Ban The Islamic Revolutionary Guard Corps (IRGC)

Download the complete briefing memo here:

Listing the IRGC: FAQs

1. Is there a Canadian precedent for listing an entity like the IRGC which is ostensibly a state agency of a foreign country?

a.  Policy Precedent – As noted later in FAQ #5, there is no legal obstacle in the Criminal Code to defining the IRGC as an “entity” for the purposes of listing. Furthermore, the IRGC is not a normative state or military entity. It is a sui generis entity not really comparable to other state structures. (see Appendix). But however one might categorize the IRGC, current Canadian policy on Iran and that of the previous government, have already laid the policy groundwork for an IRGC listing. 

Iran’s status under Canadian law is unique and is shared only with Syria. Both countries are currently listed in Canada as a “State Supporters of Terrorism” under the Justice for Victims of Terrorism Act (JVTA). This listing, recently reviewed and reconfirmed by the Foreign Minister, lifts their state immunity.[i] This in turn allows these countries to be sued by terror victims in Canada, for supporting terrorism. (Victims in fact have successfully sued Iran and the IRGC in Canadian courts for several billion dollars under the JVTA. See Appendix.) If Canadian law enables the government of Iran and its agencies to be successfully sued for terrorism, it is hardly a radical departure from a policy perspective for those same agencies which the courts found legally liable for terrorism to now be listed as terrorist entities. In lifting this veil of state immunity, Canada has already placed Iran and the IRGC in a special category, now recognized as a matter of judicial findings of fact and conclusions of law, already quite different from virtually all other state entities.   

b.  Legal Precedent – The proposition that a state agency could be defined as a “terrorist organization” for certain legal purposes has precedent in Canadian jurisprudence, as demonstrated in the case of Mansour Ahani. 

Mr Ahani was an Iranian national who acquired refugee status in Canada in 1991. CSIS was of the opinion that Ahani was an assassin working for the Iranian Ministry of Intelligence and Security (MOIS). Ahani later met with CSIS agents after a trip to Europe and allegedly admitted that he had met with a former MOIS associate. In June 1993, Canada issued a certificate declaring Ahani to be inadmissible both as a member of a terrorist organization and as one who there are reasonable grounds to believe has engaged or will engage in acts of terrorism or violence that “would or might endanger the lives or safety of persons in Canada.”[ii] In other words, the Canadian government deemed a state agency – in this case MOIS – to be a terrorist organization, and the Supreme Court of Canada upheld that decision.[iii]

Yes. Listing the IRGC in its entirety is broadly consistent with: the publicly stated foreign policy and human rights objectives of the current government and the official opposition; the existing sanctions regimes of both the current Liberal government and its Conservative predecessor; the policies of both the current government and its predecessor in listing other terrorist entities; and with the recent findings of the Canadian courts. 

The collective import of these factors establishes that the IRGC as a whole, is a legitimate and recognized target of sanctions within Canadian policy. As such, the proposed IRGC listing is hardly a radical departure from exiting policy. In fact, it is the failure to do so that seems to be a glaring inconstancy either political in nature and/or a function of bureaucratic reticence, rather than principled and practical policy making. The proposed listing should therefore be considered in the following context: 

a. Publicly Stated Commitments of the Liberal Government – The current government has committed as a matter of policy, to “hold Iran to account for human rights violations and to implement a robust sanctions regime.”[iv] Most recently PM Trudeau and the vast majority of Liberal Ministers and MPs supported the passage of a Conservative motion on June 12, 2018, calling on the government to “immediately designate” the IRGC “as a listed entity under the Criminal Code of Canada”.[v]

b. The Iranian Regime as a Whole is Already Listed by Canada – Iran is widely acknowledged as the globe’s preeminent state sponsor of terrorism and was listed as a “State Supporter of Terrorism” under the Justice for Victims of Terrorism Act (JVTA). The bill was passed by the Harper government in 2012 and supported by the Hon. Irwin Cotler former, former Liberal MP and Minister of Justice. The law requires the Minister of Foreign Affairs to review the list of State Supporters of Terrorism every two years to determine “if there are still reasonable grounds for the foreign state set out on the list to remain set out on the list”. The first listing of Iran and Syria under the JVTA was in 2012 under the Conservative government.  Another review was conducted by the current Liberal government, and on July 1, 2017 the Canada Gazette reported that the Foreign Minister had determined that Canada would continue listing Iran and Syria as a “State Supporters of Terrorism”.[vi]

c. Existing Canadian Sanctions on the IRGC – Canada has already imposed limited sanctions on various IRGC branches and individuals under the Special Economic Measures Act (SEMA) and has banned the IRGC’s Quds Force (QF) as a terrorist entity under the provisions of the Criminal Code. 

d. Canadian Courts and the IRGC – Terror victims sued Iran under the JVTA, and in 2018 won a multi-billion-dollar judgment against the Iranian regime and the IRGC.  The court gave its approbation to the intent and method of the JVTA and to the use of civil litigation against terrorism. It also confirmed the culpability of Iran and the IRGC for terror sponsorship as a matter of judicial findings of fact and conclusions of law. American courts have also found the IRGC in its entirety to be liable for multiple acts of terrorism. (See Appendix)

e Canada, Venezuela, and the IRGC – Canada has taken a strong frontline position in the international coalition of countries opposing Venezuelan dictator Nicolas Maduro. But the IRGC and Hezbollah are intervening to undermine this effort. Iran and its terrorist proxies became entrenched in Venezuela under the rule of Venezuela’s previous President Hugo Chavez, although a strong Hezbollah support network has existed in Venezuela since the 1990’s. But under Maduro this relationship has only deepened. The cooperation between the Iranian and Venezuelan regimes is extensive:

  • “Iran is playing a far larger role in designing Venezuela’s security structure than is commonly known,” says James Humire, a Washington-based policy analyst who lectures on Latin America.[vii] Adm. Craig S. Faller, Commander of U.S. Southern Command, testified similarly before the Senate Armed Services Committee in February 2019 explaining that “Iran has … exported its state support for terrorism into our hemisphere.”[viii]
  • At a recent U.S. Congressional hearing, Humire presented a list of over 2,000 Venezuelan passports issued to suspected members of Hezbollah, Hamas and other Iranian-supported Islamist group.[x]
  • Maduro’s industry minister and former vice president Tareck El Aissami, a close confidant of Maduro, is under U.S. indictment for funding Hezbollah with proceeds from a Venezuela-based drug trafficking ring. According to a report in the New York Times,[xi] Aissami has played a critical role in embedding Hezbollah in Venezuela. “Maduro is relying on El Aissami to tighten the regime’s grip on power. As it turns out, that is in no small part thanks to his Iran and 
  • Hezbollah connections…. For Iran and Hezbollah, Bolivarian continuity in Venezuela is crucial to their ongoing Latin American operations, of which Caracas is a springboard to the rest of the region. For Maduro, Tehran represents a key security guarantee for his regime’s survival.”[xii]
  • In 2017 “Brig. Gen. Mohammad-Reza Naqdi, the new cultural adviser to the Iran Revolutionary Guard Corps (IRGC) chief commander and a former chief of the IRGC’s Basij militia, announced that a Latin American team visited Iran to learn how to form a Basij-like mobilization force, praising “Iran’s perseverance and success.” Naqdi did not disclose further details about where this delegation came from, but Venezuela is a likely candidate.”[xiii]
  • Margarita Island off the Caribbean coast of Venezuela serves as a hub for drug trafficking and Hezbollah as well as other Islamist extremists such as Hamas.[xiv]

Given the import of the IRGC’s support for the Maduro regime, Canada’s failure to act against the IRGC will only further enable and empower the IRGC’s efforts in Venezuela to crush the Venezuelan opposition. It will only further facilitate the Iran-Venezuela axis with significant implications for Canada’s human rights and counterterrorism policies, and for the security of entire western hemisphere.

3. But if Canada has already sanctioned the IRGC’s Quds Force (QF), is it still necessary to list the IRGC in its entirety? 

Listing the IRGC’s Quds Force as a terrorist entity while refraining from listing the IRGC in its entirety, is not consistent with Canadian policy on Iran, the IRGC and terror financing, nor is it reflective of or justified by, the structural or operational realities of the IRGC.  Furthermore, listing the IRGC’s QF which facilitates Iran’s terrorist foreign policies abroad, without targeting the IRGC’s vast economic, educational and political infrastructure that supports and underpins the QF itself, greatly diminishes the import and impact of the QF listing and legitimizes the IRGC’s overt support of QF terrorism. Consider the following points regarding the IRGC’s support of terrorism: 

a. The IRGC and the IRGC-QF are an Integrated Whole 

The IGRC, while comprised of multiple departments, is an integrated single entity with a defined independent command structure largely autonomous from other government agencies, committed to a very specific constitutional mandate distinct from that of the regular armed forces of Iran known as the Artesh. (see Appendix)

  • The QF is not a separate body from the IRGC and ahs never claimed to be so. It is a specialized arm of that entity. The QF recruits its manpower from the broader ranks of the IRGC[xv] and as witnessed in the Syrian civil war, QF and IRGC units operate in tandem, with personnel “routinely rotating back and forth within one command structure”.
  • Some experts have surmised that there is in fact little real difference between members of the QF Staff and the Guard Corps General Staff. The commanders of the Intelligence, Operations, and Training directorates, for instance, are among the QF’s key commanders.[xvi] Furthermore, the QF functions through and within the broader and expansive rubric of the IRGC’s relationship and integration with other state institutions.[xvii] In particular, the QF’s works closely with IRGC’s intelligence branch,[xviii]which also operates abroad.[xix]

b. The IRGC in its entirety has supported and directly committed acts considered “terrorist activities” under Canadian law 

Even if one were to accept the spurious argument that the QF is somehow a separate entity, structurally, operationally and financially distinct from the IRGC as a whole, the IRGC’s broader activities irrespective of the QF, still constitute terrorist activity under the law:

  • The IRGC and Terror Finance – Aside from the billions of dollars allocated annually by Iran to the IRGC, the Guards generate billions of dollars in revenue through a vast independent empire of legal and black-market industries including narcotics smuggling[xx], and they control nearly 40% of Iran’s economy. According to Iran expert to Saeed Ghasseminejad “The IRGC is the main player in Iran’s underground economy, which is a valuable source of income for the Guards. This income provides the Guards with financial independence from Iran’s civil politicians.”[xxi] The QF plays only a small role in this business empire used to fund the terrorist activities of the QF and the IRGC as a whole. Former U.S. Senator Jon Kyl was therefore absolutely correct in stating that it is an error to list the QF and the IRGC in its entirety as a terrorist entity: “[It is] like saying the Mafia isn’t really responsible for what the Mafia does; it is only their hit men. The QF is the group of hit men for this entity. This entity is clearly the overall entity responsible for this action, and it is the entity that engages in the economic activity which supplies the financial resources to the Quds Force.[xxii]
  • Precedents in Canadian Law – Canada has rightly banned terror groups like Hezbollah and Hamas in their entirety. Canadian lawmakers from both sides of the isle have wisely rejected the argument that the political wings of these groups are not inherently part of the structural continuity of these terrorist entities. Recently the UK, followed suit. London which had banned only the military wing of Hezbollah, changed its position and banned Hezbollah in entirety, recognizing that these terrorist entities are an integrated whole committed to a mandate of terrorist ideology and activity. The IRGC is no different in this respect. The IRGC in its entirety, is ideologically committed to establishing Iran as a regional and global power through subversion and terror. Its atrocities have rivaled or exceeded the exploits of most, if not all, of the terrorist organizations presently listed by Canada. Refusing to list the IRGC in its entirety therefore is to legitimize and enable the terrorism committed by the IRGC or any of its agencies or proxies. 

c. The IRGC’s broader involvement in terror well predates the founding of the QF in 1990. A few examples are listed below: 

  1. In 1979 the IRGC massacred in the Kurdish village of Naqada killing more than 900 people mostly women and children.[xxiii]
  • In 1980, the IRGC was put in charge of foreign terrorist operations by the Ayatollah Khomeini when the “department for Liberation Movements” was placed under IRGC tutelage;[xxiv]
  • In the 1980s the IRGC orchestrated the kidnappings of Western hostages in Lebanon (and according to former CIA agent and TIME correspondent Robert Baer, kidnapped U.S. citizens were actually held at IRGC’s Shaykh Barracks in the Baalbek);[xxv]
  • the 1983 Hezbollah (created and funded by the IRGC) bombed the U.S. embassy in Beirut in 1983 killing 23 and injuring 21; [xxvi]
  • the 1984 Hezbollah hijacking of Kuwait Airlines flight 221 killing 2 passengers;[xxvii]
  • 15 separate bombings in Paris in 1985-86;[xxviii]
  • the 1985 Hezbollah hijacking of TWA flight 847 in 1985 murdering 1 passenger;[xxix]
  • the 1988 Hezbollah hijacking of Kuwait Airlines flight 422;[xxx]
  • Evidence has also emerged over the last years that strengthens connections between the IRGC and the 1988 bombing of Pan Am flight 103, which killed all 270 passengers.[xxxi]
  • Even in the aftermath of the establishment of the QF in 1990, non-Quds IRGC leaders have continued to be involved in terrorism including IRGC official Maj.-General Mohsen Rezai. He is sought by Argentina in connection to the 1994 attack on the AMIA Jewish community centre which killed 85 people and injured 300.[xxxii]

4. Has the IRGC injured Canadians? 

Yes. Canada is host to victims of IRGC aggression and violence. Some are members of Iranian ex-pat community now living in Canada, while others have suffered arrest, imprisonment, torture or death at the hands of the IRGC and its terrorist proxies.   

5.  How would the IRGC become a listed terrorist entity under the Criminal Code?

Section 83.05 of the Criminal Code empowers the Governor in Council (i.e. the Cabinet) to create by regulation a list of entities that are to be considered terrorist groups. The Criminal Code makes it a criminal offense to have financial dealings with those entities, as well as to participate in, contribute to, facilitate and enhance their terrorist activities.

Section 83.05 provides that an entity can be listed when there are “reasonable grounds to believe that”:

(a) the entity has knowingly carried out, attempted to carry out, participated in or facilitated a terrorist activity; or

(b) the entity is knowingly acting on behalf of, at the direction of, or in association with an entity referred to in paragraph (a)

The criminal and/or security intelligence reports are submitted to the Minister of Public Safety for consideration. If the Minister “has reasonable grounds to believe” that the above test is met, the Minister can make a recommendation to the Governor in Council to place 

the entity on the list. If in turn the Governor in Council is satisfied that there are reasonable grounds to believe that the above test has been met, the entity may be placed on the list.

6. What standard of proof is required to list a terrorist entity?

The Minister of Public Safety and the Governor in Council must have reasonable grounds to believe that the entity has carried out, attempted to carry out, participated in or facilitated a terrorist activity, or is knowingly acting on behalf of, at the direction of, or in association with such an entity. “The standard of ‘reasonable grounds to believe’ is greater than reasonable suspicion but less than on a balance of probabilities when the totality of the circumstances are considered.”[xxxiii]  

Being listed places such an entity within the Criminal Code definition of a “terrorist group”, which is defined in section 83.01(1) as:

(a) an entity that has one of its purposes or activities facilitating or carrying out any terrorist activity, or

(b) a listed entity and includes an association of such entities.

The legal consequences of being listed include:

  • The entity’s property can be the subject of seizure, restraint and/or forfeiture.
  • Institutions such as banks, credit societies, trust companies and loan companies are subject to reporting requirements with respect to an entity’s property and must ensure they are not in possession or control of property owned or controlled by or on behalf of a listed entity.
  • It becomes illegal to knowingly participate in or contribute to any activity of the listed entity for the purpose of enhancing its ability to facilitate or carry out a terrorist activity.
  • It becomes illegal for a person to knowingly instruct another person to carry out any activity for a listed entity for the purpose of enhancing the ability of the listed entity to carry out a terrorist activity.
  • The Criminal Code also prohibits anyone from providing, collecting or making available property or other financial services, intending or knowing that it will be 

used to carry out terrorist activity or to benefit a terrorist group (which includes a listed entity).

  • The legal consensus for listing under the Criminal Code provisions are more severe than listing under SEMA (Special Economic Measures Act). A breach of the Criminal Code provisions, for instance, can lead to a fine of up to $100,000 and imprisonment for up to 10 years, compared to a fine of up to $25,000 and imprisonment for up to five years for a breach of SEMA sanctions.

8. Should the IRGC be considered an “entity” for the purposes of listing under the Criminal Code?

Yes. Section 83.01(1) of the Criminal Code defines “entity” as “a person, group, trust, partnership or fund or an unincorporated association or organization.” In other words, “entity” is a broadly inclusive term that should be understood to cover anything from a single individual to a broad array of structures or groupings. This definition may therefore include virtually anyone or any type of grouping that engages in or supports acts of terror that the Criminal Code seeks to prevent and deter.

The IRGC is such a group, which includes within it a variety of structures such as: military units, financial structures, paramilitary and unofficial policing and enforcement entities (used to suppress dissent), cultural associations, multi-billion dollar “charitable” bodies (called “bonyards”) that might be considered similar to trusts, and criminal organizations involved in transnational crime.

Given the apparent intent of Part II.1 of the Criminal Code to prevent acts of terrorism – in part by proscribing financial relationships with those who engage in acts of terror – the law should not allow Canadians to enable terrorist activity through financial dealings with the IRGC either as a “group” or with its personnel as individuals, or with any of its affiliated structures or businesses.



[ii] Ahani v.Canada (Minister of Citizenship and Immigration), 2002 SCC 2, [2002] 1 S.C.R. 72.












[xiv] 209 “Venezuelan Ties to Hezbollah”, ICT database Staff, IDC Herzliya – ICT (International Institute for Counter-

Terrorism), August 14, 2008,;;

[xv] Buchta, P. 164; see also the Iran Terror Database,; and Abbas Milani, director of Iranian studies at Stanford University, quoted in “Iranian Force, Focus of U.S., Still a Mystery”, by Scott Shane, New York Times, February 17, 2007.

[xvi] Iran Terror Database,

[xvii] “Iran’s Revolutionary Guards, the Al Quds Force, and Other Intelligence and Paramilitary Forces”, Rough Working Draft, P. 7, by Anthony H. Cordesman, Center for Strategic and International Studies, August 16, 2007: “ It has often difficult to separate the activities of the IRGC, the Vezarat-e-Etellea’at va Amniat-e Keshvar and the Foreign Ministry and many seem to be integrated operations managed by a ministerial committee called the Special Operations Council.

[xviii] Ibid p.14

[xix] PolicyWatch #1273, “Iran’s Revolutionary Guards Corps, Inc.”, by Mehdi Khalaji, Washington Institute for Near east

Policy, August 17, 2007.


Iran’s interior minister recently declared that the value of narcotic drug sales in Iran is $3 billion per year, not including commission from transporting the drugs from Afghanistan to other transit points, like the Balkans. The US Department of the Treasury has placed Quds Force Commander Esmail Baghbani on the US sanctions list for his role in drug trafficking. The IRGC also has close ties with the drug cartels in the South and Central America through Hezbollah.



[xxiii] Amir Taheri, The Persian Night, (New York 2003), P. 96

[xxiv] Anderson, Sean K., “Iranian State-Sponsored Terrorism”, Conflict Quarterly, Vol. IX, No.4, Fall 1991: “Not long after the 1979 revolution a department for liberation movements had been set up in the Foreign Ministry. At that time the Islamic fundamentalists perceived the Foreign Minister Sadeq Qutbzadeh as being outside of the Imam’s “Line” and not trustworthy. The 1980 Liberation Movements Conference was the occasion used by the fundamentalists to change the jurisdiction of the department for liberation movements from the Foreign Ministry to the Islamic Revolutionary Guard Corps, a context in which they could pursue their own version of exporting the revolution while side-stepping the detested Qutbzadeh. The eventual creation of the “Department [for support] of Liberation Movements,” by decree of the Imam following this Conference, created one command structure for 

conducting terrorist operations. This office began sending IRGC units to Lebanon in June 1981.”; see Arjomand P. 134-135: “…the radical Foreign Minister Mir Hossein Musavi, set up a committee ‘to determine the basis of a foreign policy from an ideological perspective’ and drew up a ‘plan an Islamic front worldwide.An Islamic Revolutionary Council was established as an umbrella organization covering the Supreme Council of the Islamic

Revolution in Iraq (SCIRI), the Islamic Revolution Movement of the Arabian Peninsula, the Islamic Front for the Liberation of Bahrain… all linked to the Islamic liberation movement unit of the Revolutionary Guards.”

[xxv] Baer, Robert, See No Evil, Crown, New York (2002), P. 81 quoted in Wikipedia, “Army of the Guardians of the Islamic Revolution”,

[xxvi] Sisso v. Islamic Republic of Iran, 2007 U.S. Dist. LEXIS 48526 (D.D.C. July 5, 2007).

The bombing was the first large-scale attack against a U.S. Embassy anywhere in the world. See Ex. 19 (Oakley Dep. Tr.) at 22; see also Tr. Vol. I at 121-22; Ex. 35 at 13. At the time, it was not immediately clear who was responsible for the bombing. See, e.g., Tr. Vol. II at 27-28; Tr. Vol. I at 121. But by 1984, the U.S. State Department, in its annual publication “Patterns of Global Terrorism: 1983,” noted that “radical Lebanese Shi’a using the nom-de-guerre Islamic Jihad” and “operating with Iranian support and encouragement” were “responsible for the suicide attacks against the U.S. Embassy.” See Ex. 20 at 11 (also at Oakley Dep. Ex. 1); Ex. 22 (discussing Islamic Jihad terrorist activities, including, inter alia, the 1983 Beirut Embassy bombing, as “part of a major terrorist campaign aimed at the elimination of U.S. and western influence in Lebanon.”); Oakley Dep. Tr. at 23-25. The terrorist group Islamic Jihad has been known by various names, including Right Against Wrong, the Revolutionary Justice Organization, and, perhaps most commonly, [*272] Hizbollah. n4 See Ex. 19 (Oakley Depo. Tr.) at 46; see also Oakley Dep. Ex. 10 (also at Ex. 29) at 304. In connection [**6] with the evidentiary

hearing in this matter, Ambassador Robert Oakley — who, as the coordinator of the State Department’s counterterrorism efforts, was tasked with assessing who was behind the 1983 Beirut Embassy bombing, see Ex. 19 (Oakley Dep. Tr.) at 9 — testifie d that it ultimately became “very clear that Islamic Jihad [Hizbollah] was behind the bombing in 1983.” Id. at 21. Ambassador Oakley further expressed “confidence that the government of Iran was involved directly in the Hisballah organization, which was created, armed, trained, protected, provided technical assistance by the Iranian Revolutionary Guards.” Id. at 21.





[xxxi] Gold, Dore, The Rise of Nuclear Iran, quoting a recently reclassified document from the Defense Intelligence Agency (DIA implicating Ali Akbar Mohtashemi, the former Iranian Ambassador to Syria, a founder of Hizbullah and one of those responsible for the bombing of the US embassy in Beirut by IRGC directed terrorists) See IRGC Threat: New ‘Punch’ Same As The Old ‘Punch’, by Steve Schippert | August 20, 2007, regarding Mohtashemi as an IRGC operative,; see also London Sunday Times, August18, , 2009, quoting former CIA agent Robert Baer; see also “Hoover Scholar, Attorney Defends Representing Libya”, by Shawn Cohen, Washington Jewish Week, December 22, 1995; also see “The Lockerbie Bombing, Syria, Iran Palestinians, Confession of an Iranian Terror Czar”, by Dr. Ludwig de Braeckeleer, January 12, 2008,; regarding Iran’s support of Jibril’ s PFLP-GC suspected of involvement in the bombing see former FBI Director Louis Freeh: “Before his appointment as the top U.S. administrator in Iraq, L. Paul Bremer chaired the National Commission on Terrorism, which studied the Khobar attack. The commission concluded that “Iran remains the most active state supporter of terrorism. . . . The IRGC and MOIS have continued to be involved in the planning and execution of terrorist acts. They also provide funding, 

training, weapons, logistical resources, and guidance to a variety of terrorist groups, including Hezbollah, Hamas, PIJ, and PFLP-GC.” Quoted in “Remember Khobar Towers”, by Louis Freeh, Wall Street Journal, May 20, 2003,



PREVIOUS What is the IRGC? NEXT Bipartisan Support