State Department Fact Sheet - Designation of the Islamic Revolutionary Guard Corps as an FTO

Date issued: Apr. 08 2019

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TURBOFAC Commentary (1376 words)

Notes:

1) The 2019 designation of the Iranian IRGC as an FTO was, as this Fact Sheet says, designed to "send[] a clear message to the world that the Administration is committed to exerting maximum pressure on the Iranian regime, and shines a spotlight on those in the IRGC who engage in terrorist activities."

However, as of 8/2019, neither the Fact Sheet nor any guidance from OFAC has clarified whether and to what extent the designation would have a practical impact on sanctions compliance. Indeed, even as late as five months subsequent to the designation, OFAC still had not amended or removed FAQ # 535 from its website (Is the IRGC now a Foreign Terrorist Organization (FTO))? No. The Department of State has not designated the IRGC as an FTO. [10/13/2017]).

The designation appears...