May 17, 2019
The designation of the Pasdaran as a “foreign terrorist organization” imposed three sanctions by law—but all three had already been imposed on the Pasdaran in prior years under other sanctions authorities.
The designation means 1) no US person may provide “material support” to the organization, 2) no visas may be issued to Pasdar members and 3) any Pasdar assets found in a US bank should immediately be frozen. Those sanctions have all been in place for decades.
But critics of the designation feared others might be innocently hurt by the designation. They suggested that anyone, including an American diplomat, dealing with the Lebanese government, in which the Hezbollah holds cabinet posts, could face US sanctions. And they said European businessmen doing legitimate business in Iran, might be caught up in sanctions if a company they dealt with was partly owned by the Pasdaran but they didn’t know that. There was also concern that Iraqis friendly to the US who have any contact with the Pasdaran could be hit by sanctions. And humanitarian groups working in the Middle East feared that their staff who sometimes brush up against the Pasdaran might be pummeled by sanctions.
Reuters reported last month that a State Department spokesman outlined new exemptions signed by Secretary of State Mike Pompeo that guarantee sanctions will not be imposed in such cases.
A State Department spokesman told Reuters, “Simply engaging in conversations with IRGC officials generally does not constitute terrorist activity.” Of course, that was true before the Pasdaran were designated as terrorist on April 15 and the new sanctions (which are also old sanctions) did not suggest otherwise.
The purpose of the exemptions appeared to be mainly a public relations exercise geared to calm down people who were coming to US diplomats with fearful questions about whether they were likely to have their bank accounts seized by the Americans or their US visas canceled.