That Iranian forces have harassed U.S. Naval forces in the international waters of the Persian Gulf, demonstrates that Iran’s leadership is prepared to test the new Trump administration on its commitment to confront Iran when it fails to meet its obligations under the JCPOA (the Joint Comprehensive Plan of Action), as well as violations of United Nations sanctions, or engagement in destabilizing activities in the region.

Because there are other nations involved with the JCPOA and U.N. sanctions on ballistic missiles, Washington’s unilateral options for confronting Iran’s unacceptable behavior are limited. However, designation of the Islamic Revolutionary Guard Corps as a Foreign Terrorist Organization (FTO) would be an effective option.

Raymond Tanter, senior member on the National Security Council staff in the Reagan-Bush administration, and Edward Stafford, retired Foreign Service officer focusing on political-military affairs write in their article for The Hill, “The State Department FTO list for 2015, published in June 2016, includes neither the Quds Force nor its parent, the IRGC. Secretary of State Rex Tillerson can add both to the list pursuant to three criteria: They must be foreign organizations engaged in terrorist activity that threatens U.S. persons or U.S. national security (i.e., national defense, foreign relations or the economic interests of the United States). Because of the IRGC-QF's ongoing support for terrorist activities, no justification for its designation is needed. Herein we argue that its parent organization, the IRGC, also merits designation, due to its function as the paymaster of the Quds Force.”  They add, “The IRGC-QF is not an element of the armed forces subordinate to military leadership; it is a distinct entity that serves the Supreme Leader to guard the Islamic Revolution. As such, it is not in fact a formal governmental entity but an expression of the Islamic Republic’s revolutionary movement. This independence from the elected government’s authority makes it a de facto nongovernmental actor operating in an extra-legal fashion, particularly when operating abroad. Thus, any use of violence by the IRGC-QF would be extrajudicial.”

 The real authority in Iran is the Ayatollah Ali Khamenei, whose authority overreaches that of the president and Parliament, allows an unofficial entity, the IRGC, to function outside the formal system of authority while appearing to be an official institution.

However, according to Tanter and Stafford, “The IRGC is dedicated to protecting the Islamic Revolution, not the state of Iran. As guardians of the Islamic Revolution, it supports terrorist activities by the Quds Force and its other military divisions. The IRGC finances these terrorist activities through its business activities, making the overall organization simply the paymaster for terrorist activities by its constituent elements. Efforts to shut off the flow of funds by using U.S. Treasury sanctions against different controlled or directed business entities become a never-ending attempt to keep track of firms that shut down and reopen under a new name, adding difficulties to blocking the flow of funds to them.”

Designating the IRGC as an FTO could constrain its foreign activities, as legitimate businesses have to conduct due diligence on partners in the regions. Designation could enable Rex Tillerson to lobby with countries involved with Iran to sever their commercial ties with the IRGC. It could encourage legitimate Iranian business interests to keep the IRGC at arm’s length, and allow independent business to grow.

The National Council of Resistance of Iran (NCRI) has documented the extent of the IRGC business interests, and their negative impact in their a recent book,“Iran, The Rise of the Revolutionary Guard's Financial Empire”.  This book describes how the IRGC bankrolls terrorist activities abroad, and how their financial activities starve investments from legitimate businesses within Iran that could engineer the more moderate political leadership that was to be strengthened by the JCPOA. It further states that moderate political leaders are doomed to failure as long as the IRGC has a hand in the Iranian economy, because he ayatollahs and the IRGC hold a monopoly over the Iranian economy. “To do business with Iran is to do business with the IRGC,” says the NCRI. Controlling the economy for their own benefit, rather than that of the general population, gives way to unemployment, high inflation, and other factors that make a strong recipe for social discontent.

Also documented in the 2016 report by the NCRI: “How Iran Fuels Syria's War,” the IRGC financial activities pay for the Iranian involvement in Syria and Iraq. In the case of Syria, the IRGC pays for Hezbollah and other non-Iranian fighters to prop up the Assad regime, reducing the effectiveness of the U.S. and others, and increases the influence the of the Iranian regime in Syria after the war there comes to an end. 

“Pro-regime security forces are already establishing themselves in Damascus, and the jockeying for influence in a post-war Syria has begun, say Tanter and Stafford, “Among these groups are those either controlled or financed by the IRGC, establishing a means for Iran to continue to direct events in Syria after the fighting has come to an end — all financed by the IRGC Designation also achieves diplomatic goals. It sends a message to the Gulf States that President Trump is serious about blunting the hegemonic intentions of Iran; it reaffirms his commitment to fighting terrorism by going after the financial empire used to sustain terrorist activities; and it sends a message to the Iranian people that he is resolved to contain the ayatollahs’ revolutionary movement, with no animus against the Iranian people.”