Royce Bill would harden US sanctions against IRGC

A bill introduced into Congress by House Foreign Affairs Committee Chairman Ed Royce would, if law, expand sanctions against Iran’s Islamic Revolutionary Guard Corps (‘IRGC’). In October, President Trump described the IRGC as a ‘corrupt personal terror force and militia’ of Iran’s Supreme Leader, but it has not been added to the OFAC list of terrorist organisations.

If introduced, the Iranian Revolutionary Guard Corps Economic Exclusion Act would amend Section 301 of the Iran Threat Reduction and Syrian Human Rights Act of 2012 (‘ITRA’).

In a briefing on the proposed legislation, lawyers Anthony Rapa and Evan Abrams at the firm of Steptoe write:

‘As currently written, Section 301 of ITRA directs the president to identify and designate certain non-U.S. persons acting as officials, agents, or affiliates of the IRGC, but does not refer to entities owned or controlled by the IRGC. HR 5132 would clarify and strengthen Section 301 by requiring the president to target entities owned or controlled by the IRGC, and with regard to such entities, by authorizing the president to “identify foreign persons in which Iran’s Revolutionary Guard Corps has an ownership interest in such foreign person of less than 50 percent.”

‘If passed, this change could lead to a significant number of new designations and could complicate compliance for companies seeking to avoid entities which might become subject to U.S. sanctions.’

The bill is at:
https://foreignaffairs.house.gov/wp-content/uploads/2018/03/HR-5132.pdf