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FDD | Nuclear Deal with Iran Would Gut IRGC Sanctions

fdd nuclear deal with iran would gut irgc sanctions
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A top Iranian spokesman said on Sunday that Iran achieved “huge progress” in “sanctions issues.” The West has reportedly offered Iran economic concessions that would lift indirect sanctions on the Islamic Revolutionary Guard Corps (IRGC). As part of a revived nuclear deal, this action would effectively dismantle the bipartisan sanctions architecture overwhelmingly enacted by Congress just five years ago while America remained a participant in the Joint Comprehensive Plan of Action (JCPOA). This and other forms of sanctions relief would allow Tehran to access up to $275 billion during the accord’s first year and $1 trillion by 2030.

Expert Analysis

“The Biden administration’s decision to keep the IRGC on the Foreign Terrorist Organization list now looks like a legal sleight of hand and not like a principled defense of that designation. If reports are true, the Biden team has agreed to gut IRGC sanctions and allow tens of billions of dollars to flow to terrorists actively plotting to murder even more Americans.”
Mark Dubowitz, FDD Chief Executive

“Either President Biden believes the IRGC is a terrorist organization, or he doesn’t. If this were ISIS or al-Qaeda, would anyone be offering sanctions relief to their top financiers or negotiating how foreigners could do business with their affiliates? Given ongoing IRGC terror plots against the United States, any sanctions relief benefitting the group should be unacceptable. Congress has been firm in its support for sanctions against IRGC affiliates and may need to act to reimpose those sanctions.”
Richard Goldberg, FDD Senior Advisor

Nuclear Deal Would Enrich the IRGC

The proposed deal would demolish indirect sanctions on the IRGC — the terrorist organization that controls between 20 and 40 percent of Iran’s economy — by reportedly allowing non-U.S. persons to conduct business with the group’s affiliates. While the IRGC would remain on the State Department’s Foreign Terrorist Organization list and continue to be designated by the Treasury Department, the full enforcement of U.S. secondary sanctions against IRGC affiliates would be lifted.

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The original 2015 agreement gave the IRGC indirect sanctions relief by lifting sanctions on entire sectors of Iran’s economy that the IRGC controls in whole or in part. In so doing, the deal circumvented (but technically complied with) earlier U.S. sanctions on the IRGC for its nuclear program, missile proliferation, human rights abuses, support for Syria’s Assad regime, and terrorism committed by the Quds Force, the IRGC’s foreign-operations arm.

This latest deal exceeds the terms of the original JCPOA. It would provide the IRGC with the same indirect sanctions relief as before, with additional terrorism-sanctions relief for the IRGC’s top financiers, including the Central Bank of Iran and the National Iranian Oil Company.

The Biden Administration Must Not Break Its Commitment

In 2021, the Biden administration pledged to enforce terrorism sanctions on Iran without distinguishing between U.S. persons and non-U.S. persons. During his confirmation hearing to serve as secretary of state, Antony Blinken said America should do “everything possible, including the toughest possible sanctions, to deal with Iranian support for terrorism.” Asked specifically if it is in the U.S. interest to maintain terrorism sanctions on the Central Bank of Iran and the National Iranian Oil Company, Blinken answered in the affirmative.

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