October 20, 2015 | The Hill

Time to Designate Iran’s Revolutionary Guards as Terror Group

Last week, news emerged that Russia's military deployment to Syria was offering cover to the Syrian regime and its allies in a campaign to recapture lost territories from rebel groups. But even that could not prevent a string of high-profile casualties among senior commanders of Iran's Islamic Revolutionary Guard Corps (IRGC) fighting alongside the Assad regime.

The recent death of IRGC commander Hossein Hamedani is a case in point. Hamedani was killed near Aleppo on Oct. 7, as the joint Syrian regime-Hezbollah-IRGC ground offensive got underway with Russian air cover.

It’s no surprise that Iran is providing the Assad regime with assistance on the ground in Syria. After all, the Islamic Republic of Iran is the world's foremost state sponsor of terrorism. But the killing of Hamedani and reports of other top IRGC commanders killed in Syria shines a spotlight on a deficiency in Washington's Iran policy. Indeed, the U.S. Department of Treasury designated Iran's Islamic Revolutionary Guard Corps' Quds Force (IRGC-QF) as a terrorist entity in 2007. The QF is the external fighting force of the IRGC, a vast military-industrial complex tasked to quash internal dissent in Iran and export its ideology abroad while cherry-picking massive profits from the Iranian economy.

The QF represents the elite of Iran's corruption, terrorism, human rights violations and regional destabilization. In spite of that, its parent organization has yet to be designated. The IRGC and the Quds Force are one and the same. The time has come for U.S. authorities to discard this artificial distinction and extend the terrorist designation to the IRGC as a whole.

The Guard is playing a central role in support of Syrian President Bashar Assad's war crimes, which include the systematic ethnic cleansing of the Sunni countryside, the torture of thousands of civilians and the indiscriminate bombing of civilian areas, both with conventional and chemical weapons. The IRGC is contributing advisors, coordinating military operations, ferrying its foreign contingents of Shiite Afghan and Iraqi fighters to Syria, and shipping a steady flow of military supplies to the regime and its Lebanese proxy, Hezbollah, which Iran has mobilized for Syria's war effort.

According to open-source data collected by my colleague, Foundation for Defense of Democracies Senior Fellow Ali Alfoneh, from Persian-language accounts of funerals in Iran, at least 144 Iranian nationals were killed in combat in Syria between January 2013 and Oct. 15, 2015. All Iranian fatalities served in the IRGC. Many of them served in the IRGC Ground Forces and at least three came from the Basij militia.

These figures suggest that IRGC casualties extend well beyond the QF. A relatively small unit, the QF is spread thin in theaters of conflict across the region, from Afghanistan to Lebanon. Therefore, the IRGC had no other choice but to deploy its “regular” Ground Forces to Syria, which in turn blurs the functional differences between its branches and makes the entire IRGC into a large extraterritorial operations force. Most importantly, while local military operations in Syria may be coordinated by the QF commander, Qasem Soleimani, overall command responsibility lies with the IRGC in Tehran.

The easiest way would be for the U.S. administration to use Executive Order 13224, the same instrument that Treasury used in 2007 against the QF. Executive Order 13224 “is an authority aimed at freezing the assets of terrorists and their supporters, and at isolating them from the U.S. financial and commercial systems.” An IRGC designation under the order for its financial, military and logistical support of Syria's regime would also lay the foundation for a blanket targeting of the Guard's vast economic empire, the revenues of which help finance its military operations.

The secretary of State could also designate the IRGC as a “Foreign Terrorist Organization” under Section 219 of the Immigration and Nationality Act (2011). As a foreign organization engaged in terrorist activity that threatens U.S. national security and the security of U.S. nationals, the IRGC fully qualifies. There are thus two pathways for the administration to target the IRGC and exact a price for its complicity with war crimes in Syria.

Washington continues to collectively wring its hands over what can be done to stem the bloodshed in Syria. An IRGC designation is a good first step. And it can send a strong signal to Iran that, even after the Iran nuclear deal's implementation, its illicit actors won't get a free pass.

Emanuele Ottolenghi is a senior fellow at the Foundation for Defense of Democracies and its Center on Sanctions and Illicit Finance. Follow him on Twitter @eottolenghi

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