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 Executive Order 13224 (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.