The US Department of State should make greater use of its ability to designate Iran-backed Shiite militias as foreign terrorist organizations (FTOs). To date, aside from the IRGC, the only Shiite militias styled as FTOs are Hezbollah in Lebanon, Kataib Hezbollah in Iraq, the al-Ashtar Brigades in Bahrain, and Asaib Ahl al-Haq. Similar entities acting as Iran’s proxies should likewise be added to the FTO list—including the Houthis, the Badr Organization, Saraya Khorassani, Harakat Hezbollah al-Nujaba, Kata’ib Imam Ali, Zainabiyoun Brigade, Fatemiyoun Division, Liwa Abu al-Fadhal al-Abbas, and Kata’ib Sayyid al-Shuhada. As an interim measure, the US government should levy terrorism sanctions against Iran’s affiliates in Iraq, Syria, and Yemen under Executive Order 13224.
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) should broaden the scope of activities constituting ‘significant support’ to Iran’s shipping sector. Iran’s ports are not only commercial in nature, but are also used to ship weapons to its regional allies, particularly in Syria. In line with recent guidance, OFAC should punish not only bunkering specialists, but also port authorities, importing agents, management firms, charterers, operators, marine insurers, classification societies, and all other “maritime services providers.” Presently, this web of maritime firms is allowing Iran’s 200-strong fleet of sanction- designated vessels, as well as non-Iranian vessels carrying sanctioned Iranian goods, to dock and unload cargos at ports all around the world. As part of this, the US government should expand and delineate very precisely the range of sanctionable maritime services.
UANI has identified scores of foreign-flagged vessels collaborating with the Iranian regime in an effort to continue exporting sanctioned Iranian oil and gas. Using a wide array of evasive and illicit tactics – ‘going dark,’ obscuring ownership, ‘flag-hopping,’ renaming, ‘spoofing,’ ‘ship-to-ship’ transfers – these vessels are providing the regime with its most critical economic lifeline. OFAC must work with the international shipping community, especially flag registries, classification societies, and P&I Clubs, to establish a widely accessible clearing-house of ‘rogue vessels’ prohibited from flagging, classing or insurance. While flag registries are increasingly alive to the issue of ‘flag-hopping,’ OFAC should also seek to individually designate vessels and/or their owners/operators as a complementary remedy.
The US Treasury should further inhibit the ongoing Iranian trade conference circuit. There are still dozens of Iran trade conferences encouraging foreign investment and business attended by Western companies. The US Department of the Treasury has already sanctioned the New Horizons conference organizer for supporting the IRGC-QF and for “host[ing] international conferences that have provided Iranian intelligence officers a platform to recruit and collect intelligence information from attendees...” The Treasury Department should likewise sanction Iran’s leading conference organizer, the Iran International Exhibition Co (IIEC). Accurately describing itself as “one of the most important economic and trade companies,” the IIEC is a key facilitator of foreign trade for European and Asian SMEs and holds around 90 exhibitions each year. Like New Horizons, the IIEC regularly works with multiple sanction-designated, GOI- and IRGC affiliated entities including the National Iranian Oil Company (NIOC), the Iranian Mines and Mining Industries Development and Renovation Organization (IMIDRO), the Industrial Development and Renovation Organization of Iran (IDRO), the Trade Promotion Organization of Iran, the Iranian Chamber of Commerce, Industries, Mine and Agriculture (ICCIMA), and the Iranian Customs Administration (IRICA). Furthermore, the Treasury Department should sanction any European organizer, notably including Germany’s IMAG GmbH, which continues to play a big role in convening Iranian conferences. Finally, the US government should call on all foreign companies to refrain from attending Iranian trade shows and business conferences for the same reasons that New Horizons was sanctioned: exposure to surveillance and corporate theft.
The United States should sanction all senior officials associated with the IRGC’s engineering and construction arm, Khatam al-Anbiya Construction Base (KCB a.k.a. Khatam ol-Anbiya Construction Base; Khatam al-Anbiya (KAA) Headquarters; KAA-IRGC; GHORB) as well as the IRGC’s Space Command. In October 2018, the IRGC commander-in-chief appointed Saeed Mohammad (a.k.a. Saeed Mohammad Esmaili) as KCB’s new “Commander.” Mohammad must be individually designated to inhibit his and KCB’s abilities to solicit foreign investment which directly advances the IRGC’s cause. As Iran’s largest contractor for industrial and construction projects with hundreds of satellite firms under its control, KCB is the most critical element in the IRGC’s economic dominance over the Iranian economy.