The Trump administration designated Iran's Islamic Revolutionary Guard Corps ("IRGC") as a Foreign Terrorist Organization ("FTO"), making it the first time that the United States has designated part of another government as an FTO. The Trump administration asserted that the designation will increase financial pressure on the regime and deprive it of necessary resources to fund terrorist activities.
The action puts businesses and other governments "on notice" with respect to the nature of the IRGC, which "operates front companies and institutions around the world to fund terror." The action also will authorize strict criminal penalties on knowing dealings with the group, and will place U.S. immigration restrictions on travel by any of its members.
Absent Congressional objection, the designation will go into effect on April 15, 2019.
Commentary / James Treanor
The FTO action against the IRGC is high on symbolism - the first such designation of a foreign government agency - but its practical implications may be limited. Any business, bank or other organization with even the most remote exposure to U.S. law should already be taking necessary precautions to avoid dealings with the IRGC and its network of companies. If any reminder was needed that enforcement of Iran sanctions is a top priority for the Trump administration - this is it.
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