

The new U.S. sanctions on the IRGC’s missile production are a prudent move, but not nearly enough.
E arlier today, the Biden administration issued sanctions on the Islamic Revolutionary Guard Corps’s ballistic-missile production. The Treasury Department’s Office of Foreign Assets Control issued a statement saying it had sanctioned “an Iran-based procurement agent and his network of companies that procured ballistic missile propellant-related materials” for the IRGC. The move is one of the Biden administration’s first signs of resistance to the Islamic Republic’s destabilizing behavior after a slew of capitulatory concessions throughout the ongoing nuclear negotiations.
The Treasury’s new sanctions target “Iranian procurement agent” Mohammad Ali Hoseini and the companies that supplied him with ballistic-missile inputs. The sanctions have been issued under Executive Order (E.O.) 13382, which “blocks the property of specially designated WMD proliferators and members of their support networks.”
Behnam Ben Taleblu, a senior fellow at the Foundation for Defense of Democracies, believes the administration should build on this move, telling National Review that the White House “should take note of where Iran likes to go shopping for solid-propellant motor technology and step up the rate of sanctions enforcement.” “Iran is making steady leaps in solid-propellant technology, both for missiles and its satellite program,” Taleblu said.
Michael Rubin, a senior fellow at the American Enterprise Institute, told National Review that the sanctions are a step in the right direction, but a small one: “There is a danger in narrowly sanctioning entities belonging to the Islamic Revolutionary Guard Corps. . . . The Guards own so many businesses, they can simply play anti-sanctions three-card monte by shifting operations and titles around faster than the U.S. can sanction.”
The Treasury statement says the sanctions were in response to the IRGC’s most recent episodes of regional destabilization, including the ballistic-missile attack in Erbil and its continued support of Houthi missile strikes:
Today’s action follows Iran’s missile attack on Erbil, Iraq on March 13 and the Iranian enabled Houthi missile attack against a Saudi Aramco facility on March 25 as well as other missile attacks by Iranian proxies against Saudi Arabia and the United Arab Emirates and are a reminder that Iran’s development and proliferation of ballistic missiles continues to pose a serious threat to international security.
The twelve ballistic missiles in Erbil struck next to a new U.S. consulate, though the Biden administration denied that the U.S. was a target. The administration defended its continued nuclear negotiations with Iran. U.S. deputy secretary of state Wendy Sherman said that preventing a nuclear Iran would allow the U.S. to better address Iran’s other “malign behavior in the Middle East.”
As for the Houthi strikes, the UAE and Saudi Arabia are disappointed with the Biden administration’s hands-off approach to Iran’s support for the Yemeni rebel group. When Biden asked the Saudis and Emirates to increase their oil production amid rising fuel prices, both turned down his calls in protest.
In February 2021, the Biden administration removed the Houthis — who control 80 percent of Yemen’s territory — from the terrorist list to ease Yemen’s humanitarian crisis. The administration also withdrew its support for Saudi Arabia’s offensive operations against the Houthis. The Houthis have frequently carried out Iranian-backed attacks on Saudi targets and have started to strike at the UAE. Their most recent strike was on a Saudi Aramco fuel depot last week. As a part of the Iran nuclear negotiations, the Biden administration is considering lifting the IRGC’s designation as a “foreign terrorist organization” despite the IRGC’s funding and arming of groups such as the Houthis.
So while these new sanctions are a prudent move by the Biden administration, they are nowhere near enough to discourage Iran’s regional destabilization, especially if the new Iran deal goes through.
Desperate for a return to a nuclear deal, the Biden administration is ready to grant the Islamic Republic a long list of concessions, including lifting terrorism sanctions and delisting the IRGC as a terrorist organization. The White House has also shamelessly overlooked Iran’s malign behavior throughout the duration of the Vienna negotiations. Over the past year, Iran has engaged in sanctions violations, exceeded its uranium-enrichment limits, continued to fund its proxies, and evaded International Atomic Energy Agency inspections.
Biden’s nuclear deal would flood Iran with billions that would surely enrich its terroristic proxies, including Hezbollah and Hamas. Rubin posed an important question: “If the White House is serious about stopping this sort of sanctions-evasion scheme as well as deter future missile attacks, why then push a policy that resources the Revolutionary Guards and may even delist the Guards’s multibillion-dollar business network?”
Taleblu told National Review that the administration is moving in the right direction but could do more: “Exposing and punishing Iran’s missile-technology procurement nodes is the price floor, not price ceiling, of a broader and better policy on Iran.”
It’s a low bar. The impending Iran deal, should it pass, would lift major pressure off Iran’s ballistics program. Taleblu said U.S. sanctions are “a mere slap on the wrist” as negotiators push for a deal that “removes EU sanctions on Iran’s main missile and military actors and has a lapsing missile-testing prohibition as early as next year.” Under the 2015 Joint Comprehensive Plan of Action, Iran had to halt its ballistics program for eight years. Under the new agreement, that’s down to one year.
Unless the Biden administration is willing to hold the IRGC comprehensively accountable for regional activities, this new round of sanctions amounts to what Rubin described as “one step forward, four steps back.”