In a recent letter to supporters of the Iranian opposition, Dr. Bruno Scholl, head of the Iran Division of the European External Action Service, commented on why the EU had resisted blacklisting the Islamic Revolutionary Guard Corps, the Iranian equivalent of the Gestapo. He stated: “Regarding the issue of the Islamic Revolutionary Guard Corps (IRGC), According to Article 1(4) of the Common Position of December 2001, the prerequisite for listing an organisation is a national decision by a competent national authority of a Member State or a third country, such as a court decision or an order by an administrative authority. In this context, let me also recall that the EU has already listed individuals and entities of the IRGC under the Iran human rights sanctions regime, the territorial integrity of Ukraine sanctions regime, the Syria sanctions regime as well as the Iran weapons of mass destruction sanctions regime, while the IRGC in its entirety has also been listed under the Iran weapons of mass destruction sanctions regime. As such, in effect, there is already an obligation within the EU to freeze all assets held by the IRGC, as well as a prohibition on making available to them of funds or economic resources, directly or indirectly.”

In reality, the EU has listed “the IRGC in its entirety” under the Iranian nuclear programme, meaning that there is a prohibition on any person or entity attempting to sell or transfer items that could be used in the manufacture or deployment of nuclear weapons or weapons of mass destruction. However, this prohibition stops short of listing “the IRGC in its entirety” as a terrorist........

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