretary of State Antony Blinken said. “These sales depend on foreign intermediaries to obscure the IRGC-QF’s involvement. The United State will continue to expose and disrupt those supporting such efforts.”

 

September 17, 2021 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned members of an international network of financial facilitators and front companies for supporting the IRGC Qods Force and Hizballah. The network moved tens of millions of dollars’ worth of gold, electronics, and foreign currency.

“Hizballah and the IRGC-QF continue to exploit the international financial system to finance acts of terrorism,” Andrea Gacki, Office of Foreign Assets Control Director.  “The United States will not hesitate to take action to disrupt networks that provide financial support to Hizballah and IRGC-QF.”

 

October 29, 2021 (Executive Orders 13224 and 13382)

Under Executive Orders 13224 and 13382, the United States sanctioned four men and two companies for supporting UAV programs run by the IRGC and its Qods Force.

“Iran’s proliferation of UAVs across the region threatens international peace and stability. Iran and its proxy militants have used UAVs to attack U.S. forces, our partners, and international shipping,” Deputy Treasury Secretary Wally Adeyemo said.

 

March 30, 2022 (Executive Order 13382)

Under Executive Order 13382, the United States sanctioned one Iranian man and four companies for procuring equipment used for the IRGC-run ballistic missile program. “We have taken this action following Iran’s recent missile attack on Erbil, Iraq, as well as missile attacks by Iranian proxies against Saudi Arabia and the United Arab Emirates,” Secretary of State Antony Blinken said. “These attacks are a reminder that Iran’s development and proliferation of ballistic missiles pose a serious threat to regional and international security.” 

 

May 25, 2022 (Executive Order 13224)

Under Executive Order 13224, the United States sanctioned an oil smuggling network that secretly funded both Iran’s Qods Force, the external operations arm of the Revolutionary Guards, and Hezbollah, a Lebanese political party and militia. The U.S. named a web of nine companies and 10 men operating in Iran, Hong Kong, Lebanon, Russia, South Korea, Turkey, and the United Arab Emirates. They facilitated the sale of hundreds of millions of dollars’ worth of oil. 

The network, which was backed by “senior levels” of the Russian government and state-run economic enterprises, “has acted as a critical element of Iran’s oil revenue generation, as well as its support for proxy militant groups,” according to the Treasury Department. “While the United States continues to seek a mutual return to full implementation of the Joint Comprehensive Plan of Action (JCPOA), we will strictly enforce sanctions on Iran’s illicit oil trade,” Secretary of State Antony Blinken said in a statement. He said Behnam Shahriyari and Rostam Ghasemi, who both have had ties to the Qods Force, ran the operation; both men had already been sanctioned. 

 

Garrett Nada, managing editor of The Iran Primer, and Brett Cohen, a research assistant at the Woodrow Wilson Center, assembled this report building on previous work by Jason Starr, Helia Ighani, and others.

Updated