The European Union levied new sanctions against Iran's Revolutionary Guards last week over a brutal crackdown on protesters. But some experts question the effectiveness of sanctions, saying they risk pushing Tehran closer to other sanctioned states, namely Russia and China. Instead, they advocate the creation of a special task force similar to the one hunting down Vladimir Putin's oligarchs.
The European Union slapped Iran's Revolutionary Guards with a fresh round of sanctions over the brutal crackdown on protesters following the September 16 death of 22-year-old Iranian Kurd Mahsa Amini, who died after being arrested for improperly wearing the required hijab.
More than 200 Iranian individuals and 37 entities have now been blacklisted by the EU in an eighth round of sanctions over the violent repression of protests that erupted in the weeks after her death.
Five new names were added to the list on May 22, including Sirjan County Prosecutor Moshen Nikvarz; Tehran police commander Salman Adinehvand; and the secretary of Iran's Supreme Council for Cyberspace, Seyyed Mohammad Amin Aghamiri. They were targeted for their role in monitoring and arresting demonstrators, some of whom were sentenced to death.
But the Islamic Revolutionary Guard Corps (IRGC) and its obscure investment wing, the IRGC Cooperative Foundation, were the main targets of the sanctions.
The EU hit the IRGC with an asset freeze, an EU travel ban and a prohibition against providing funding or other economic resources to those listed.
The country's Revolutionary Guards are believed to control as much as 20 to 30 percent of the Iranian economy. They own numerous companies, especially in the construction, transport infrastructure and airport sectors. Just how much they control is almost impossible to quantify, however, due to the IRGC's obscure, almost Byzantine web of organisations, deliberately established with multiple layers of subsidiaries that make relationships difficult to trace.
For these and other reasons, fresh sanctions are unlikely to have much impact.
"There are so many ways of circumventing them (the sanctions) that they are ineffective," said Stephane Dudoignon, an Iran specialist at the French National Centre for Scientific Research and author of a book on the Revolutionary Guards. The guards have as many as 120,000 to 190,000 members, but only 216 of them have made it onto the EU blacklist, Dudoignon noted.
Research associate David Rigoulet-Roze, of the French Institute for International and Strategic Affairs, described the way the paramilitary group has protected its finances. "The Revolutionary Guards have assets abroad; they have funds invested via a widespread system of corruption," he said, referring to Transparency International's 2022 global corruption index, where Iran was ranked 147 out of 180 nations.
Even some of Iran's most prestigious officials have fallen from grace due to corruption. The same day the EU announced its sanctions, Revolutionary Guard General Ali Shamkhani resigned as secretary of the Supreme National Security Council after allegations that his family had made millions of dollars from an oil transport company that was helping Iran evade sanctions - a charge he has denied.
The new money routes
Funneling money through transit points abroad and converting the cash into foreign currencies has also become an important source of funding. And the money rarely passes through Europe.
According to an investigative report published in Paris Match magazine in February, Turkey, the United Arab Emirates, Qatar, Oman, Georgia, Kazakhstan and Turkmenistan have become clandestine financial centres where the Revolutionary Guards stash money. The report said guard members also smuggle goods into these countries, sell them, and are paid in foreign currencies.
The Financial Action Task Force, a global money laundering and terrorist financing watchdog, in March of last year placed the United Arab Emirates on its grey list, which subjects it to increased monitoring.
Kasra Aarabi, head of the Iran programme at the Tony Blair Institute for Global Change in London, said new remedies are necessary since sanctions make little difference. Europe and the United States should set up a special task force to identify and sanction Iranian regime elites living in the West, he said, similar to how those loyal to Putin have been tracked since the invasion of Ukraine by the international Russian Elites, Proxies, and Oligarchs Task Force, which seized $30 billion in personal assets from sanctioned Russians in its first 100 days.
'Solidarity among the sanctioned'
Another challenge for any sanctions regime is that Iran's main investors are Russia, China, the Taliban and Iraqi Shiite militias, currently subject to sanctions themselves, explained one academic who requested anonymity. These entities won't be deterred from doing business by a new round of European sanctions on Iran.
"On the contrary, sanctions create solidarity among the sanctioned," the academic added.
The Revolutionary Guards thus remain relatively unaffected by European sanctions while Iran strengthens its diplomatic alliances with states arrayed against the West.
"If the aim is to sow discord within the Revolutionary Guards, the effect is counter-productive," the source said. "The Pasdaran (the guards) see themselves as a citadel under siege, so by being penalised they show their loyalty to the regime. There's even a promotion system for those who are targeted by Western sanctions," he said.
Nor is there a great risk of fallout among Iranian public opinion. Iran's President Ebrahim Raisi was placed on the US blacklist for complicity in human rights violations in November 2019 but was elected to the presidency less than two years later.
Dudoignon said there is even greater loyalty towards the regime among today's Revolutionary Guard members since they "owe everything" to the supreme leader, Ali Khamenei. Unlike the previous generations of Revolutionary Guards, who were appointed on merit and who acquired credibility through military or financial success, this new generation is more dependent on currying favour with the supreme leader himself.
"We've already seen former officers call on the authorities to be less severe on civilians. But today, it would be more difficult to do so for this new generation of officers, who are more fixated on Ali Khamanei," Dudoignon said.
Student group sanctioned
One part of the EU's latest sanctions package stands out, however: the blacklisting of the Student Basij Organisation (SBO).
The SBO is closely tied to the Revolutionary Guards and is accused of leading the violent crackdowns on protests at university campuses following Amini's death.
"Those who belong to the SBO will no longer be able to travel, study or work in Europe. Members can be easily identified using a number of methods, including open-source intelligence, given that the SBO has public websites with accessible lists in every Iranian university," said Aarabi, who wrote an article about the organisation in April.
The sanctions will actually affect SBO members, Aaraabi observed, because they travel and study in Europe. "The Iranian government gives them special grants and scholarships for this, as a sort of favour in exchange for their loyalty."
Could the sanctions lead to prosecutions?
Although most experts say the EU sanctions are unlikely to bring the regime to its knees, or even restrict the Revolutionary Guards' cash flow, their main goal is to show that the EU is putting pressure on Iran, punishing it for its violent crackdown on protesters.
"The EU produces individual sanctions to please us," said Hirbod Dehghani-Azar, a Franco-Iranian lawyer and a member of the Iranian Justice Collective, adding that it was important to make public the names of those being sanctioned.
"It's a stopgap measure, even if it has a certain effectiveness, because the people sanctioned won't be able to travel the world as they please; they have a finger pointed at them and it curtails their options. Let's not forget that they lose money by skirting sanctions."
Still, Dehghani-Azar, who is working with colleagues in Iran and the diaspora to gather evidence of abuses by the Revolutionary Guards, believes the sanctions could serve as a legal basis for prosecutions in the future.
"They provide a body of evidence that offers material for our mission."
He is currently working to have the Revolutionary Guards inscribed on the EU list of terrorist organisations.
This article has been adapted from the original in French.