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How to sanction Iran – The Washington Times

By Matthew Levit

The Washington Times – Last week, Iran’s Supreme Leader Ayatollah Ali Khamanei threatened to hit back at U.S. interests “worldwide” if attacked. That same day, Iran’s Revolutionary Guards Corp (IRGC), the force likely responsible for carrying out any such attacks, kicked off naval and air exercises in the Persian Gulf and Sea of Oman, which flank the Strait of Hormuz through which an estimated 20 percent of world oil transits daily.

The question is how to avoid military confrontation with Iran while confronting the Islamic Republic over its nuclear program, its support for terrorist groups and its involvement in IED (improvised explosive device) networks in Iraq.

U.S. officials are pressing their European counterparts to discourage investment and financial transactions with Iran, to stop export credit guarantee programs for companies doing business in Iran, and to work with the private sector to deny Iran access to outside financial services. But while Washington has enjoyed some success reaching out to the public sector — several banks have ended or restricted dollar transactions with Tehran — both European governments and the European Union (EU) have demurred, asserting their preference for implementing United Nations Security Council Resolution (UNSCR) 1737, passed in December.

And therein lies the answer. The most robust and effective nonmilitary tool available to the international community is to apply UNSCR 1737 in full. While many pundits blasted UNSCR 1737 as toothless and ineffective, fully carried out it would employ travel bans and targeted financial sanctions against the very tool of Iranian foreign policy responsible for the regime’s unacceptable conduct: the Revolutionary Guards.
The annex to the resolution listing entities involved in Iranian proliferation activity does not include the Revolutionary Guards. But two key leaders, IRGC commander Maj. Gen. Yahya Rahim Safavi and IRGC air force chief General Hosein Salimi, are listed as persons involved in Iran’s nuclear and/or ballistic missile programs.

Under UNSCR 1737, member states “shall freeze the funds or other financial assets and economic resources that are owned or controlled by persons or entities designated in the Annex.” In other words, by virtue of listing the overall head of the IRGC (and the head of its air force), the U.N. empowered — a strict reading suggests it requires — member-states to freeze IRGC funds and financial assets.

And while they have been skittish over employing unilateral sanctions, EU leaders have strongly backed enforcing UNSCR 1737. EU foreign ministers called on all countries to enforce the resolution’s sanctions, while EU foreign policy chief Javier Solana, expressing his own concerns about additional financial measures against Iran, asserted, “What we have to do is apply the [U.N.] resolution.”

To be sure, the Republican Guards are precisely the element within Iran that should be targeted. Considered the backbone of President Mahmoud Ahmedinejad’s political powerbase, the Guards are an elite military corp that operates independently of Iran’s regular armed forces and reports directly to the supreme leader. The IRGC is deeply involved in the country’s nuclear, missile and other weapons proliferation activities, and maintains a special branch — the Qods Force — responsible for providing funds, weapons, IED technology and training to terrorist groups like Hezbollah and Hamas and insurgents attacking Coalition and Iraqi forces in Iraq.

Indeed, U.S. officials recently revealed Qods Force commander Mohsin Chizari was among the six Iranians detained in northern Iraq last month.

Applying targeted financial measures against the IRGC represents the kind of regime-hostile, people-friendly sanction that punishes those engaged in offensive behavior without harming the average Iranian citizen. Indeed, the award of no-bid contracts to IRGC companies is already the stuff of domestic criticism and charges of cronyism. Moreover, the IRGC controls vast financial assets and economic resources. While most of the actual funds and assets are in Iran and beyond seizure, the IRGC’s business and industrial activities — especially those connected to the oil and gas industries — depend heavily on the international financial system.

Consider, for example, the $2.09 billion contract to develop parts of the South Pars natural gas field, or the $1.3 billion contract to build parts of a pipeline, both meted out to the IRGC’s engineering arm, the Khatam-ol-Anbia.

As the Feb. 21 deadline nears for Iranian compliance with international demands for a halt to Tehran’s uranium enrichment program, European capitals should already be considering not if but how to apply targeted financial measures focused on the IRGC. A simple reading of UNSCR 1737 requires member states to apply financial measures against financial assets and economic resources controlled by IRGC’s head.

Moreover, targeted financial measures against the IRGC can work, for several reasons: Enforcing this existing multilateral sanction requires passing no new domestic legislation; it fulfills Europe’s strong preference for only multilateral action against Iran; it targets bad actors as opposed to the population at large; it buttresses domestic criticism of the Ahmedinejad regime’s cronyism; and it pulls at the purse strings of the specific element of the Iranian bureaucracy responsible for the regime’s most egregious behavior.

Matthew Levit is senior fellow and director of the Stein Program on Terrorism, Intelligence and Policy at the Washington Institute for Near East Policy.