September 30, 2021 | Visual
The Sanctioned Cabinet of Ebrahim Raisi
September 30, 2021 | Visual
The Sanctioned Cabinet of Ebrahim Raisi
The Cabinet1 of Iran’s new president, Ebrahim Raisi, represents the culmination of a decades-long political project by Supreme Leader Ali Khamenei to promote ultra-hardline elites to key leadership positions.2 Drawn from an increasingly narrow bench, Raisi’s appointees include several persons who served under former President Mahmoud Ahmadinejad (2005–2013),3 who also harbored immense hostility to the West and stacked his Cabinet with veterans of Iran’s security forces.4
Reflecting this new constellation of power, Raisi’s Cabinet boasts 12 sanctioned individuals, more than any other in the history of the Islamic Republic. These persons are subject to overlapping international penalties imposed by the United States, European Union, United Kingdom, and United Nations due to their role in Khamenei’s networks, support for Iran’s nuclear program, ties to terrorist groups, and human rights abuses. These 12 also hold some of the most important portfolios, including the ministries of defense, interior, and petroleum as well as two vice presidencies.
The Cabinet members under sanctions include eight persons on the U.S. Specially Designated Nationals and Blocked Persons (SDN) List,5 seven persons subject to UK sanctions,6 seven persons subject to EU sanctions,7 and one person on a UN sanctions list.8 The EU and UK lists mirror one another, and both entities will delist the same three persons come October 2023, pursuant to the implementation timeline of the 2015 nuclear deal with Iran, formally known as the Joint Comprehensive Plan of Action (JCPOA).9 Similarly, UN sanctions will terminate in October 2023 pursuant to the same JCPOA implementation timeline.10 The other four EU and UK designations against members of Raisi’s Cabinet will remain, as they were issued under human rights-related authorities and are separate from each entity’s JCPOA commitments. Three of those four individuals have yet to be sanctioned by the U.S. Treasury Department.11
While Raisi is by now known for serving on a “death commission” in 1988 that led to the execution of several thousand political prisoners, he is subject to U.S. sanctions for having been elevated by Khamenei to a state position.12 Several other Cabinet members have been designated under this broad and unique U.S. sanctions authority, which exposes and penalizes the supreme leader’s network of appointees.13 They include First Vice President Mohammad Mokhber,14 who previously led a multibillion-dollar holding company owned by the supreme leader, known by its acronym, EIKO,15 as well as three others.16
Some cabinet members are subject to multiple sanctions authorities given their myriad crimes. A prime example is Rostam Ghassemi, a brigadier general in Iran’s Islamic Revolutionary Guard Corps (IRGC), an ideological force parallel to the Artesh (national military). The U.S. Treasury Department, using counterproliferation authorities, sanctioned Ghassemi in 2010 for supporting the IRGC’s “engineering arm.” Treasury designated him again in 2019, this time using counterterrorism authorities, for working for the IRGC’s Quds Force and its then-chief, Major General Qassem Soleimani, to illicitly export Iranian oil.17 Ghassemi is also subject to EU and UK nuclear-related sanctions but is slated to be delisted by October 2023 pursuant to the JCPOA.18
Furthermore, two members of Raisi’s Cabinet are subject to Interpol Red Notices — requests to locate wanted criminals — for their involvement in the 1994 terror attack against the AMIA Jewish Community Center in Buenos Aires, Argentina, which killed 85 people.19 Both are affiliated with the IRGC.20 Although Raisi’s Cabinet, like his predecessor’s, has an Artesh officer at the helm of the defense ministry,21 there at least three individuals in Raisi’s Cabinet who attained the rank of general in the IRGC. Multiple other Cabinet members have worked with or retain ties to the IRGC. The United States has designated the IRGC as a Foreign Terrorist Organization,22 but Iranian official sources allege that Washington will drop this penalty if nuclear negotiations result in a new agreement.23
During confirmation proceedings in the Iranian Majlis (parliament), Speaker Mohammad Bagher Ghalibaf confirmed an open secret: Khamenei personally approved key appointments to the Cabinet for positions related to national security, including but not limited to the minister of intelligence.24 Accordingly, the Majlis approved all but one of Raisi’s Cabinet nominees.25
Per Iranian law, the minister of intelligence must be a Mujtahid (a religious scholar),26 which remains the case for Raisi’s Cabinet. Ahmadinejad unsuccessfully contested the supreme leader’s choice for minister of intelligence in 2011, resulting in a political crisis late in his second presidential term.27
Khamenei’s willingness to have a Cabinet in which almost 40 percent of its members are subject to sanctions reflects his comfort with escalating tensions with the outside world and his confidence in not needing to feign moderation to garner relief from sanctions.
- Defined as presidential office, ministry heads, and vice presidents. See: Islamic Republic of Iran Presidency, “معرفی کابینه دولت [Introduction of the Government’s Cabinet],” accessed September 15, 2021. (https://www.president.ir/fa/president/cabinet). For biographies of ministerial nominees, see: “رئیسی فهرست وزرای پیشنهادی دولت سیزدهم را به مجلس معرفی کرد+ سوابق [Raisi introduced the proposed list of ministers of the thirteenth government to the parliament],” Fars News Agency (Iran), August 11, 2011. (http://fna.ir/33gsj)
- See: Saeed Ghasseminejad and Behnam Ben Taleblu, “Khamenei is Iran’s most important voter, and he wants more extremism, not less,” Al Arabiya (UAE), June 14, 2021. (https://english.alarabiya.net/views/news/middle-east/2021/06/14/Khamenei-is-Iran-s-most-important-voter-and-he-wants-more-extremism-not-less)
- This point has been stressed by Iranian reformists, who call the Raisi Cabinet “the third Ahmadinejad cabinet.” See: “کابینه معرفی شده بیشتر شبیه «کابینه سوم احمدینژاد» است/ معرفی برخی افراد ابهامآفرین است/ قحطالرجال شده که فردی با پرونده اختراع تقلبی وزیر شود؟ [The introduced cabinet is ‘the third Ahmadinejad cabinet’/Introducing some persons is ambiguous/Has there been a political famine that a person with a falsified patent has become a minister?],” Iran Labor News Agency (Iran), August 14, 2021. (https://www.ilna.news/fa/tiny/news-1117512)
- For a breakdown of those with IRGC vs. civilian, clerical, and other backgrounds in past Iranian Cabinets, see: Ali Alfoneh, “President Rouhani’s Cabinet: MOIS vs. IRGC?” Foundation for Defense of Democracies, August 7, 2013. (https://www.fdd.org/analysis/2013/08/07/president-rouhanis-cabinet-mois-vs-irgc)
- The SDN List can be searched here: U.S. Department of the Treasury, Office of Foreign Assets Control, “Sanctions List Search,” accessed September 15, 2021. (https://sanctionssearch.ofac.treas.gov)
- Note: Following Brexit, there are two UK sanctions regimes on Iran. The full UK sanctions list can be downloaded here: UK Foreign, Commonwealth & Development Office, “The UK sanctions list,” September 9, 2021. (https://www.gov.uk/government/publications/the-uk-sanctions-list)
- For EU Iran human rights listings, see: COUNCIL REGULATION (EU) No 359/2011 of 12 April 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Iran, UK National Archives.(https://www.legislation.gov.uk/eur/2011/359); COUNCIL IMPLEMENTING REGULATION (EU) 2021/584 of 12 April 2021 implementing Regulation (EU) No 359/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Iran, Official Journal of the European Union. (https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L:2021:124I:FULL&from=EN). For aggregated EU counterproliferation listings that are slated to terminate, see: Joint Comprehensive Plan of Action, Vienna, July 14, 2015, Annex 2. (https://2009-2017.state.gov/documents/organization/245319.pdf). Note: There are no Raisi Cabinet members on the EU terrorism list. To cross reference, see: COUNCIL IMPLEMENTING REGULATION (EU) 2021/138 of 5 February 2021 implementing Article 2(3) of Regulation (EC) No 2580/2001 on specific restrictive measures directed against certain persons and entities with a view to combating terrorism, and repealing Implementing Regulation (EU) 2020/1128, Official Journal of the European Union. (https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021R0138&from=EN)
- For UN list pursuant to conditions of United Nations Security Council Resolution 2231, see: UN Security Council, “Sanctions,” accessed September 15, 2021. (https://scsanctions.un.org/8zw7zen-iran.html). Note: This list is not to be confused with the Attachment found in Annex of United Nations Security Council Resolution 2231.
- Compare Cabinet member names with those listed in Attachment 2: Joint Comprehensive Plan of Action, Vienna, July 14, 2015, Annex 2. (https://2009-2017.state.gov/documents/organization/245319.pdf). For timeline, see: Joint Comprehensive Plan of Action, Vienna, July 14, 2015, Annex 5. (https://2009-2017.state.gov/documents/organization/245324.pdf)
- See: Behnam Ben Taleblu and Andrea Stricker, “Key Sunsets Under the JCPOA and UNSC Resolution 2231,” Foundation for Defense of Democracies, February 24, 2021. (https://www.fdd.org/analysis/2021/02/19/key-sunsets-under-the-jcpoa-and-unsc-resolution-2231)
- The Cabinet members who are subject to UK and EU human rights penalties but are not on the U.S. SDN List at the time of this writing are: Gholamhossein Esmaeli, Seyyed Mohammad Hosseini, and Seyyed Sowlat Mortazavi.
- Behnam Ben Taleblu, “The Coming Sanctions Battle Over Iran’s New President,” The National Interest, July 4, 2021. (https://nationalinterest.org/blog/middle-east-watch/coming-sanctions-battle-over-iran%E2%80%99s-new-president-189105)
- Executive Order 13876, “Imposing Sanctions With Respect to Iran,” June 26, 2019. (https://www.federalregister.gov/documents/2019/06/26/2019-13793/imposing-sanctions-with-respect-to-iran)
- Arsalan Shahla, “Iran’s Raisi Picks Sanctioned Endowment Chief as Vice President,” Bloomberg News, August 8, 2021. (https://www.bloomberg.com/news/articles/2021-08-08/iran-s-raisi-picks-sanctioned-endowment-chief-as-vice-president). For the initial sanctions press release, see: U.S. Department of the Treasury, Press Release, “Treasury Targets Billion Dollar Foundations Controlled by Iran’s Supreme Leader,” January 13, 2021. (https://home.treasury.gov/news/press-releases/sm1234)
- For background on EIKO, see: Behnam Ben Taleblu and Saeed Ghasseminejad, “Iran’s supreme leader has a business empire — the US must sanction it,” The Hill, November 1, 2017. (https://thehill.com/opinion/national-security/358203-irans-supreme-leader-has-a-business-empire-the-us-must-sanction-it)
- Find the “IRAN-EO13876” program tag on the individual SDN listings for: Major General Mohsen Rezaei, Brigadier General Mohammad-Reza Ashtiani, and Javad Oji.
- U.S. Department of the Treasury, Press Release, “Treasury Designates Vast Iranian Petroleum Shipping Network That Supports IRGC-QF and Terror Proxies,” September 4, 2019. (https://home.treasury.gov/news/press-releases/sm767)
- Find Ghassemi’s name (spelled “Qasemi” or “Ghasemi”) in: Joint Comprehensive Plan of Action, Vienna, July 14, 2015, Annex 2. (https://2009-2017.state.gov/documents/organization/245319.pdf)
- “New Iranian President’s Cabinet Pick Wanted by Interpol for AMIA Jewish Center Bombing,” The Algemeiner, August 11, 2021. (https://www.algemeiner.com/2021/08/11/new-iranian-presidents-pick-for-interior-minister-wanted-by-interpol-for-amia-jewish-center-bombing)
- They are Major General Mohsen Rezaei and Brigadier General Ahmad Vahidi. Interpol, Red Notice, “Rezai, Mohsen,” accessed September 15, 2021. (https://www.interpol.int/en/How-we-work/Notices/View-Red-Notices#2007-49958); Interpol, Red Notice, “Vahidi, Ahmad,” accessed September 15, 2021. (https://www.interpol.int/en/How-we-work/Notices/View-Red-Notices#2007-49957)
- For former President Hassan Rouhani’s defense minister from the Artesh, see: Behnam Ben Taleblu, “Why Iran’s New Defense Minister Doesn’t Change Much,” U.S. News & World Report, August 25, 2017. (https://www.usnews.com/news/best-countries/articles/2017-08-25/why-irans-new-defense-minister-doesnt-change-much)
- U.S. Department of State, Bureau of Counterterrorism, “Foreign Terrorist Organizations,” accessed September 15, 2021. (https://www.state.gov/foreign-terrorist-organizations)
- They also allege that Executive Order 13876, the U.S. authority under which most of Raisi’s Cabinet is sanctioned, would be lifted. See: Islamic Republic of Iran Foreign Ministry, “بیستودومین و آخرین گزارش روند اجرای برجام [The twenty-second and latest report on the implementation process of the JCPOA],” July 14, 2021, pages 37–41. (https://cdn.isna.ir/d/2021/07/12/0/61976377.pdf)
- See: “Raisi’s Key Ministers Approved By Khamenei, Iran Speaker Says,” Iran International, August 22, 2021. (https://iranintl.com/en/iran/raisis-key-ministers-approved-khamenei-iran-speaker-says)
- “Majlis votes for 18 proposed ministers, rejects education minister nominee,” Tehran Times (Iran), August 25, 2021. (https://www.tehrantimes.com/news/464333/Majlis-votes-for-18-proposed-ministers-rejects-education-minister)
- Islamic Republic of Iran Parliament, “قانون تعیین ضوابط و شرایط وزیر اطلاعات [Law on determining the terms and conditions of the Minister of Intelligence],” May 19, 1983. (https://rc.majlis.ir/fa/law/show/90739)
- “Iran’s Khamenei rejects minister’s resignation: report,” Reuters, April 17, 2011. (https://www.reuters.com/article/us-iran-minister/irans-khamenei-rejects-ministers-resignation-report-idUSTRE73G1LA20110417)