Previous administrations had contemplated a similar action, but sanctions have so far been applied only to the foreign special operations branch of the organization, the IRGC Quds Force. Some critics of the Iranian regime have dismissed those sanctions as ineffectual half-measures. For instance, the National Council of Resistance of Iran has long held that the actions of the Quds Force are fundamentally inseparable from those of the IRGC as a whole.

The NCRI coalition’s main constituent group, the People’s Mojahedin Organization of Iran has also gathered intelligence to show that the IRGC controls the majority of Iran’s gross domestic product, making it extremely difficult to isolate those revenue streams that end up contributing to imperialist foreign policy activities like Iran’s defense of the Syrian dictator Bashar al-Assad or its instigation of the Yemeni Civil War through IRGC-backed Houthi militants.

These sorts of activities were highlighted in President Trump’s statement to support his description of the IRGC as the primary tool of Iran’s global terrorist initiatives. Paralleling oft-repeated NCRI talking points, the president also explained that the IRGC blacklist “recognizes the reality” of Iran’s tendency to use “terrorism as a tool of statecraft.”

In 2018, at least half a dozen Iranian terror plots were thwarted in Europe and North America, including the planned bombing of an international rally organized near Paris by the NCRI on June 30. The revelation of such plots may have hastened and helped to justify the White House’s decision, just as it motivated the European Union to impose sanctions on Iran’s intelligence service and some of its known operatives.

Those sanctions and the accompanying public criticism of the Islamic Republic contributed to a notable downturn in relations between it and the nations of Europe. Last week, Iran’s Supreme Leader Ali Khamenei and Foreign Minister Javad Zarif – ostensibly representatives of opposing political factions – both offered sharp public criticism of the West, suggesting for instance that the EU was incapable of standing up to the US over the issue of sanctions which were re-imposed after Trump’s withdrawal last year from the seven-party Iran nuclear agreement.

Tehran has repeatedly threatened to walk away from that deal itself, if it failed to receive financial benefits from the Europeans in line with what Khamenei and his advisors deemed appropriate. At the same time, the Iranians have threatened to close off the Strait of Hormuz and have more vaguely threatened retaliation for each major action taken by the US government in service of the Trump administration’s strategy of “maximum pressure.”

In an interview with Fox News, State Department deputy spokesperson Hogan Gidley stated in no uncertain terms that the forthcoming sanctions on the IRGC are part of that strategy’s development. Gidley also emphasized that the Iranian economy is already in freefall, owing to the regime’s chronic mismanagement and the amplifying effects of the sanctions that have already been put in place. Meanwhile, supporters of these and other sanctions maintain that their effects tend to be limited to regime institutions, and do not generally extend to the civilian population, on account of the misplaced priorities of the Islamist regime.

In spite of the extensive control that the IRGC exerts over much of the Iranian economy, the Los Angeles Times stated that the pending blacklist can be expected to have limited impact. However, the same report goes on to set the stage for a debate over the strategic wisdom of the emerging plan, which could arguably “complicate US military and diplomatic work” as it concerns areas of Iranian influence in the broader region.

There is little question that the IRGC terror designation will intensify Iranian actions and statements against the US. Already, Iranian state media has declared the relevant sanctions “unwise and illegal,” and a threat to regional peace and stability. It is unclear whether the latter remarks were intended to suggest that the IRGC’s foreign role is beneficial to the Middle East, to convey a vague threat at the hands of the group, or both. But a threatening interpretation of those remarks is certainly suggested by some of the accompanying public statements emanating from Tehran.

UPI reported, for instance, that a collective statement by Iranian lawmakers had promised that the nation’s retaliation would make the US “regret the stupid move.” The same report quoted Foreign Minister Zarif as saying that the American policy would constitute a “disaster” for US interests. Meanwhile, to the extent that Iranian state media intended to convey the message that neighboring countries should embrace the IRGC, this was contradicted by Secretary of State Mike Pompeo, whom UPI quoted as saying, “masquerades as a legitimate military organization” when in fact it is purely a terrorist entity tasked with spreading Iran’s Islamic revolution both within Iranian society and beyond the country’s borders.

In spite of this professed role, or perhaps because of it, the IRGC has succeeded in finding regional partners, and this is arguably a major part of the reason why the Trump administration saw fit to take the unprecedented step of sanctioning a group that professes to be a state military institution. But these partnerships are also the basis of the LA Times’ aforementioned warning about the potential complications associated with the White House’s newest measures.

Those complications may prove to be especially apparent in Iraq, which has lately become a battleground for competing American and Iranian influences. IRGC-linked Shiite militias became entrenched in that country against the backdrop of the multilateral war against Sunni militants of the Islamic State of Iraq and the Levant. And as a result, the Iranian proxies have successfully fielded candidates for high office, thereby acquiring enough political capital to explicitly challenge the presence of US assets.

These challenges have been openly encouraged by leading Iranian political figures including Supreme Leader Khamenei, who once again spoke out on the issue on Saturday, at the time of a trip to Tehran by Iraqi Prime Minister Adel Abdul Mahdi. As Reuters reported, Khamenei urged the Iraqi government to demand US forces depart “as soon as possible,” then attempted to convince Baghdad of an American conspiracy to remove Iraqi politicians who represent a threat to American interests.

As if to reinforce that message while also retaliating directly against the White House’s newest sanctions, Iran’s Supreme National Security Council reportedly issued its own terrorist designation for the entire US military. But neither this gesture nor the American action that instigated it are likely to exert much influence on the opinions of other regional actors. Indeed, existing allies and adversaries of the Islamic Republic have already publicly expressed their support for one of the two competing designations, as evidenced by reports that the Bahraini Foreign Ministry had welcomed the IRGC terror designation, recognizing the group as a source of support for Shiite militants opposing that nation’s Sunni leadership.

Naturally, the American sanctions will have a greater practical impact simply by virtue of the size of the American economy. But Iraq and some other countries of the region are sufficiently dependent upon Iranian trade that they will not be able to simply disregard Tehran’s retaliatory measures. The White House is no doubt committed to diminishing that dependency, especially in the wake of the Iranian regime’s efforts to foster it. During Mahdi’s trip to Tehran, Iranian President Hassan Rouhani boasted of plans to boost trade between the two countries from 12 billion dollars per year to 20 billion. Mahdi himself endorsed the plan, as well as embracing a declaration of shared security interests during a joint press conference.

Countering these trends will presumably require more than just the force of US sanctions. And it is largely for this reason that some Western officials have been quick to express doubts about the White House’s plan. Elaborating upon the warnings that were conveyed in the LA Times, the Associated Press reported that American intelligence agencies have urged the provision of waivers that would allow government entities and US allies to communicate with persons who have had contact with the IRGC, so as to challenge its influence directly.

Although there is presently no clear indication that such waivers are forthcoming, there is also no reason to assume that they will not be. In fact, it is possible that the current situation will parallel the re-imposition of sanctions that had been suspended under the 2015 nuclear deal. At the time of US withdrawal, the Trump administration expressed the desire to withhold all waivers for secondary sanctions on the Iranian oil industry. But by the time those sanctions came into force in November, waivers had been granted to the eight largest importers, reflecting a practical adjustment to the realities of the global petroleum market.

There has almost certainly been ample time for concerned parties to make the case for a similar compromise on “maximum pressure” where enforcement of the IRGC blacklist is concerned. In an editorial for Fox News, Brett Velicovich wrote that the White House’s move “comes as no surprise to intelligence professionals like myself who have known for a long time the pure evil of the Iranian regime.” And regardless of practical concerns about the effects of the terror designation, Velicovich entertains no doubt that the IRGC would be responsible for more deaths and more instability “if we let them continue unchecked globally” and that the US blacklist of the group is therefore “long overdue.”