UK MPs Seek to Designate Iran’s Islamic Revolutionary Guard Corps a Terrorist Organisation

In light of the recent protests in Iran, a UK press report has recently drawn attention to a motion - known as Early Day Motion 483 – filed in October by a Conservative Party MP to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a terrorist organisation. The motion calls upon the UK Government to include the IRGC on the list of “proscribed organisations” and to impose “punitive measures” against its individuals.  Since its filing, the motion has collected 70 signatures from MPs from various parties, including the Conservative Party, the Labour Party, the Scottish National Party, Plaid Cymru, the Liberal Democrat Party and the Democratic Unionist Party. While Early Day Motions can be debated, most are not.  Instead they are typically used to draw attention to a particular topic or to record the views of those MPs that lend their signatures.  For example, the official UK Parliament website notes that during the 2015-2016 parliamentary session a total of 1,457 Early Day Motions were filed.  With the House of Commons back in session after the Christmas break, it remains to be seen whether Early Day Motion 483 gets debated.  Were the Early Day Motion to be debated and result in formal action by the UK Government then the designation of IRGC as a proscribed organisation would have a number of consequences.  The organisation would become ‘proscribed’ under the Terrorism Act 2000, and it would become a criminal offence under UK law to, among other things, belong to the organisation, invite support for the organisation and arrange any meetings in furtherance of the organisation’s activities.  Inclusion on the list of proscribed organisations is not, however, the same as inclusion on the “consolidated list” maintained by the UK Office of Financial Sanctions Implementation of all designated persons subject to financial sanctions under EU and UK legislation.  The punitive measures contemplated by the motion could, however, extend to imposing such sanctions upon individual members of the IRGC. Early Day Motion 483 follows, and in fact references, the designation by the US Office of Foreign Assets Control of the IRGC in October 2017 under global terrorism Executive Order 13224, which was a largely symbolic act in light of other pre-existing OFAC sanctions on the IRGC and its affiliates.