The Revolutionary Guard designation, planning for which was first reported by The Wall Street Journal, comes with sanctions, including freezes on assets the Guard may have in U.S. jurisdictions and a ban on Americans doing business with it or providing material support for its activities.
Although the Guard has broad control and influence over the Iranian economy, such penalties from the U.S. may have limited impact. The designation, however, could significantly complicate U.S. military and diplomatic work, notably in Iraq, where many Shiite militias and Iraqi political parties have close ties to the Guard. And in Lebanon, where the Guard has close ties to Hezbollah, which is part of the Lebanese government.
Without exclusions or waivers to the designation, U.S. troops and diplomats could be barred from contact with Iraqi or Lebanese authorities who interact with Guard officials or surrogates.
The Pentagon and U.S. intelligence agencies have raised concerns about the impact of the designation if the move does not allow contact with foreign officials who may have met with or communicated with Guard personnel. Those concerns have in part dissuaded previous administrations from taking the step, which has been considered for more than a decade.
No evidence has surfaced showing that Donald Trump, or any of his employees involved in the Baku deal, actively participated in bribery, money laundering, or other illegal behavior. But the Trump Organization may have broken the law in its work with the Mammadov family. The Foreign Corrupt Practices Act, passed in 1977, forbade American companies from participating in a scheme to reward a foreign government official in exchange for material benefit or preferential treatment. The law even made it a crime for an American company to unknowingly benefit from a partner’s corruption if it could have discovered illicit activity but avoided doing so. This closed what was known as the “head in the sand” loophole.