Founded just after the 1979 revolution, the Iranian Revolutionary Guard Corps (IRGC) fields elite military and paramilitary units (now deployed throughout Iraq and Syria), engages in clandestine activities and support for terror abroad, and is responsible for the country’s nuclear and ballistic-missile programs. It also exerts sizable political influence and controls a significant portion of the Islamic Republic’s economy. In a comprehensive study, Emanuele Ottolenghi, Saeed Ghasseminejad, Annie Fixler, and Amir Toumaj explain the various avenues through which the nuclear agreement grants the IRGC new sources of funding, and what can be done to restrict these without violating the deal’s terms:
Neither the U.S. nor the EU has sanctioned the vast majority of IRGC-linked companies. We have identified at least 229 companies with significant IRGC influence, either through equity shares or positions on the board of directors. The U.S. Treasury, however, has only sanctioned 25 IRGC individuals, 25 companies, and two academic institutions as owned or controlled by the IRGC. . . .
[As the nuclear deal is implemented and] export and trade restrictions are lifted, previously prohibited Western technology will make its way back to Iran. The challenge of denying the IRGC access to banned technology—including dual-use technology and equipment for monitoring dissidents—will become even more arduous. The demise of sanctions may also facilitate the acquisition of advanced weaponry that will improve Tehran’s conventional military capabilities, including the capabilities of the IRGC, which in turn may trickle down and enhance its ability to support the Syrian regime, Hamas in the Gaza Strip, Hizballah in Lebanon, and Houthi rebels in Yemen, to name a few.
[Furthermore], the United States and European Union have lifted specific sanctions against strategic sectors of the Iranian economy. We judge that [these] sectors are important for two reasons: the IRGC has an overwhelming stake in these sectors, and the sectors combined account for nearly half of Iran’s total GDP. Additionally, . . . these sectors are important to Iran’s ballistic-missile development.