Written by Dr. Raymond Tanter and Edward Stafford

The Argument

“Terror tagging” refers to labeling Iran’s Islamic Revolutionary Guard Corps (IRGC) as a Foreign Terrorist Organization (FTO).

We argue that terror tagging of Iranian institutions and individuals would facilitate the growth of liberal democracy in Iran, e.g., provide real guarantees to the people of Iran that the leadership would face consequences for violation of civil liberties at home and rules of international relations norms abroad.

The Iranian parliament is under the sway of the Supreme Leader and other religious leaders, who preside over a religious dictatorship without real checks, such as separation of powers that have independent authority. The Iranian military is in effect subordinated to the IRGC, which also controls most of the economy. To coin a phrase, Iran is not a garden variety liberal democracy, to say the least.

Electoral results that do not satisfy the leadership are ignored and protests of anti-democratic governmental action are ruthlessly and systematically suppressed. It appears as if the leadership of Iran faces few domestic consequences for its illiberal and anti-democratic rule; so, to paraphrase Burke, the fewer consequences from within, the more needed from without.

Candidates for Designation

The IRGC is a foreign organization we believe should be designated by the Secretary of State. Legal criteria for designation are: 1) It must be a foreign organization; 2) engage in terrorist activity or terrorism, or retain the capability and intent to engage in terrorist activity or terrorism; and 3) the organization’s terrorist activity or terrorism must threaten the security of U.S. nationals or the national security (national defense, foreign relations, or the economic interests) of the United States).

The Bureau of Counterterrorism and Countering Violent Extremism is the lead unit within State for FTO designation. In Treasury, the lead entity is the Office of Foreign Assets Control (OFAC).

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities like proliferation of weapons of mass destruction, and other threats to the national security, foreign policy, or economy of the United States.

With respect to Iran, it remains a designated state sponsor of international terrorism. These are countries determined by the Secretary of State to have repeatedly provided support for acts of international terrorism. And there are some entities/persons designated as SDNs.

To designate an organization or individual, there must be evidence they pose threats to the national security, foreign policy, or economy of the United States. The IRGC is a threat to the national security interests of the United States.

As evidence of congressional interest in designation, on Jan. 10, Representative Michael McCaul (R-TX), introduced H.R.380 and Senators Ted Cruz, (R-TX) and James Inhofe (R-OK) S.67, titled, “The Iranian Revolutionary Guard Corps (IRGC) Terrorist Designation Act.” These identical bills emphasize that “Iran’s Revolutionary Guard Corps meets the criteria for designation as a foreign terrorist organization as set forth in section 219 of the Immigration and Nationality Act (8 U.S.C. 1189); and that the Secretary of State should designate Iran’s Revolutionary Guard Corps as a foreign terrorist organization under such section 219.”

Congressman McCaul said, “If a foreign organization looks like a terror group, operates like a terror group, and supports terrorism, then it should be called for what it is–a foreign terrorist organization. As obvious as that seems, for years the IRGC has been allowed to operate clandestinely using front companies and illicit networks to evade formal designation.”

Senator Cruz added that by designating IRGC as a foreign terror organization, the U.S. would be “signaling to financial institutions and companies who facilitate or conduct business with the IRGC that they may be held liable.” Cruz authored another bill, S.68, to designate the Muslim Brotherhood as a terrorist group. Although it does not mention Iran, we include S.68 because the Brotherhood and Tehran line up as a threat against Riyadh.

The Way Forward

Trump made excellent choices for his national security team—Rex Tillerson, State; Gen. James Mattis, Defense; Gen. Mike Flynn, White House; Gen. Kelly, Homeland Security; Dan Coats, Director of National Intelligence; and Director of Central Intelligence, Mike Pompeo.

The team can speak truth to power—an over-concentration of control in any one place. In so doing, they can suggest policies that consider views of allies, military capabilities, and sound intelligence from sources abroad and at home. The group can make novel recommendations to blunt the Iranian threat to U.S. and allied interests.

One idea would be to give succor to the democratic forces within Iran by imposing costs on anti-democratic leaders. The team may be able to convince President Trump to use designation as a tool. The overall goal would be to minimize the threat posed by the Islamic Republic of Iran to Israel, Tehran’s Sunni Arab Gulf neighbors, Iraq, Syria, Lebanon, and even to the Americas.

Designation also would help bring liberal democracy to Iran by weakening the grip of a key repressive institution—the Islamic Republican Guard Corps.

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Dr. Raymond Tanter served as a senior member on the National Security Council staff in the Reagan-Bush administration and is now Professor Emeritus at the University of Michigan. Edward Stafford is a retired Foreign Service officer; he served in Political-Military Affairs at the State Department, as a diplomat with the U.S. Embassy in Turkey, and taught at the Inter-American Defense College.