The United States on Monday sanctioned more than 700 Iranian entities and individuals for enabling Tehran’s malign conduct, but it omitted half of the publicly listed firms under the principal control of the regime’s security forces. Listed on the Tehran Stock Exchange (TSE), these lucrative companies play a major role in financing Iran’s regional aggression and domestic repression.
The Armed Forces of the Islamic Republic of Iran owns more than 50 percent of the shares – or controls more than 50 percent of the seats on the boards of directors – of 22 TSE-listed companies. These firms encompass a variety of industries, including finance, energy, construction, automotive, and telecommunications, among others. Eleven of the 22 companies fall under the Armed Forces’ general jurisdiction (Table 1); the IRGC, in particular, controls the rest (Table 2).
The Armed Forces includes the Islamic Revolutionary Guard Corps (IRGC), the regime’s praetorians; the Law Enforcement Force (LEF) of the Islamic Republic of Iran, the state police; the Basij, or religious police; the Artesh, or conventional military; the General Staff of the Armed Forces; and the Ministry of Defense and Armed Forces Logistics (MODAFL). Supreme Leader Ayatollah Ali Khamenei, the commander-in-chief of the Armed Forces, directly appoints the heads of all of them except the MODAFL. The United States had already designated the IRGC, the LEF, the Basij, and the MODAFL prior to Monday’s sanctions.
On Monday, Washington sanctioned six companies under the Armed Forces’ general jurisdiction. Treasury had sanctioned two of those six – Ghadir Investment and Parsian Oil and Gas – before the finalization of the 2015 nuclear deal, which led to their delisting. Treasury had not previously sanctioned the other four – Motogen, Sepahan Cement, Shargh Cement, and Kurdistan Cement.
Treasury has yet to sanction the remaining five, which they should do in light of their ties to other firms that Treasury designated on Monday. Pardis Perochemical Company, Shiraz Petrochemical Company, Tabriz Oil Refinery, and Kermanshah Petrochemical Industries are subsidiaries of Parsian Oil and Gas, while Ghadir Investment controls the International Construction Development Company.
With respect to the 11 companies under the specific control of the IRGC, Washington sanctioned two of them – Ansar Bank and Tide Water Middle East – prior to the nuclear deal. Both remained sanctioned despite the deal, which did not provide much direct relief to IRGC-backed companies. Last month, Treasury sanctioned three of the others – Calcimin, Iran Tractor Manufacturing, and Iran Zinc Mines Developing Company – for providing financial support to the Basij.
Treasury also has never sanctioned the remaining six IRGC-backed firms – Iran Mineral Products Company, Iran Tractor Foundry Company, Iran Tractor Motors Manufacturing Company, National Iranian Lead & Zinc, Telecommunication Company of Iran, and Mobile Telecommunication Company of Iran.
The United States should resolve these discrepancies by sanctioning all 11 companies that so far have escaped designation. In so doing, the Trump administration can ensure that its maximum pressure campaign targets the full spectrum of actors responsible for facilitating Iran’s malign conduct.
Mark Dubowitz is the chief executive officer for the Foundation for Defense of Democracies, where Saeed Ghasseminejad is Senior Iran and Financial Economics Advisor. Follow Mark on Twitter @mdubowitz and Saeed @SGhasseminejad. Follow @FDD and @FDD_Iran. FDD is a Washington-based, nonpartisan research institute focusing on national security and foreign policy.