President Donald Trump signed wide-ranging Congressional sanctions against Iran, North Korea and Russia last week. Known as the Countering America’s Adversaries Through Sanctions Act, the law’s Iran section requires the president to extend a terrorism designation pursuant to Executive Order (E.O.) 13224 to Iran’s Islamic Revolutionary Guard Corps (IRGC) and its foreign agents and affiliates by Oct. 30.

The milestone marks the first instance the US will designate the military branch of a foreign country for terrorism.

The law’s Sec. 105 (3) states, “The IRGC, not just the IRGC-QF [the Qods Force, the Guard’s extraterritorial branch], is responsible for implementing Iran’s international program of destabilizing activities, support for acts of international terrorism, and ballistic missile program.”

E.O. 13224 is an authority aimed at freezing the assets of terrorists and their supporters, while isolating them from the US financial and commercial systems, according to Treasury.

In 2007, the US designated the Qods Force for terrorism pursuant to the same order.

As a consequence of the latest law, the US will apply the terrorism designation to the IRGC in its entirety, which would include its Ground Forces, Aerospace Forces, Navy and the Basij paramilitary. The Revolutionary Guard, which is a conscript army, is estimated to have 150,000 active duty members. Estimates for the all-volunteer Basij vary widely: Iranian officials claim as high as 11 million, but a 2007 study by a Western think tank estimated the Basij at 90,000 active members, 300,000 reservists and 1 million who could be mobilized. A 2015 study by scholar Saeed Golkar argues the Basij has 200,000 special, 1 million active and at least 4 million total members.

Guard-owned companies would be eligible for designation as supporters of terrorism. The Revolutionary Guard has deeply penetrated key sectors of the Iranian economy, drawing on these resources to generate funds and support its military and civilian programs. For instance, a front company for the Qods Force, the Headquarters for the Restoration of Holy Shrines, raises funds and develops shrines in Iraq to project soft war and act as a pipeline for the force’s operations. Hundreds of companies, including major corporations traded on the Tehran Stock Exchange, are controlled by Revolutionary Guard foundations and a network of current and former Guardsmen.

Companies and foundations owned by the supreme leader that fund the Revolutionary Guard’s proxies would also be eligible for designation. According to Western intelligence reports, the supreme leader’s foundations provide financial support to Lebanese Hezbollah, which the US has classified as a terrorist group. Abdallah Safieddine, Hezbollah’s representative in Iran, told a reporter in 2012 that his organization receives funding directly from the supreme leader and his conglomerate.

The latest American law appears to require the president to designate the Guard’s external network, as well. Per Sec. 105 (3) (b), the administration must designate “foreign persons” that are “agents” or “affiliates” of the corps. US law defines “agent of a foreign power” as a person who “acts for or on behalf of a foreign power,” which meets the definition for Tehran’s proxies that do its bidding.

Shiite-jihadist groups constitute the overwhelming majority of the Revolutionary Guard’s foreign legion. A number of these militias, such as Lebanese Hezbollah, the Iraqi Hezbollah Brigades and more recently the Bahraini Ashtar Brigades, have already been designated for terrorism. But there at least 40 militias that are not. Many are Iraqi-based groups, and include Afghans, Pakistanis, and Syrians. The numbers are in the tens of thousands. The IRGC is estimated to have trained, funded or armed 65,000 Iraqis, according to a scholar who spoke with Buzz Feed. Director of National Intelligence Dan Coats recently estimated that Iran “manages as many as” 10,000 Afghans, Pakistani and Iraqis in Syria to support Syrian president Bashar al Assad.

Revolutionary Guard commanders have threatened US bases in the Middle East should the US execute the terrorism designation. Chief commander Major General Mohammad-Ali Jafari warned late last month that the US “has to close down all its bases within 1,000 kilometers of Iran and it should realize that it will pay a high price for its miscalculation.” The Armed Forces General Staff chief Major General Mohammad Bagheri said the designation would pose “major risks” to US bases and troops in the region.

“Do they think that the region would remain safe for them when they call our people, corps, and government terrorists?” declared the chief of the Basij Organization, Brigadier General Qolam-Hossein Qeibparvar.

The Guard has attempted to frame this sanction as an action to harm the Iranian people in order to shape the narrative and bolster support.

The Revolutionary Guard’s threat to US bases is real, but these public statements should be taken with a grain of salt. The Guard Corps may attempt to expand its asymmetric strategy while falling below the threshold of a direct attack. During the wars of Iraq and Afghanistan, the Revolutionary Guard provided material assistance to militants targeting American soldiers. In Iraq, it directly oversaw attacks. It continues to harass the US Navy in the Persian Gulf on a frequent basis. Between May and June, Guard-led militants and Iranian drones challenged a US deconfliction zone near Tanf, Syria, triggering American strikes. Revolutionary Guard commanders, however, have a long record of issuing exaggerated statements to project an image of strength and to deter. Given the immense disparity in conventional capabilities with the US, the Guard prefers to avoid direct military confrontation, which would surely ensue following an attack on US forces.

In the latest law, Congress affirmed the Revolutionary Guard’s proliferation designation pursuant to E.O. 13382 and took an additional step to declare Iran’s missile program an “unusual and extraordinary threat” pursuant to the International Emergency Economic Powers Act. The Revolutionary Guard’s Aerospace Force is in charge of Iran’s strategic missile force. Congress is expressing its concern about the long-term, potential trajectory of the missile program and advancements in intercontinental-ballistic-missile (ICBM) capability. The US administration is furthermore required to provide assessments of Iran’s chemical and biological weapons capabilities.

Last week’s law also requires the secretaries of State, Defense and Treasury and the Director of National Intelligence to jointly develop and submit to Congress within six months a strategy for deterring Iran’s conventional and asymmetric activities that threaten the US and its allies. The administration is to incorporate a coalition of US allies in this effort.

For the first time, the law has directed the administration to include the Treasury Secretary in the National Security Council.

The president is required to designate any entities that sell heavy weaponry and provide a range of arms assistance to Iran. As a UN arms ban expires on Iran in 2020, Congress is seeking to deter the sales of such weapons to Iran. Congress grants the president the authority to waive this if and when he/she determines that Tehran no longer supports terrorism or presents a threat to the US.

*To be clear, Congress grants the president authority to waive the IRGC terrorism sanctions if he gives a detailed rationale for why the waiver is in the vital national security interest of the United States. The author believes that since the IRGC continues its activities that meet the definition of terrorism, and the president has signaled a more muscular approach toward Iran, he will levy sanctions on the Guard Corps under anti-terrorism authorities.

Update: the article’s earlier version stated the US must designate the IRGC by Nov. 1, while the deadline is Oct. 30.

Amir Toumaj is a independent analyst and contributor to FDD's Long War Journal.

Are you a dedicated reader of FDD's Long War Journal? Has our research benefitted you or your team over the years? Support our independent reporting and analysis today by considering a one-time or monthly donation. Thanks for reading! You can make a tax-deductible donation here.