New bills are being introduced in Congress with bipartisan support that would target the Islamic Revolutionary Guard Corps (IRGC), Iran’s powerful extraterritorial militia, preventing it from benefiting from the sanctions relief that was allowed as part of the nuclear deal with the Islamic Republic.
Proposals like the IRGC Sanctions Act, the Quarantining the Ayatollah’s State-Sponsored Aggression and Militancy (QASSAM) Act, the Iran Terror Finance Transparency Act, the IRGC Terrorist Designation Act, and the Iran’s Revolutionary Guard Corps Sanctions Implementation and Review Act have been introduced by members of both parties in both Congressional chambers. Tyler Stapleton, Deputy Director of Congressional Relations for the Foundation for Defense of Democracies, and Emanuele Ottolenghi, a senior fellow at that think tank, wrote a policy brief  on Monday that explains and different ways the bills would sanction he IRGC and label it a terrorist organization:
The bills call for, inter alia, designating the entire IRGC as a foreign terrorist organization (the IRGC Terrorist Designation Act) and creating an IRGC watch list to provide transparency for companies looking to invest in Iran (IRGC Sanctions Act). Under the QASSAM Act, Treasury would be required to lower the threshold for companies to be considered IRGC-owned or controlled, thereby bringing hundreds of front companies, shipping assets, and financial institutions under greater scrutiny.
The Iran’s Revolutionary Guard Corps Sanctions Implementation and Review Act would provide for more effective sanctions against the IRGC or any of its officials, agents, or affiliates to counter support for international terrorism and assistance to the Assad regime in Syria. Lastly, the IRGC Sanctions Act would limit licenses granted to entities that have business relationships with the Guard and impede efforts to remove Iran from the State Department’s list of state sponsors of terrorism until Congress approves such a move.
The bills aim to address weaknesses in the current system of sanctions, which fail “to designate hundreds of Guard companies and thousands of its top officials.” The IRGC is a potent military and economic force in Iran, and controls around 20 percent of the value of the Tehran Stock Exchange. Once sanctions are lifted, Stapleton and Ottolenghi write, “Congress will have to move swiftly to minimize the risk that renewed trade relations with Tehran enrich the Guard’s already full coffers.”
While the language of the nuclear deal limits the United States from imposing new nuclear-related sanctions on Iran, Secretary of State John Kerry told  the Senate in July that Iran had agreed that sanctions related to terrorism or other similar issues would not violate the deal.
We’re not going to come back and just slap [sanctions] on again, but that absolutely does not mean that we are precluded from sanctioning Iranian actors, sectors, as any actions or circumstances warrant. So all of our other sanctions authorities remain in place, they are unaffected by this agreement, and Iran only said, if you read what it says, that they would treat the imposition of new nuclear related sanctions as the grounds to cease performing. But they are clear and we are clear that we have all other kinds of authorities and let me specific on that because it’s important for this whole debate to be clear.
The IRGC is being targeted because of its support for terror and human rights abuses.
Before the deal was announced, an Iranian businessman told Reuters  that Iran benefiting from sanctions relief would “increase the IRGC’s influence over politics and the economy because it will strengthen the hardline establishment.” Lee Smith, a senior fellow at the Hudson Institute, wrote  shortly after the deal was announced that the sanctions relief would strengthen the IRGC’s financial hold over Iran.
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