WASHINGTON, D.C.—Today, Congressman Ted Poe (TX-02), Chairman of the House Subcommittee on Terrorism, Non-proliferation & Trade, introduced H.R. 3693 the IRGC Terrorist Sanctions Act of 2015. 

“Iran’s Islamic Revolutionary Guard Corps (IRGC) has funded, planned and executed terrorist attacks against the United States and our allies for decades,” said Chairman Poe. “Despite this fact, the IRGC has managed to escape the economic repercussions of Department of Treasury sanctions because of an excessively narrow rule defining Government of Iran controlled entities. The Department of Treasury also, inexplicably, has not yet designated the IRGC for its support of terrorism. It’s time to close both of these loopholes and hold the IRGC accountable for its terrorist actions.”

  • The Treasury Department has repeatedly cited the IRGC’s support for terrorism and destabilizing activity throughout the Middle East and beyond. However, only the IRGC’s Qods Force is currently designated by Treasury for its support for terrorism, while the broader IRGC is designated only for its role in proliferation and human rights abuses.
  • In multiple designations, Treasury has highlighted the IRGC’s involvement terrorist activities and even detailed the IRGC’s facilitation of al-Qaeda’s Iran-based network. The IRGC has been linked to terrorist attacks against Americans, including the 1983 bombing of the U.S. embassy in Beirut and the 1996 Khobar Towers bombing in Saudi Arabia. The IRGC is the parent organization of the Qods Force: it is directly responsible for its terrorist activities. 
  • There is also growing concern that the IRGC is engaging in financial evasion practices that erode the efficacy of the sanctions currently in place. Treasury currently sanctions companies that are 50% owned or controlled by the Iranian government or in which Iran wields a controlling interest. However, through control of a company’s board of directors, the IRGC can exercise the same level of power over a company without meeting Treasury’s designation trigger.
  • By exploiting this sort of legal loophole, the IRGC has managed to become so deeply entrenched in the Iranian economy to the point that, as former Treasury Secretary Henry Paulson pointed out, “it is increasingly likely that if you are doing business with Iran, you are somehow doing business with the IRGC.”

The IRGC Terrorist Sanctions Act of 2015 would stop this by requiring the Treasury Department to issue a report within 30 days detailing whether the IRGC meets the requirements for designation as a terrorist entity under E.O. 13224.

The Treasury report will also address whether IRGC control of a company’s board of directors triggers designation and outline the factors used to determine controlling interest for such purposes.

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