U.S. Should Target IRGC’s Economic Agents

The latest round of terrorist attacks and regional aggression by proxies of the Islamist regime in Iran has put the issue of terror finance by Tehran front and center. Washington has imposed sanctions on key components of the vast economic empire built by the Islamic Revolutionary Guard Corps (IRGC), which trains and supports Tehran’s proxies, yet it has not sanctioned many of the key executives that run the IRGC empire.

The IRGC seeks to raise funds inside and outside Iran and funnel them to its partners and agents worldwide. At the heart of the IRGC’s economic empire sit three main entities: the IRGC Cooperative Foundation, the Basij Cooperative Foundation, and the Khatam-al-Anbia Construction Headquarters. The United States has sanctioned all three of them but not many of their key officials.

The two foundations play a critical role in the IRGC’s economic empire, acting as its two main financial conglomerates, acquiring companies, both public and private. Meanwhile, the Khatam-al-Anbia Construction Headquarters plays the pivotal role of the nation’s largest infrastructure conglomerate, receiving the lion’s share of infrastructure mega deals.

Over the past year, the two foundations listed 14 persons as key figures on their board of directors. Currently, the United States has sanctioned only five of these people. The nine non-sanctioned individuals are as follows:

• Shahram Jafari, CEO of the Basij Foundation;
• Hamid Reza Mohammad Taghizadeh Ghouchani, Ali Nasr, Ali Kargrar, Ali Asghar Davarzani, and Heidar Baba Ahmadi, members of the Basij Foundation’s board;
• Mohammad Shoghi, chief inspector at both the Basij and IRGC Foundations;
• Jalil Safari, deputy chief inspector at the IRGC Foundation; and
• Abbas Shekarzadeh, deputy chief inspector at the Basij Foundation.

Abdolreza Abed, the commander of Khatam, is sanctioned by the U.S. Treasury, but many of his lieutenants are not. These include Second Brig. Gen. Assadollah Haji Zamani, deputy commander for coordination; Mohammad Reza Rahmani, CEO of Khatam’s Road and Urban Engineering Specialized Holding; and Mohammad Rostami, CEO of Khatam’s Energy Specialized Holding. Hojjat-al-Islam Hossein Ahmadian, Iranian supreme leader Ayatollah Ali Khamenei’s representative to Khatam, is not sanctioned either.

The United States should continue and expand its designation campaign targeting the IRGC’s key economic managers who oversee and control a large network of subsidiaries and in many cases sit on the boards of numerous other companies. This large network of firms has many contact points with companies and persons outside Iran who work in banking, consulting, and export and import operations. In other words, these designations would provide value beyond the usual name-and-shame campaign, as the economic operators have more exposure to the outside world in their day-to-day work in comparison to high-level military commanders or police officers.

The goal should be to designate thousands of the IRGC’s economic agents and put a minefield around its economic empire. Given the IRGC’s deep penetration of Iran’s economy, such a designation campaign will significantly increase the risk of doing business with Tehran and provide the United States with greater opportunity and flexibility to target non-complying persons and entities.

Saeed Ghasseminejad is a senior advisor on Iran and financial economics at the Foundation for Defense of Democracies (FDD), where he contributes to FDD’s Iran Program and Center on Economic and Financial Power (CEFP). Follow Saeed on X @SGhasseminejad. For more analysis from Saeed and FDD, please subscribe HERE. FDD is a Washington, DC-based, non-partisan research institute focusing on national security and foreign policy.