# What the Closing IRGC Sanctions Loopholes Act Does

This bill tightens economic penalties against Iran's Revolutionary Guard Corps (IRGC), which is a military organization that the U.S. government considers a threat to national security. Right now, the U.S. already has sanctions in place against the IRGC, but this bill closes what lawmakers see as gaps that allow people and companies to work around those penalties.

The main change is that the bill expands who can be sanctioned. Currently, sanctions target direct officials and agents of the IRGC. This bill adds companies and organizations that are owned or controlled by the IRGC—even if they don't directly appear to be military entities. It also targets people who try to help the IRGC conduct sensitive financial transactions or activities, even if they're not officially part of the organization. The bill lowers the financial threshold for what counts as a suspicious transaction from $1 million to $500,000, meaning smaller deals now trigger investigation. It also adds new categories of prohibited activities, including transactions that support terrorist organizations, the Syrian government, or Iranian financial institutions.

For most Americans, this bill won't have a direct impact on daily life. However, it could affect U.S. companies and individuals doing international business, particularly those with connections to Iran or the Middle East. Any American business involved in financial transactions with Iran or entities connected to the IRGC could face serious penalties, including fines and criminal charges. The bill also requires the government to review and update its sanctions list every six months instead of every 90 days, making the enforcement more systematic. These changes are set to expire at the end of 2025 unless Congress extends them.

Closing IRGC Sanctions Loopholes Act

Lamborn, Doug

Closing IRGC Sanctions Loopholes Act This bill expands sanctions on those associated with Iran's Revolutionary Guard Corps (IRGC). Current law requires the President to identify foreign persons (individuals and entities) that are officials, agents, or affiliates of the IRGC and impose visa- and property-blocking sanctions on them. The bill expands this requirement to include identifying and sanctioning foreign persons that are owned or controlled by the IRGC. The President must also identify foreign persons attempting to conduct sensitive transactions or activities on behalf of such IRGC-associated persons. The bill expands the definition of sensitive transactions or activities, which are used to identify persons potentially subject to sanctions, to include transactions providing support for an act of international terrorism or providing material support to (1) a foreign terrorist organization, (2) a foreign person sanctioned under<A href="https://www.federalregister.gov/documents/2001/09/25/01-24205/blocking-property-and-prohibiting-transactions-with-persons-who-commit-threaten-to-commit-or-support"> Executive Order 13224</A> (related to sanctioning those who commit or support terrorism), or (3) the Syrian government or its agencies or instrumentalities. Additionally, the bill lowers the threshold for financial transactions involving non-Iranian financial institutions to qualify as a sensitive transaction from $1,000,000 to $500,000 per year and adds similar transactions involving Iranian financial institutions. The bill requires the President to investigate certain categories of foreign persons to determine if they are subject to these sanctions (versus prioritizing such investigations as under current law). The bill also adds foreign persons listed in specified attachments to U.N. Security Council Resolution 2231 (concerning Iran's nuclear program) as a new category the President must investigate to determine if there are any sanctionable relationships to the IRGC.