Mandatory Sanctions: New Law Forces Designation of IRGC-Linked Groups as Foreign Terrorist Organizations within 90 Days

The newly proposed Iranian Terror Prevention Act is a highly specific piece of legislation designed to mandate action against several foreign organizations. Simply put, this bill takes the decision out of the hands of the Secretary of State regarding certain groups and forces a designation, which then triggers a review for sanctions. Within 90 days of this bill becoming law, the Secretary of State must officially designate a list of specific groups—including the Abu Fadl al-Abbas Brigades and the Badr Organization—as Foreign Terrorist Organizations (FTOs).

The Mandatory FTO List and the IRGC Connection

This isn't the usual process where the State Department deliberates on FTO status; for the groups named in this bill, the designation is mandatory and immediate. Crucially, the bill also requires the FTO label to be applied to any foreign organization that acts as an agent for, is affiliated with, or is controlled by the Islamic Revolutionary Guard Corps (IRGC). The FTO designation is significant because it makes it illegal for anyone in the U.S. or subject to U.S. jurisdiction to knowingly provide material support or resources to these organizations. If you’re a business owner or a financial institution, this designation drastically expands the list of groups you must avoid transacting with, or face serious legal consequences.

The Sanctions Clock Starts Ticking

Once the FTO designation is made, the next step is sanctions. The bill sets a 60-day deadline for the President to decide on imposing sanctions on these newly designated FTOs and their affiliates, using the existing authority under Executive Order 13224. This order is the government’s go-to tool for freezing assets and blocking transactions related to terrorism. For individuals and businesses, this means the financial walls are going up fast. If your company deals internationally, especially in regions near these groups, you need to be hyper-aware of these designations to ensure you aren't accidentally or unknowingly doing business with an affiliate and running afoul of U.S. law.

Accountability Through Constant Reporting

One of the most robust parts of this bill is the mandatory reporting requirement, which gives Congress a heavy hand in oversight. The Secretary of State must report to Congress every 180 days on any new groups meeting the FTO criteria or any new foreign persons sanctioned. Furthermore, the President must report back to Congress within 60 days of the sanctions decision. If the President decides not to impose sanctions on any of the organizations listed in the bill, they must provide a detailed, written explanation to Congress as to why they made that choice. This mechanism ensures that the Executive Branch cannot easily sidestep the intent of the law and provides clear accountability for every sanction decision (or lack thereof).