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.