Trump's Reckless New Iran Provocation

The following is the seminal work of NIAC Action and republished by Peace Action, of which I am a board member.

Designing the IRGC
According to the New York Times, the Trump administration is prepared to designate the Islamic Revolutionary Guard Corps (IRGC) a Foreign Terrorist Organization (FTO). This is an extremely provocative move by an administration that increasingly looks eager to start a war with Iran. At minimum, it will put the Joint Comprehensive Plan of Action (JCPOA) -- the Iran nuclear deal -- in extreme jeopardy.

An Escalation that Increases Risk of War and Undercuts Diplomacy
Hardliners will be boosted by provocative U.S. actions leading into the May 2017 Iranian presidential elections. Already, Iranian Supreme Leader Ali Khamenei has exploited the Trump administration's actions to generate popular backlash. The Rouhani government, which has advocated for engaging the West and has fought to reign in the IRGC, may either lose reelection or be forced to adopt a more hardline stance under domestic pressure due to the Trump administration's actions.

Jeopardizes the JCPOA
Paragraph 29 of the JCPOA's Main Text obligates the U.S. and other parties to "refrain from any policy specifically intended to directly and adversely effect the normalization of trade and economic relations with Iran."

The designation would subject non-U.S. persons that conduct a transaction involving a non-designated Iranian entity in the which the IRGC holds an interest -- passive or otherwise -- to civil and criminal penalties (18 U.S.C. 23339B). This action threatens to kill the practical value to Iran of the JCPOA's sanctions-lifting, as the risk of engaging with broad sectors of Iran's economy could prove too substantial to merit potential benefit.

The U.S. Military Has Opposed Designating IRGC
In 2007, the U.S. military reportedly opposed designating the IRGC or the Qods Force as a Specially Designated Global Terrorist (SDGT). According to "The Twilight War" by David Crist, it was the position of the Joint Chiefs that foreign militaries or their officers should not be designated as "terrorists" for fear that such designation could be reciprocated against the U.S. military, particularly the Special Forces officers.

Currently, the U.S. and Iran are engaged in de facto tactical cooperation in Iraq as both U.S. forces and Iran-linked Shia militias target ISIS forces, including in Mosul. Designating the IRGC an FTO will put that tactical cooperation at risk.

The designation could turn the current de facto cooperation into outright conflict with Iranian forces and proxies in Iraq. U.S. personnel remain on the ground in Iraq and an FTO designation could pose significant threats to U.S. soldiers on the front lines against ISIS forces.

The IRGC Is Already Heavily Sanctioned
The IRGC was not designated under a single sanctions program until October 2007 and has thrived since then in a sanctions economy.

Iran's private economy, not the IRGC, will be the victims of a designation. The chilling effect that an FTO designation would have on the entire Iranian economy will harm the private sector, which -- thanks to the JCPOA -- has been clawing back its share of the economy relative to the IRGC.

ADDENDUMS:
*Gasoline-powered lawn and garden equipment (GLGE) in the United States emits a total of 20.4 million tons of carbon dioxide per year, and that number is projected to reach almost 23 million tons in a few years, according to the EPA.