The very real dangers of Biden’s pending Iran nuclear deal

With a renewed nuclear deal reportedly imminent, the Biden administration has touted its hard-nosed negotiating tactics forcing Iran to accept that its Islamic Revolutionary Guards Corps (IRGC) will remain on the State Department’s list of Foreign Terrorist Organizations. While that’s technically accurate, the real question is what practical effect any new deal might have on IRGC finances and whether they would benefit from the $100 billion a year in sanctions relief likely to also be part of a renewed agreement.

Most people think of the IRGC as a military and terrorist organization, but in reality, they control a significant percentage of Iran’s everyday economy. In 2010, Iran expert Meir Javedanfar said, “A conservative estimate would be to say that the IRGC now controls at least half of [Iranian] government-owned companies.” Alireza Nader of Rand Corporation has noted, “The Revolutionary Guards is the key economic player in Iran and control(s) Iran’s official and illicit economy.” Indeed, their investments include domestic construction and infrastructure, energy production, medical surgeries, food, education, transportation and, of course, military infrastructure. 

There is little difference between the Iranian government under the control of Supreme Leader Ali Khamenei, his heir apparent, President Ebrahim Raisi, and the Revolutionary Guards. They are intertwined. According to Reuters, the IRGC is a more than 125,000-strong military force, “is also an industrial empire with political clout, and is loyal to the supreme leader.” BBC reported that the IRGC’s Khatam al-Anbia Construction Company “control(s) around a third of Iran’s economy through a series of subsidiaries and trusts” worth an estimated $100 billion. Western distinctions in negotiations between the IRGC and the Iranian government are artificial and misleading, undermining our strategic goals.  

According to Mark Dubowitz, chief executive of the Foundation for Defense of Democracies (FDD),  “The Biden administration’s decision to keep the IRGC on the Foreign Terrorist Organizations list now looks like a legal sleight of hand and not like a principled defense of that designation. If reports are true, the Biden team has agreed to gut IRGC sanctions and allow tens of billions of dollars to flow to terrorists actively plotting to murder even more Americans.” His colleague, Richard Goldberg, added, “Either President Biden believes the IRGC is a terrorist organization, or he doesn’t. If this were ISIS or al Qaeda, would anyone be offering sanctions relief to their top financiers or negotiating how foreigners could do business with their affiliates?”  

Secondary sanctions penalize countries and entities that deal with and profit from trade with a sanctioned organization. The 2015 nuclear agreement known as the Joint Comprehensive Plan of Action (JCPOA) bypassed restrictions on the IRGC by removing sanctions on whole segments of the Iranian economy controlled by the organization. According to the FDD experts, in a new agreement the “full enforcement of U.S. secondary sanctions against IRGC affiliates will be lifted … with additional terrorism-sanctions relief for the IRGC’s top financiers, including the Central Bank of Iran and the National Iranian Oil Company.”

The Central Bank of Iran (CBI) has a history of subterfuge, hiding and transferring funds for the IRGC to support its terrorist networks in Lebanon, Syria, Iraq and Yemen. This has included circumventing sanctions on oil exports and covering up the true source of transactions. With a new deal, sanctions against the CBI reportedly will be lifted, allowing it to more easily cover the financial tracks of the Revolutionary Guards.  

If you expect the Biden administration to enforce secondary sanctions against the IRGC after a new Iran deal comes about, then you also may believe that the JCPOA will permanently end Iran’s ability to develop atomic weapons and that the moon is made of green cheese. As it was with President Obama, non-nuclear-related sanctions for terrorism, human rights abuses and missile proliferation will be minimally enforced so as not to rock the boat, by displaying Iran’s defiance. 

The bottom line is that Iran’s hundreds of billions of dollars in sanctions relief will benefit the IRGC and its malign activities. The Foreign Terrorist Organizations designation is more for show than effect, since there will be no secondary sanctions on businesses that have one degree of separation from the IRGC. The organization’s prosperity provides the financial resources needed to support proxies such as Hezbollah, Hamas, Palestinian Islamic Jihad, and Iranian-controlled Popular Mobilization Units.

Can Congress do anything to stop the financial enrichment of the IRGC in the Biden administration’s new nuclear deal? No. By law, the Iran Nuclear Agreement Review Act of 2015, sanctions relief must be reviewed by Congress. There is little doubt that all Republicans will vote against lifting sanctions and almost all Democrats will support it. Even if a majority of Congress were to vote against sanctions relief in a renewed deal, Biden would veto that decision. 

Defenders of this deal claim it is better than no deal, because at least there will be some temporary restrictions on Iran’s nuclear program. They point to North Korea, noting there are no agreements or hope for reining in a fanatical regime. 

Unfortunately, this bad deal with Iran will not be better than having no deal. Providing financial support for the Islamic Revolutionary Guard Corps will feed the regime’s appetite for expansionism and terrorism, increasing the potential for a regional war. In a few years, any nuclear restrictions will expire, and a Middle East nuclear arms race inevitably will follow. How would any of this advance America’s national security interests?

Dr. Eric R. Mandel is the director of MEPIN, the Middle East Political Information Network. He regularly briefs members of Congress and their foreign policy aides. He is the senior security editor for the Jerusalem Report. Follow him on Twitter @MepinOrg.