Sanctions

On April 8, the Trump administration designated the Islamic Revolutionary Guard Corps (IRGC) as a foreign terrorist organization (FTO) under Section 219 of the Immigration and Nationality Act. A few days earlier, the administration had made good on its threat to impose sanctions on officials of the International Criminal Court (ICC) involved in the examination of U.S. actions in Afghanistan and Israeli actions in other contexts. As part of this effort, it revoked the U.S. visa of Fatou Bensouda, the ICC’s chief prosecutor.

New movement may be afoot on a sanctions bill designed to deter Russian election interference. The bill, the Defending Elections from Threats by Establishing Redlines Act of 2018 (Deter Act), was introduced earlier this year by Sens. Marco Rubio (R.-Fla.) and Chris Van Hollen (D.-Md.).

Author’s Note: After drafting the post below, I belatedly checked Lawfare’s recent posts to ensure I’m not preempted. And there I found this terrific post by my colleague Megan Reiss, covering a great deal of the same ground on the Section 231 and 241 issues (and doing a much better job of contextualizing them).

On Nov. 20, the Treasury Department’s Office of Foreign Assets Control, which enforces sanctions, identified and designated individuals and entities connected to an operation by the Quds force, the special forces division of Iran’s Revolutionary Guard Corps (IRGC) to print counterfeit Yemeni money worth hundreds of millions of U.S. dollars using European equipment.