OUTLAW REGIME: 

A CHRONICLE OF IRAN’S 

DESTRUCTIVE ACTIVITIES 

2020 Edition 

Iran Action Group 

U.S. DEPARTMENT OF STATE 
“America will not be held hostage 

to nuclear blackmail.” 

PRESIDENT DONALD J. TRUMP, MAY 2018 
 

OUTLAW REGIME: 

A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES 

4 A Letter From 6 Executive 10 Chapter One: 

Secretary of State Summary Iran’s Regional 

Michael R. Pompeo Destabilization 

19 Chapter Two: 23 Chapter Three: 32 Chapter Four: 

Iran’s Missile Iran’s Support for Illicit Financial 

Program Terrorism Activities in Iran 

38 Chapter Five: 44 Chapter Six: 53 Chapter Seven: 

Iran’s Nuclear Human Rights Iran’s Threat to 

Program Abuses in Iran Cyber Security 

Chapter Eight: 

Environmental 58 Exploitation 

AP PHOTO OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 3 
A LETTER FROM U.S. SECRETARY OF STATE 

MICHAEL R. POMPEO 

The Trump Administration harbors no illusions about the nature of the 

Islamic Republic of Iran: it is a radically revolutionary, outlaw regime, 

the world’s leading state sponsor of terror and anti-Semitism, and 

the principal driver of instability in the Middle East. The United States 

made the necessary and responsible decision to exit from the Joint 

Comprehensive Plan of Action (JCPOA), a flawed deal premised on the 

hopes of appeasement that failed to protect the American people and our 

allies, or prevent the regime from obtaining a nuclear weapon. President 

Trump offered the Iranian regime a choice: either negotiate a new, 

comprehensive deal or face unprecedented U.S. sanctions and manage 

economic collapse. Since then, the Islamic Republic chose the latter, 

rejecting diplomacy and doubling down on its revolutionary agenda. It 

has used the benefits it gained from the JCPOA – including billions in sanctions relief – to 

continue fueling violence and instability. 

In response to Iran’s choice to pursue hostility and aggressive acts, this administration 

has implemented the unprecedented Maximum Pressure Campaign. We have made good 

on our commitments by imposing the toughest sanctions regime ever against the corrupt 

leadership of the Islamic Republic. Our sanctions have denied Iran more than 90% of its oil 

export revenue, depriving the regime access to well over $70 billion in income that could 

have otherwise gone to fund terror operations – while preserving avenues for humanitarian 

trade and assistance. These actions have saved the lives of innumerable Iranians, Syrians, 

Iraqis, Yemenis, and other innocent civilians in the regime’s crosshairs. 

Two years ago, I said it was important that the world understand the full spectrum of Iran’s 

malign influence; its support to Shia militia groups in Iraq, its longstanding sponsorship of 

Hizballah in Lebanon, its use of Afghan and Pakistani refugees as cannon fodder in Syria, 

and most of all the regime’s systematic disregard for the human rights of its own people 

inside Iran. Sadly, since we last published this report, the Iranian regime has found new ways 

to harm Iranians and recklessly extort the international community. 

The regime has threatened freedom of navigation and global economic stability by mining 

and detaining commercial vessels in and around the Strait of Hormuz. In a brazen attack, 

Iran launched more than 25 land attack cruise missiles and unmanned aerial vehicles directly 

from its own soil last year against the world’s largest oil processing facilities in Saudi Arabia. 

Just a few months later, Iran struck U.S. and coalition forces stationed in Iraq on the frontline 

of the fight against ISIS. Yet the regime’s attempt to extort the international community into 

4 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

backing down only increased its isolation and brought the world together to condemn Iran’s 

violence. 

The Iranian regime’s continued acts of aggression beyond its borders is consistent with its 

campaign of terror and repression at home. In response to widespread protests in November 

2019 the regime executed a brutal crackdown, killing as many as 1,500 of its own citizens 

while jailing thousands more. In an attempt to hide its actions from the world, the regime 

simultaneously imposed a near-total shutdown of access to the internet. In September, the 

regime tortured and executed champion wrestler Navid Afkari to send to its own people an 

unmistakable message of intimidation that protests will not be tolerated. This reminded the 

world again that the greatest victims of the Islamic Republic of Iran are the Iranian people, 

who are increasingly standing up to the regime. 

The United States has not stood by idly in the face of Iran’s violence. Working with our 

partners and allies, we have redoubled our commitment to preserving peace and stability 

in the region. We have shown Iran that if it chooses to threaten American lives, President 

Trump will not hesitate to take decisive action. We have continued to strengthen and 

vigorously enforce our sanctions, making clear to Iran that its malign actions will only 

steel our resolve and increase the regime’s economic and diplomatic isolation. Since our last 

report, several countries in Europe and South America have correctly declared Iran’s proxy 

Hizballah a terrorist organization. We invoked the “snapback” mechanism to restore nearly 

all UN sanctions on Iran. We continue to stand with the Iranian people, and have rolled out 

sanctions and visa restrictions on a host of Iranian officials directly responsible for the 

lethal crackdown in November 2019. Corrupt and repressive regime officials, not the Iranian

people, are the targets of the Maximum Pressure Campaign. 

The only path forward for Iran to secure relief from economic sanctions is to cease its 

destabilizing activity and behave like a normal nation. It is not too late for the Iranian 

regime to abandon its dangerous conduct in favor of a new path. Countries in the Middle East 

recognize the opportunity that peace and stability bring and so too should Iran. Israel, the 

United Arab Emirates, and Bahrain recently came together in the historic Abraham Accords 

because they understand cooperation and dialogue are the best ways to address shared 

challenges and bring prosperity to their people. 

As President Trump has said, Iran is a country with enormous untapped potential. If Iran 

were to work alongside its neighbors to foster stability and welcome peace rather than drive 

conflict, the Iranian people would thrive and once again enjoy prosperity. I look forward to 

the day that all Iranians enjoy the freedom and dignity they so deeply deserve. 

Michael R. Pompeo 

SECRETARY OF STATE, UNITED STATES OF AMERICA 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 5 
EXECUTIVE SUMMARY 

AP PHOTO 

The 2020 edition of the Outlaw Regime report documents the 

magnitude of the Islamic Republic of Iran’s destructive activities 

at home and abroad. This report has been revised to include the 

range of destabilizing actions Iran has taken since October 2018, 

when we first released the Outlaw Regime report, contains a new

chapter on Iran’s Regional Destabilization, and includes many 

other updates. Some of the activities highlighted in this report 

have occurred recently, while others date back to the early days 

of the revolution. As this report makes clear, the one constant is 

that the Iranian regime will do whatever it takes to maintain its 

grip on power and spread its violent, revolutionary ideology. 

Since the establishment of the Islamic Republic, the regime has deployed a revolutionary ideology 

to justify the export of terrorism and instability throughout the Middle East. The primary tool to 

execute this hegemonic mission has been the Islamic Revolutionary Guard Corps (IRGC). The IRGC 

is the most powerful conglomerate in Iran, spreading and consolidating its control over much of 

Iranian life. As the Iranian government’s primary means of directing and implementing its global 

expansionist campaign, the IRGC actively participates in, finances, and promotes terrorism as a

tool of statecraft. In the past year alone, the IRGC naval forces have mined six commercial ships 

while its Aerospace Force has launched a complex missile attack against Saudi Arabian oil facilities 

and struck U.S. and Coalition forces on the frontline of the fight against the Islamic State of Iraq

and Syria (ISIS). IRGC ground forces are deployed abroad to bolster the Assad regime, and its Basij 

paramilitary force is mobilized at home to surveil, harass, and kill ordinary Iranians. The IRGC 

Qods Force (IRGC-QF), whose activities have an extraterritorial focus, leads the Islamic Republic’s 

destabilizing support for militias and terrorist groups, supplying arms, training, and operational 

guidance to armed groups across the region in order to exacerbate conflicts at the expense of local

populations, deepening the cycle of violence and misery. 

Chapter One underscores the regime’s role as a persistent destabilizing force across the Middle 

East, detailing the aggressive actions taken by the Iranian regime and its partners and proxies. In 

September 2019 and January 2020 respectively, Iran conducted large scale conventional attacks 

on Saudi oil facilities and an Iraqi base hosting U.S. and coalition forces. In May and June 2019,

Iran endangered the free flow of maritime commerce by conducting limpet mine attacks on six

commercial vessels passing through the Strait of Hormuz and shot down a U.S. drone flying in

international airspace. In July 2019, the IRGC Navy detained a British oil tanker and her crew, 

subjecting them to more than two months of captivity. Beyond actions by its own forces, Iran 

6 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

 

has continued its longstanding practice of arming and training terrorists and militia groups 

throughout the Middle East, inflaming conflicts in Iraq, Syria, and Yemen and catalyzing increased

instability and human suffering throughout the Middle East.

Chapter Two explores Iran’s development of its ballistic missile program. Iran has the largest 

and most diverse ballistic missile force in the Middle East and is continuing to explore multiple 

pathways that would allow it to expand its longer-range missile capabilities and achieve greater 

precision. Recognizing this threat, the UN Security Council adopted UN Security Council Resolution 

(UNSCR) 1929 in 2010, which imposed tough limitations on Iran’s proliferation activities. While 

Resolution 2231 replaced Resolution 1929 and weakened aspects of its binding limitations, 

Resolution 2231 nonetheless continues to call upon Iran not to undertake any activity related to 

ballistic missiles designed to be capable of delivering nuclear weapons — a clear signal of the 

international community’s continued concern about Iran’s behavior. In spite of these demands, 

Iran has continued to defy the provisions of UNSCR 2231, and its pace of missile launches and tests 

has not diminished since this resolution went into force in 2016. 

Chapter Three recounts the long history of the Islamic Republic’s support for terrorism, 

primarily driven by the IRGC. Since 1979, Iran has made it a policy of the state to actively direct, 

facilitate, and carry out terrorist activity globally. Unlike almost any other country, the Islamic 

Republic has supported terrorism as a method of asymmetric warfare via its own military and 

intelligence apparatuses: the IRGC-QF and the Ministry of Intelligence and Security (MOIS). Today, 

the IRGC-QF is active across the Middle East and has plotted or carried out terrorist attacks on five

out of seven continents. Where it does not act directly, the Iranian regime has used partner and 

proxy groups such as Hizballah, Hamas, Palestine Islamic Jihad, the Bahraini Al-Ashtar Brigades, 

and the Iraqi Shia militia groups Kata’ib Hizballah and Asa’ib Ahl al-Haq to conduct attacks.

Chapter Four details the Islamic Republic’s illicit financing activities, which undermine

the integrity and security of the global financial system, yet are vital to the Iranian regime’s

destabilizing campaigns and the aggrandizement of its leaders. The Iranian regime uses opaque

and fraudulent financing activities to fund its partners, proxies and proliferation activities. In the

last year, the international community exposed the IRGC-QF’s continued use of front companies 

and related individuals to move funds, procure restricted materials and technologies, exploit 

currency exchange networks in neighboring countries, and produce counterfeit currency. In 

February 2020, the Financial Action Task Force (FATF) called on all jurisdictions to impose 

effective countermeasures on Iran for its failure to implement basic international standards to

combat money laundering and terrorist financing.

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 7 
EXECUTIVE SUMMARY 

Chapter Five outlines the most recent concerns with Iran’s nuclear program reported by the world’s 

independent nuclear verification authority, the International Atomic Energy Agency (IAEA), and puts

those concerns in the context of Iran’s decades-long history of obstruction and noncompliance with its 

obligations under its IAEA safeguards agreement required under the Nuclear Non-Proliferation Treaty

(NPT). In January 2019, the IAEA detected chemically-processed uranium particles at an undeclared 

location in Iran; the IAEA’s investigation into the source and origin of these particles is ongoing. To 

date, Iran has failed to fully address multiple separate questions raised by the IAEA about possible

undeclared nuclear material and activities in Iran — including by refusing for many months the IAEA’s 

requests for access at two locations associated with those questions — which Iran is required to provide

under its safeguards obligations. In 2020, the IAEA Board of Governors made an important rebuke of 

Iran’s actions by adopting a resolution calling on Iran to fully cooperate with the IAEA without further 

delay, including by providing prompt access to the locations specified by the IAEA. On August 26 2020

the IAEA Director General and Iran reached agreement on access to both locations, however critical 

questions about Iran’s implementation of its safeguards agreements still remain outstanding. The IAEA

will continue to report on whether its initial questions have been addressed based on the information

collected during these visits as well as its continued engagement with Iran. 

Together with Iran’s efforts to both preserve a vast archive of records from its past nuclear weapons

program and maintain its former nuclear weapons scientists within a bureaucratic structure under 

military direction and headed by the past leader of that weapons program, Iran’s recent provocative 

steps to expand its uranium enrichment activities paint a very troubling picture of its nuclear program 

today and underline the importance of the international community reaching an enduring solution to 

the myriad problems Iran has presented since its covert nuclear program first came into public view in

2002. 

Chapter Six documents the repeated and systemic deployment of human rights abuses by the 

Islamic Republic to suppress peaceful civil society activism and the demands of the Iranian people 

for democratic reforms. The Islamic Republic does not tolerate dissent of any kind and persecutes 

civil society activists, including labor rights leaders, and members of ethnic and religious minority 

groups. The regime also denies its citizens fair trial guarantees, regularly falling short of the standards 

provided by its own laws. Its prisons are notorious for mistreatment and torture, and it uses capital 

punishment on minors and for crimes that do not meet Iran’s international obligation to impose the 

8 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

death penalty for only “the most serious crimes.” All of these issues were on full display when the Islamic 

Republic arrested, tortured, and ultimately executed champion wrestler Navid Afkari, all because he dared 

participate in a protest in 2018. Beyond its borders, the Islamic Republic and its partners and proxies have 

committed numerous human rights abuses, including targeting civilians in Syria and kidnapping Sunnis 

in Iraq.

Chapter Seven illustrates the spread of the Islamic Republic’s malign behavior in cyberspace. While 

the bulk of Iran’s malign cyber actions are against countries in the region, Iran has increasingly deployed 

this capability against a variety of U.S.-based entities including financial companies, universities, and

critical energy infrastructure. Iran has used its cyber capabilities to identify and silence critics and spread 

its disinformation campaigns abroad. In the past year the regime has resorted to even more extreme 

measures, imposing an almost total internet shutdown and removing internet access for one week to 

nearly all of its 80 million people during nationwide protests in November 2019. 

Chapter Eight highlights the enduring and increasingly irreversible tragedy of environmental 

degradation at the hands of the Islamic Republic’s self-serving leaders. Following decades of corruption 

and misguided policy, Iran is inching ever closer to an environmental crisis. The regime’s failure to 

respond to worsening environmental conditions has led to a significant depletion of Iran’s water resources

and severe air pollution. Instead of addressing these existential issues, the Islamic Republic has brutally 

responded against those calling for reform. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 9 
10 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 

-

CHAPTER ONE 

IRAN’S 

REGIONAL 

DESTABILIZATION 

July 18, 1994 – Buenos 

Aires, Argentina: Lebanese 

Hizballah detonated a bomb 

outside the Argentine Israeli 

Mutual Association. Iran 

provided logistical support, 

and the attack resulted in 

95 dead and 200 wounded. 
 

“THIS IS AN ATTACK OF A SCALE WE’VE JUST NOT SEEN BEFORE. 

THE SAUDIS WERE THE NATION THAT WERE ATTACKED. IT WAS ON 

THEIR SOIL. IT WAS AN ACT OF WAR AGAINST THEM DIRECTLY.” 

U.S. SECRETARY OF STATE MICHAEL R. POMPEO, SEPTEMBER 18, 2019 

INTRODUCTION 

Since its founding in 1979, the Islamic Republic has acted as a destabilizing force in the Middle East, 

instigating and inflaming conflict in an attempt to assert itself as the region’s dominant power

and export its authoritarian system of government. In the past year alone, Iran has launched an 

attack from its territory against civilian oil facilities in Saudi Arabia and used its ballistic missiles 

against an Iraqi base hosting U.S. and Coalition forces on the frontlines of the fight against ISIS.

At sea, Iran continues to pose a major threat to freedom of navigation and maritime security. 

Since 2019, the Iranian regime has mined six commercial vessels, shot down a U.S. unmanned 

aerial vehicle (UAV) flying in international airspace, and unjustifiably detained a British tanker

and her crew for more than two months. In addition to these actions, the regime has continued 

its longstanding practice of funneling weapons, personnel, and finances to partners and proxies

throughout the region, needlessly prolonging and exacerbating conflicts from Syria to Yemen.

MISSILE STRIKES IN SAUDI ARABIA AND IRAQ 

On September 14, 2019, Iran launched, from its own soil, a combination of at least 25 land 

attack cruise missiles (LACMs) and unmanned aerial vehicles (UAVs), striking Saudi Arabian oil 

processing facilities in Abqaiq and Khurais. The attack temporarily shut down approximately half 

of Saudi Arabia’s oil production capacity. Although the Houthis initially claimed responsibility 

for the strike, a panel of United Nations experts rejected the Houthi claim. Careful analysis 

clearly revealed that the attack originated in Iran. The impact points on the Saudi facilities 

show that the attack originated from the northwest, not the south as would be expected from 

an attack originating in Yemen. The distance of the targets exceeds the estimated range of 

weapons in the Houthi arsenal. The size and complexity of the attack required an operational 

capability that the Houthis have never demonstrated, before or since. Finally, there is no 

history of the Iranian produced UAVs used in the attack ever being deployed or possessed by the 

Houthis. The overwhelming evidence against Houthi involvement has resulted in widespread 

condemnation of Iran for the attack. Days after the attack, Saudi Arabia’s Ministry of Defense 

stated that the weapons used in the attack were of Iranian origin, and on September 24, the 

AP PHOTO OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 11 
AP PHOTO 

Lebanese Hizballah fighters parade during 

a ceremony in south Lebanon. 

United Kingdom, France, and Germany issued a joint statement condemning the attack and 

attributing it to Iran. 

On January 7, 2020, Iran again used its missile force to launch more than a dozen ballistic missiles 

at U.S. and Coalition forces stationed at Ain Al-Assad Air Base in Iraq. Although the strike did 

not result in any deaths, more than one hundred U.S. servicemen suffered traumatic brain 

injuries due to the attack. Moreover, multiple DoD personnel have provided their assessment 

that the lack of casualties was due to the base’s early warning system and good fortune rather 

than Iranian intentions. In contrast to the attack on Saudi Arabia, Islamic Revolutionary Guard 

Corps (IRGC) Aerospace Force Commander Amir Ali Hajizadeh immediately claimed credit for 

the attack, boasting of the strike’s success and noting 

that Iran could easily have caused “4,000 or 5,000” 

deaths. 

PARTNERS AND PROXIES: INFLAMING 

REGIONAL CONFLICTS 

Through the IRGC, Iran has provided advisors, training, 

technology, and weapons to a variety of armed groups 

across the region, all of whom continue to use those 

capabilities to attack and threaten people across the 

region. Iranian lethal aid to these groups includes small 

arms, ammunition, explosives, improvised explosive devices (IEDs), explosively formed penetrators 

(EFPs), vehicles, anti-tank guided missiles (ATGMs), man-portable air defense systems (MANPADs), 

artillery, rockets, UAVs, Anti-Ship Cruise Missiles (ASCMs), and ballistic missiles. 

Iraq

In Iraq, Iran has maintained decades-long relationships with a variety of Shia militant groups

(SMGs), many of whom have deployed Iranian weapons against U.S. military personnel. Since the 

fall of 2019, U.S. and Coalition forces stationed in Iraq to fight ISIS have come under multiple rocket

attacks, two of which have resulted in American fatalities. Iran’s closest and most capable partner 

armed group in Iraq, Kata’ib Hizballah, executed a rocket attack with a barrage of over 30 rockets at

an Iraqi military facility in Kirkuk on December 27, resulting in the death of an American contractor.

Iranian-backed SMGs struck again on March 11, launching a rocket barrage against Camp Taji, 

killing one British and two U.S. service members as well as wounding eleven others. 

12 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

LEBANON: Iran 

provides Lebanese 

Hizballah about $700 

million every year 

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UKRAINE 

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,, .. 

RUSSIA 

SYRIA: Iran has 

extended at least 

$4.6 billion in 

credit to the 

Assad regime 

PALESTINIAN --------- 0 i JORDAl')J 

TERRITORIES: ISRVAEL 

IRAQ 

Iran historically \/ 

provides over $:LOO 

SAUDI 

ARABIA 

Caspian 

Sea 

million a year to 

Palestinian groups, 

including HAMAS and 

Palestine Islamic Jihad 

EGYPT 

..... ···· · ... .. 

IRAQ: Iran's support 

for Shia militants in 

Iraq remains the 

primary threat to US 

personnel there 

-,g, Ou' 

SUDAN ~~ 

~ m 

YEMEN: Iran since 20:1..2 - --------------(@) 

has spent hundreds of 

millions of dollars aiding 

the Houthis in Yemen 

SOUTH 

SUDAN 

ETHIOPIA 

YEMEN 

SOMALIA 

IRAN 

U.A.E. 

0 

0 

KAZAKHSTAN 

OMAN 

AFGHANISTAN 

Arabian 

Sea 

200 400 Miles 

200 400 Kilometers 

Since 2012, Iran has spent over $16 billion propping up 

the Assad regime and supporting its other partners and 

proxies in Syria, Iraq, and Yemen. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 13 
Pompeo 0 

@SecPompeo 

FACT: #Iran 's regime punished 

Palestinians by providing them just 

$20,000 -yes, $20,000-via #UNWRA 

from 2008 to 2017. 

8:23 PM - 7 Sep 2018 

Lebanon 

In Lebanon, Iranian support has been foundational to Hizballah since its emergence in the 1980s 

as the first organization to employ the widespread

and regular use of suicide bombers. In addition 

to providing as much as $700 million in funds 

annually, Iran has long been one of the primary 

suppliers of Hizballah’s military technology, 

enabling the group’s transformation into a quasiconventional force. This support violates UNSCR 

1701, adopted in 2006, which obligates all UN 

Member States to prevent the sale or supply to any individual or entity in Lebanon of arms and 

related materiel, except those authorized by the Government of Lebanon or the United Nations 

Interim Force in Lebanon. As part of this larger picture, Iran has continued to support Hizballah’s 

development of missile production facilities, as well as the group’s ongoing efforts to convert its

130,000-plus rocket stockpile into precision guided missiles. Hizballah poses a growing threat to 

both Lebanese and regional stability, as demonstrated in September 2019 when the group used a 

number of Anti-Tank Guided Missiles to target an Israeli army base and military vehicles located 

inside Israeli territory. 

Syria 

Iran has been the Assad regime’s most reliable partner over nearly a decade of involvement in the 

Syrian conflict, propping up the Syrian regime and extending Assad almost $5 billion in lines of

credit and more than $10 billion in funding since 2012. Tehran has deployed thousands of soldiers 

on the ground—including both their conventional army (Artesh) and IRGC Ground Forces—while 

managing militia groups of as many as 10,000 Iraqi, Afghan, and Pakistani Shi’a fighters in Syria.

Iran’s support for the Assad regime has been constant even in the face of the regime’s egregious 

use of chemical weapons and attacks killing civilians and destroying civilian infrastructure such as 

hospitals and schools. In addition to IRGC and Artesh fighters, Iran’s oldest partner in the region,

Hizballah, has been particularly active in Syria during the conflict, sending fighters and commanding

militia forces to bolster the regime against opposition forces. 

As the unresolved Syrian conflict demonstrates, ISIS and Iran’s Shia militia proxies fed off each

other and exploited conditions to strengthen their grip on societies. Iranian malign activities, and its 

influence in Damascus, fueled the emergence of ISIS and, in turn, capitalized on the cycle of violence

that ISIS caused. Vulnerable Shia and Alawi populations, under pressure from ISIS, welcomed the 

security of Shia militias supported by Iran. The grave abuses of Iranian-backed Shia militia and 

14 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

 

Assad’s forces, in turn, convinced vulnerable Sunni populations that ISIS protection was their only 

recourse. Finally, Iran exploited the fight against ISIS and the elimination of the ISIS territorial

caliphate to expand and deepen its influence and advance its hostile and hegemonic goals. Iranian

malign influence and activities in Syria, coupled with the failure of the Assad regime to secure and

serve the Syria people, have ensured that the grievances that ISIS exploited have not been resolved 

and have only deepened, thereby enabling the regeneration of ISIS. 

Yemen

Iran has sought to prolong the conflict to challenge its main regional rival, Saudi Arabia. Iran has

spent hundreds of millions of dollars assisting the Houthis and has provided a broad spectrum 

of lethal aid, including ballistic missiles, UAVs, and explosive boat technology, in violation of UN 

Security Council Resolution 2216, which prohibits the supply or sale of arms and related materials to 

the Houthis. U.S. naval forces have interdicted multiple shipments of Iranian weapons bound for the 

Houthis in Yemen. The most recent interdictions in November 2019 and February 2020 uncovered

over 150 anti-tank guided missiles (ATGMs), explosive boat components, surface-to-air missiles, 

and land attack cruise missile and UAV components, among other forms of lethal assistance. 

Iranian supported UAV and missile attacks from Yemen have undermined peace efforts and have

threatened to escalate the conflict even further. In recent years, the Houthis, enabled by IRGC

advisors, have conducted multiple long-range missile and UAV strikes on both Saudi Arabia’s Yanbu

port and capital city of Riyadh using versions of the Iranian Qiam ballistic missile. The Iranian hand 

in these recent attacks is evident in recovered missile debris from several attacks that are unique to

Iranian missiles, including components stamped with a logo signifying the letters SBI, used by the 

Iranian company Shahid Bagheri Industries. 

Palestinian Territories 

Iran has historically provided up to $100 million 

annually in combined support to Palestinian 

terrorist groups, including Hamas, Palestinian 

Islamic Jihad (PIJ), and the Popular Front for the 

Liberation of Palestine-General Command. These 

terrorist groups have been behind a number of 

deadly attacks originating from Gaza, the West 

Bank, Syria, and Lebanon, including attacks 

against Israeli civilians, Egyptian security forces in the Sinai Peninsula, and American citizens. 

Iran’s support for Palestinian terrorist groups serves only to further its own strategic interests 

AP PHOTO 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 15 
and threaten our partner and ally Israel while coming at a high cost to the Palestinian people. As 

the regime prioritizes funding for Palestinian terror groups, it falls well short of living up to its 

self-professed obligation of directly supporting the Palestinian people. In the last ten years, Iran 

has provided only $20,000 to the United Nations Relief and Works Agency (UNRWA). This pales in 

comparison to the nearly $3 billion provided to UNRWA by the U.S during this period, as well as the 

almost $2 billion provided by the EU and the more than $600 million provided by Saudi Arabia. 

MARITIME SECURITY: ESCALATING VIOLENCE AT SEA 

The Islamic Republic poses a major threat to the exercise of navigational rights and freedoms 

and maritime security from the Persian Gulf to the Red Sea. Since 2019, the Iranian regime has 

mined six commercial vessels, shot down a U.S. UAV lawfully operating over the Persian Gulf, and 

illegally detained a British tanker and her crew without justification for more than two months.

Iranian officials, including high-level IRGC commanders, have repeatedly threatened to close the

Strait of Hormuz, the narrow waterway between the Persian Gulf and the Arabian Sea through 

which 20 percent of global petroleum shipments pass. 

The Islamic Revolutionary Guard Corps Navy (IRGCN) operates hundreds of small speedboats 

typically armed with Anti-Ship Cruise Missiles (ASCMs), torpedoes, and naval mines, representing 

IRGC personnel mined the Norwegian owned vessel Front Altair 

16 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE while it transited the Gulf of Oman on June 13th, 2019. 
 

 

a persistent threat to freedom of navigation and maritime security. Iran’s threat to the free flow of

commerce manifested itself in May and June of 2019, when IRGCN personnel placed and detonated 

limpet mines on six commercial vessels. On May 12 two Saudi-, one UAE-, and one Norwegian-flagged

ships were damaged after limpet mines detonated on their hulls while harboring in UAE territorial 

waters off Fujairah. Barely a month later on June 13, IRGCN personnel mined one Japanese and one

Norwegian-owned ship while the vessels transited the Gulf of Oman. Although Iran denied conducting 

these attacks, U.S. armed forces later released a video showing an IRGCN small boat removing an 

unexploded Iranian limpet mine from the side of the Japanese tanker. Soon after the second limpet 

mine attack, on June 19 the IRGC used a surface-to-air missile to shoot down a U.S. UAV transiting 

the Strait of Hormuz. Undergirding all of Iran’s specific acts of violence is the IRGCN’s consistently

unsafe and unprofessional conduct, having for years deployed its small attack boats to harass U.S. 

naval vessels. The U.S. Navy has recorded dozens of dangerous interactions with IRGCN vessels in 

recent years, most recently in April 2020, when a swarm of IRGC fast boats disrupted a routine exercise 

of five U.S. naval vessels by engaging in high speed, provocative approaches.

By providing weapons, training, and advisors to the Houthis in Yemen, Iran has expanded its reach

beyond the Persian Gulf to the Red Sea. With Iranian support, the Houthis have executed a number of 

attacks on commercial and military vessels, threatening the free flow of commerce through another

maritime chokepoint, the Bab al-Mandeb Strait. In October 2016, the Houthis fired Anti-Ship Cruise

Missiles at U.S. warships in international waters just north of the Bab-al-Mandeb. The attacks came 

just one week after militants struck and disabled the Swift, an Emirati transport vessel. In January 

2017, the Houthis were responsible for launching a remotely-detonated marine craft that attacked the 

Saudi Royal Navy frigate Al Madinah. The U.S. Navy determined that the IRGC likely provided the craft. 

Since then, the Houthis have continued to threaten and carry out attacks against Saudi commercial 

vessels, including a July 2018 attack on a Saudi tanker in the Red Sea. The Houthis have also emplaced 

naval mines near commercial shipping routes in the Red Sea, threatening the exercise of navigational 

rights and freedoms and the free flow of commerce in the region.

UNJUSTIFIED DETENTION OF SAILORS AT SEA 

Since its founding, the Islamic Republic has frequently resorted to kidnapping and wrongful detentions

for political gain, a pattern of behavior that has also played out at sea. A obvious example of this was 

the IRGC Navy’s July 19, 2019 seizure of the British-flagged, Swedish-owned Stena Impero tanker while

it was transiting the Strait of Hormuz. Iran ultimately detained the Stena Impero for over two months, 

using the ship’s crew as leverage to secure the release of the Adrian Darya, an Iranian oil tanker that 

had been detained by Gibraltarian authorities on July 4 that same year due to credible suspicion that 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 17 
the ship was transporting Iranian oil to Syria in violation of EU sanctions. Once Gibraltar’s authorities 

released the Adrian Darya, the ship immediately set sail for Syria’s western coast and, via ship-to-ship 

transfer, illegally delivered over two million barrels of Iranian crude directly to the Assad regime. 

Another example is the IRGCN’s January 2016 seizure of two U.S. Navy riverine boats. Iranian authorities, 

claiming the vessels illegally strayed into Iranian waters following engine failure, detained ten U.S. 

sailors for a period of 15 hours. A Department of Defense investigation later concluded that Iran violated 

international law by impeding the boats’ exercise of the right of innocent passage. The investigation also 

determined that Iran violated the sovereign immunity of a U.S. vessel by boarding, searching, and seizing 

the boats, and by taking photographs and video recordings of the crew. 

Iran’s Islamic Revolutionary Guards 

Corps Navy seized Maersk Tigris cargo 

ship and held the vessel for a week. 

18 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 19 

CHAPTER TWO 

IRAN’S MISSILE 

PROGRAMS 

Iran launches an 

Emad long-range 

ballistic surface-tosurface missile. 
“Iran’s pace of missile launches did not diminish after JCPOA 

Implementation Day in January 2016, and Iran continues 

to prioritize its missile force development. Iran has conducted 

multiple ballistic missile launches since that time.” 

SPECIAL REPRESENTATIVE FOR IRAN BRIAN H. HOOK, SEPTEMBER 2018 

INTRODUCTION 

Iran’s development and proliferation of ballistic missiles poses a critical threat to regional security 

and remains a significant challenge to global nonproliferation efforts. This is evident not only in

Iran’s continued expansion and refinement of its ballistic missile capabilities, but also in its reckless

proliferation of missile components and technology to others, including the Houthis in Yemen and

Lebanese Hizballah in violation of UN Security Council resolutions. In addition to activities in which 

the regime has attempted to avoid attribution, the Iranian regime’s threat to regional security is 

evident in its operational use of ballistic missiles in open attacks against U.S. service members in 

Iraq in 2020 and targets in Iraq and Syria in 2018, and its employment of land attack cruise missiles

against Saudi refineries in September 2019.

Iran’s missile development activities have been a concern of the UN Security Council for more 

than a decade. Adopted in 2010, UN Security Council Resolution (UNSCR) 1929 demonstrated the 

international community’s longstanding concern with Iran’s activities, affirmed prior resolutions

restricting Iran’s missile program, and placed tough limitations on its ballistic missile program. 

The resolution prohibited Iran from undertaking any activity related to ballistic missiles capable of 

delivering nuclear weapons, recognizing that such missiles would likely be Iran’s preferred method 

of delivering a warhead in the future. 

In 2015, UNSCR 2231 replaced UNSCR 1929 and weakened aspects of its binding provision on Iranian 

missile launches as part of the implementation of the Joint Comprehensive Plan of Action (JCPOA). 

UNSCR 2231, however, continues to call upon Iran not to undertake any activity related to ballistic 

missiles designed to be capable of delivering nuclear weapons--a clear signal of the international 

community’s continued concern about Iran’s missile program. Adherents of the JCPOA wishfully 

assumed that the deal would engender a positive change in the Iranian regime’s behavior and that 

the deal would beget further deals. Those assumptions were invalid. Since 2015, Iran has brazenly 

continued to defy the will of the international community as it pushes ahead with its missile 

programs. 

AP PHOTO 20 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

 

IRAN’S MISSILE FORCE: A GROWING THREAT 

Iran has the largest and most diverse missile force in the Middle East, with more than 10 types 

of ballistic missiles either in its inventory or in development. The regime continues to deploy a 

range of solid- and liquid-propellant short-range and medium-range systems and is exploring

multiple pathways that would allow it to expand its longer-range missile capabilities and greatly 

enhance precision. In its recent military parades, Iran has exhibited the variety of missiles in 

its arsenal, displaying systems such as the Zolfaghar short-range ballistic missile (SRBM), Qiam 

SRBM, Shahab-3 medium-range ballistic missile (MRBM), the precision-strike Emad MRBMs, Sejil 

MRBMs, and Khorramshar MRBM. In October 2019, Iran publicly unveiled upgrade kits designed

to convert artillery rockets, including the Zeizal 610mm diameter heavy rocket, into steerable, 

surface-to-surface, precision missiles. 

Iran also continues to develop new missiles, as shown by its 2019 unveiling of a new land attack 

cruise missile system known as the Hoveizeh that it claims has a range of 1,300 kilometers, as well 

as a new solid-propellant ballistic missile called the Dezful that allegedly has a 1,000-kilometer 

range. Iran continues to prioritize its missile force development, routinely conducting ballistic 

missile launches since the JCPOA went into effect. Such tests have not only defied the provisions

of UNSCR 2231, they have supported the continued expansion of Iran’s missile capabilities and 

increased the lethality of Iran’s arsenal. Iran engaged in numerous missile launches between 2010 

and 2015 in violation of UNSCR 1929 and, since 2016, in defiance of UNSCR 2231. Since 2016, Iran has

conducted a number of tests on a variety of missile systems including the Khorramshahr, Shahab,

Qiam, and Zolfaghar ballistic missiles, all of which are Missile Technology Control Regime (MTCR) 

Category I systems (e.g., capable of delivering at least a 500 kilogram payload to a range of at least 

300 kilometers) and therefore are inherently capable of carrying nuclear warheads. Many of these 

launches have been catalogued by the United States, the United Kingdom, France, Germany, and

Israel in letters to the Security Council, as summarized in reports of the Secretary-General on the 

implementation of UNSCR 2231. 

Iran has also continued to develop many of the technologies needed to develop longer-range 

missile systems through its space launch vehicle (SLV) program. SLVs use technologies that are 

virtually identical and interchangeable with those used in ballistic missiles. For this reason, Iran’s 

ongoing SLV development efforts pose a particular concern, as they allow Iran to gain experience

with various technologies applicable to longer-range systems under the guise of a peaceful space 

program. SLV development has been a priority for Iran, shown by its unsuccessful attempts on 

three occasions in 2019 to place a satellite into orbit using its Simorgh and Safir SLVs. Thus far

in 2020, Iran conduced a test of its Simorgh SLV in February, and most recently, in April, Iran’s 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 21 
AP PHOTO 

Recovered segments of an Iranian missile. 

IRGC conducted a space launch from a mobile system 

that it claimed placed a military satellite into orbit, 

contradicting their previous claims that they did not 

have a military space program. As with Iran’s ballistic 

missile launches, its SLV tests have been condemned 

at the Security Council by the United States, as well as 

by France, Germany, the United Kingdom, and Israel

as in defiance of UNSCR 2231.

ADDRESSING THE THREAT 

The United States employs a wide range of tools to address this problem. On the multilateral 

front, we work with partners to interdict missile-related transfers to Iran and to disrupt Iranian 

missile proliferation activities in third countries. The United States and many of its closest 

partners participate in the Missile Technology Control Regime and the Hague Code of Conduct 

Against Ballistic Missile Proliferation, where we use our participation to raise awareness of Iran’s 

missile development program, chokepoint technologies, and procurement strategies, as well as 

to press countries to take steps to impede Iran’s acquisition of missile technology. The United

States also reviews thousands of visas annually to ensure that students, researchers, and other 

foreign visitors are not evading export controls and acquiring technological know-how that

could benefit Iran’s missile programs.

The United States and its partners also sanction entities who knowingly supply technology to 

Iran’s missile program. Since the beginning of 2017, the United States imposed sanctions on 

a total of thirty-three foreign entities, mostly in China, for transferring equipment to Iran’s

missile program. The United States has also designated a number of Iranian targets including 

multiple missile-related entities and individuals associated with Iran’s Organization of Defensive 

Innovation and Research (SPND), which played a central role in the Iranian regime’s past 

nuclear weapons effort; the Iran Space Agency, which develops SLV technology; the Iran Space

Research Center, which has worked with the UN-designated ballistic missile organization Shahid 

Hemmat Industrial Group on several projects; and the Iranian Astronautics Research Institute 

which managed the Kavoshgar project, which launched the Safir SLV. The United States also has

designated Iran’s Mahan Air, the Islamic Republic of Iran Shipping Lines (IRISL), and a Chinabased IRISL subsidiary -- all of whom have transported UN-restricted missile items to Iran. 

The United States will continue to aggressively implement and enforce sanctions with respect to 

Iran’s missile program until the Iranian regime agrees to abandon its nuclear ambitions as part 

of a new, comprehensive deal. 

22 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 23 

CHAPTER THREE 

IRAN’S 

SUPPORT 

FOR 

TERRORISM 
“The bet that the JCPOA would increase Middle East stability 

was a bad one for America, for Europe, for the Middle East, 

and indeed for the entire world.” 

U.S. SECRETARY OF STATE MICHAEL R. POMPEO, MAY 2018 

INTRODUCTION 

Since 1979, Islamic Republic of Iran has made it a policy of state to actively direct, facilitate, 

and carry out terrorist activity globally. Designated a State Sponsor of Terrorism since January 

19, 1984, the Islamic Republic has supported terrorism using its own military and intelligence 

apparatuses unlike almost any other country. On April 15, 2019, the United States designated the 

Islamic Revolutionary Guard Corps (IRGC) in its entirety, including its Qods Force (IRGC-QF), 

as a Foreign Terrorist Organization (FTO). The designation was the first time that the United 

States has ever named a part of another government as an FTO. The IRGC FTO designation 

highlights that Iran is an outlaw regime that uses terrorism as a key tool of statecraft. 

Through the IRGC-QF and the Ministry of Intelligence and Security (MOIS), Iran conducts 

attacks, assassinations, and supports terrorist plotting. As outlined in the chapter on proxies, 

terrorist groups such as Hizballah and the Palestinian Islamic Jihad (PIJ) have frequently received 

from the IRGC-QF the training, weapons, and financing needed to conduct acts of terrorism. In 

addition to conducting intelligence collection and clandestine operations outside Iran, MOIS 

operatives also have a history of conducting and enabling acts of terrorism across the globe, 

often abusing diplomatic cover. In July 2018, authorities across Europe foiled an MOIS terror 

plot to detonate an explosive device at a political rally outside of Paris. Several months later in 

October 2018, authorities in Denmark disrupted an Iranian assassination plot targeting Iranian 

opposition figures there. In November 2019, Iranian agents assassinated a dissident Iranian 

journalist living in Turkey. Where it is does not act directly, the Iranian regime has mastered 

the use of terrorist partner and proxy groups to conduct attacks, often through unconventional 

means. Unlike non-state terrorist groups such as ISIS and al-Qa’ida, Iran prioritizes deniability 

and obscures its role in terrorist activities. But the evidence is clear: Iran remains the world’s 

leading state sponsor of terrorism. 

IRAN-BACKED TERRORIST GROUPS 

Through the IRGC-QF, Iran supports several U.S.-designated terrorist groups, providing 

funding, training, weapons, and equipment. Among the groups receiving support from Iran are

Lebanese Hizballah, Hamas, Palestinian Islamic Jihad (PIJ), Kata’ib Hizballah (KH) and Asa’ib 

AP PHOTO 24 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

of money Aowing from 

Islamic Revolutionary Guard 

Corps-Qods Force 

(IRGC-QF) to Hizbolloh 

(i) 

ISLAMIC 

REVOLUTIONARY 

GUARD CORPSQODS FORCE ... The Central Bonk of Iran's then-governor, 

Voliolloh Seif, and the assistant director of 

its international division, Ali Torzoli, 

conspired with IRGC-QF to transfer money 

to AI-Bilod Islamic Bonk, where Aros Habib, 

the bank's chairman and CEO, facilitated 

transfer of the money to Hizbolloh 

representative Muhammad Qosir. 

❖ HIZBALLAH 

f Muhammad Gasir • 

AL-BILAD 

ISLAMIC BANK 

' ArasH~ 

Ahl al-Haq (AAH) in Iraq, and the Al-Ashtar Brigades (AAB) in Bahrain. The Iranian regime has 

also facilitated travel by senior leaders of some of these groups to Iran, often under the guise of 

religious education. 

Lebanese Hizballah is Iran’s most powerful terrorist partner. Over the last decade, it has 

demonstrated its far-reaching terrorist and military capabilities. Above and beyond its 

shipments of weapons, Iran’s annual direct financial backing to Lebanese Hizballah – which 

in recent years has totaled a staggering $700 million per year – accounts for the overwhelming 

majority of the group’s annual budget. Since its successful 2012 attack in Bulgaria, Hizballah 

has conducted terrorist plotting on five continents, with plots disrupted in Azerbaijan, Cyprus, 

Guinea, Kuwait, Nigeria, Panama, Peru, Thailand, the United Kingdom, and the United States, 

among others. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 25 
In addition to its support of proxies and terrorist groups abroad, terrorists also continue to 

reside within Iran’s own borders where they have a haven. Al-Qa’ida (AQ) operatives continue 

to reside in Iran, where they have been able to move money and fighters to South Asia and Syria 

from sanctuary. In 2016, the U.S. Treasury Department identified and sanctioned three senior 

AQ operatives residing in Iran. 

UNCONVENTIONAL TACTICS 

As the Islamic Republic stokes conflicts in the Middle East, it frequently turns to unconventional

tactics to sustain and assist its partners and proxies. This includes the coercion and bribery 

of foreign officials, the facilitation of foreign fighters, use of child soldiers in hostilities, and

misuse of civilian and commercial airlines to facilitate malign military activity. 

The IRGC recruits foreign fighters to increase its influence abroad. The IRGC created the

Fatemiyoun Division of Afghan Shia and the Zainabiyoun Brigade of Pakistani Shia to fight

in regional conflicts, most notably in Syria. The U.S. government designated both groups for

support for terrorism in 2019. West Point’s Combatting Terrorism Center reports the size of 

the Fatemiyoun Division is between 10,000 and 12,000 soldiers, while a Fatemiyoun official in

Iran stated in January 2018 that over 2,000 militiamen had been killed in Syria. In 2018, Human 

Rights Watch documented and condemned the IRGC’s practice of recruiting child soldiers for 

the Fatemiyoun, uncovering evidence that Afghans as young as 14 have died in combat in Syria. 

Following a full assessment of Iranian activities, the U.S. Department of State listed Iran under 

the Child Soldiers Prevention Act for the first time in 2018, and the Department of State listed

Iran again in 2019. 

Multiple organizations continue to document the IRGC’s tactic of coercing Afghan migrants to 

serve as foreign fighters. Human Rights Watch interviewed more than two dozen Fatemiyoun,

reporting that “some said they or their relatives had been coerced to fight in Syria and either

had later fled and reached Greece, or had been deported to Afghanistan for refusing. One

17-year-old said he had been forced to fight without being given the opportunity to refuse.” A

New York Times interview with Fatemiyoun stressed that the Afghans were frequently used as

the “first wave” of fighters, resulting in higher casualty rates among their brigades, and that

the IRGC would send the Fatemiyoun “to fight the most difficult battles.” IranWire reported

in an April 2020 interview in with former Afghan child soldiers, who were 17 and 15 years old 

when recruited in Tehran, that they were dispatched for fighting in Syria multiple times to

26 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

fight alongside President Bashar Al-Assad’s forces and received a three-week training in guerrilla

warfare tactics by the IRGC in Yazd prior to their tours. The former child soldiers said Pakistani Shia

also were a part of the 80 fighters receiving training in Yazd at the time.

The Iranian government also exports its destructive behavior by harnessing the global reach of civil 

and commercial aviation. Mahan Air, Caspian Air, Meraj Air, Pouya Air, and Qeshm Fars Air have all 

been implicated in supporting the IRGC and its partners and proxies. The egregious use of Mahan 

Air to support the IRGC-QF, including with respect to Iranian proxies, threatens regional stability 

and the safety and security of international civil aviation, which is why the entity was sanctioned by 

the U.S. Government in 2011. Mahan Air has been implicated in the transport of IRGC-QF operatives, 

weapons, equipment, and funds in support of the regime’s campaigns abroad. It has shuttled IRGCQF and proxy personnel to the frontlines of 

conflicts, including in Syria, where they engage

in military training and fighting. The airline

has also provided private transportation to 

senior IRGC-QF officials like former Qods Force

commander Qassem Soleimani, allowing them 

to bypass UN-mandated travel restrictions as 

well as normal security and manifest procedures 

in contravention of international standards 

of aviation security. Mahan is also being used 

to support the illegitimate Maduro regime in 

Venezuela. Following the declaration of the 

coronavirus pandemic, Mahan Air’s continued flights to China, Syria, and Lebanon contributed to the

spread of the deadly virus. 

IRANIAN-SUPPORTED TERRORIST PLOTTING, ASSASSINATIONS, AND ATTACKS 

WORLDWIDE 

Although the Middle East bears the brunt of the consequences, Iranian-sponsored terrorist activity

is a global problem. Since the Iranian regime seized power in 1979, Iran has planned and executed 

terrorist plots, assassinations, and attacks in more than 35 countries worldwide, primarily through 

the IRGC-QF and MOIS but also via its partner Lebanese Hizballah. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 27 
Iran’s terrorist activities are on the rise. After a brief lull in the 1990s and early 2000s, Iran has 

ramped up its active involvement in worldwide terrorist activities, with numerous terrorist 

operations uncovered or disrupted in Europe, North and South America, Africa, and Asia since 2009. 

The pace of these activities indicates that Iran remains committed to using terrorism, violence, and 

coercion to achieve its objectives and is confident in its ability to operate anywhere in the world.

EUROPE 

January 2020 – Albania 

Albania expels two more Iranian diplomats for “activities incompatible with 

their diplomatic status” 

November 2019 – Turkey 

Massoud Molavi, who ran an opposition social media site, is assassinated Iranian Opperatives 

December 2018 – Albania 

Albania expels the Iranian ambassador and another diplomat for “damaging [Albania’s] national 

security” 

October 2018 – Denmark 

Authorities in Denmark disrupt an Iranian plot to assassinate Iranian opposition figures

June 2018 – Belgium, France, Germany 

Authorities in Belgium, France, and Germany arrest several Iranian operatives, including MOIS 

operatives assigned as diplomats to the Iranian embassy in Vienna, in a plot to plant a bomb to 

disrupt a political rally in Paris, France. 

March 2018 – Albania 

Albanian authorities detain and deport two Iranian operatives for plotting terrorist activities 

against members of the Mujahedin e-Khalq 

November 2017 – Netherlands 

An Iranian dissident is assassinated in The Hague 

28 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

2016-2018 – Germany 

German authorities search the homes and offices of 10 suspected IRGC-QF operatives in

early 2018. In 2016, German authorities convicts an IRGC-QF operative for spying on the

ex-head of a German-Israeli group and people close to him. 

December 2015 – Netherlands 

An Iranian dissident is assassinated in the city of Almere 

2013 – Bosnia and Herzegovina 

Two Iranian diplomats are discovered to be Iranian intelligence officers and expelled for

espionage and connections to terrorism. 

2012 – Turkey 

Four IRGC-QF operatives enter Turkey to attack Israeli targets; the attack is disrupted by

Turkish authorities. 

July 2012 – Sofia, Bulgaria

An Iranian operative is arrested by Bulgarian authorities for surveilling a synagogue. 

September 17, 1992 – Berlin, Germany 

Hizballah – with Iran’s logistical support – assassinates four Iranian Kurdish dissidents in a 

small-arms attack at a café. Four operatives are tried and convicted in 1997. 

August 6, 1991 – Suresnes, France 

Iranian operatives assassinate former Iranian Prime Minister Shahpour Bakhtiar, who led 

an anti-Iranian regime movement. One operative is convicted, but two flee.

July 13, 1989 – Vienna, Austria 

Iranian operatives assassinate the head of an Iranian Kurdish dissident group and two 

others. 

December 1985-September 1986 – Paris, France 

Hizballah bombs a number of soft targets. Iran provides logistical support, and the attack

results in twelve dead and at least 200 wounded. 

June 14-30, 1985 – Athens, Greece 

Hizballah – with Iran’s logistical support – hijacks TWA flight 847 and kills a U.S. Navy

diver. 

‘ 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 29 AFRICA 
 

 

 

 

November 2016 – Kenya

Two Iranian operatives and their Kenyan driver, who is employed by the Iranian embassy, 

are arrested and charged with information collection in connection with a terrorist act 

after surveilling the Israeli embassy. 

February 20, 2013 – Nigeria

Three Iranian operatives are arrested for planning attacks against U.S. and Israeli tourist 

sites and organizations. A terrorist cell leader had received weapons training in Iran. 

June 2012 – Nairobi, Kenya

Two IRGC-QF operatives are arrested for planning bomb attacks against Western interests. 

Authorities discover thirty-three pounds of explosive materials. 

October 2010 – Nigeria

Nigerian authorities seize an Iranian shipment of rockets, rocket launchers, grenades, 

and ammunition destined for rebels in the Gambia and Senegal. 

NOR T H A M ER I C A 

August 20, 2018 – United States: 

Two Iranian operatives are charged for conducting covert surveillance of Israeli and Jewish 

facilities in the United States, and collecting identifying information about U.S. citizens and 

U.S. nationals who are members of an Iranian opposition group. 

September 29, 2011 – Washington, DC, United States: 

The IRGC-QF supports a plan to bomb a restaurant to assassinate the Saudi Ambassador to 

the United States. 

September 2009 – Glendora, CA, United States: 

An Iranian operative hires a hitman to assassinate a regime opponent. 

July 22, 1980 – Bethesda, MD, United States: 

An Iranian operative assassinates a former Iranian diplomat-in-exile, Ali Akbar Tabatabai, a 

vocal critic of then-Iranian Supreme Leader Ayatollah Ruhollah Khomeini. 

30 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

S OU T H A M E R I C A 

January 8, 2015 – Montevideo, Uruguay: 

A senior Iranian diplomat is expelled for planning an attack near the Israeli Embassy. 

July 18, 1994 – Buenos Aires, Argentina: 

Hizballah detonates a vehicle-borne improvised explosive device (VBIED) outside the 

Argentine-Israeli Mutual Association. Iran had provided logistical support, and the attack 

results in 85 dead and over 300 wounded. 

March 17, 1992 – Buenos Aires, Argentina: 

Hizballah detonates a VBIED outside the Israeli Embassy. Iran had provided logistical 

support. The attack kills twenty-nine people and wounded 242. 

A S I A 

February 2016 – Manila, Philippines 

Philippine authorities thwart an Iranian plot to hijack a Saudi Arabian civilian aircraft. 

April 13, 2013 – Kathmandu, Nepal 

An Iranian traveling on a fake Israeli passport is arrested for conducting surveillance of the 

Israeli Embassy. 

February 14, 2012 – Bangkok, Thailand 

Three IRGC-QF operatives plan attacks against Israeli diplomats in Thailand, but are 

arrested after accidentally detonating explosives. One operative and five others are injured.

February 13, 2012 – New Delhi, India 

IRGC-QF directs a bomb attack targeting Israeli diplomats that injures one Israeli and three 

Indian citizens. 

May 16, 2011 – Karachi, Pakistan 

Iranian operatives assassinate Saudi diplomat Hassan al-Qahtani.

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 31 
32 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 

CHAPTER FOUR 

ILLICIT 

FINANCIAL 

ACTIVITIES 

IN IRAN 
 

“The United States will cut off the IRGC’s access to capital to fund

Iranian malign activity, including its status as the world’s largest 

state sponsor of terror, its use of ballistic missiles against our allies, 

its support for the brutal Assad regime in Syria, its human rights 

violations against its own people, and its abuses of the international 

financial system.”

SECRETARY OF THE TREASURY STEVEN T. MNUCHIN, MAY 2018 

INTRODUCTION 

The Islamic Republic regularly seeks to use deception and subterfuge to fund its myriad illicit 

activities, threatening the integrity and security of the international financial system. The 

regime primarily uses shell companies and other types of seemingly legitimate entities to 

exploit vulnerabilities that enable it to access financing. Although prompted for years by the 

international community to adopt a more stringent regulatory framework, the Iranian regime 

has refused to implement necessary reforms to comply with widely-accepted anti-money 

laundering and combatting-the-financing of terrorism standards. 

MOVING MONEY FOR THE QODS FORCE 

The IRGC Qods Force (IRGC-QF), the IRGC’s extra-territorial branch responsible for supporting 

partners and proxies in the region, continues to engage in large-scale illicit financing schemes to

fund its malign activities and enrich regime leaders. This includes its support for U.S.-designated 

terrorist groups like Hizballah, Hamas, and Kata’ib Hizballah. In one case, IRGC-QF set up a

network of front companies to exploit the currency exchange market in the United Arab Emirates 

(UAE) to procure and transfer hundreds of millions in U.S.-dollar denominated bulk cash. The 

network forged documents and disguised its conduct behind legitimate businesses. At least one 

Iranian front company, the Rashed Exchange, advertised its services online and appeared to be 

a legitimate broker. To disrupt this activity, in May 2018, the U.S. government designated nine 

entities. 

In another scheme, the IRGC-QF used an ostensibly religious institution, Reconstruction 

Organization of the Holy Shrines of Iraq (ROHSI), to transfer millions of dollars to advance the

IRGC’s interests in Iraq, including through a front company that served as a base for Iranian

intelligence activities in Iraq and helped facilitate the shipment of weapons and ammunition to

Iranian-backed militia groups. In addition, IRGC-QF officials used ROHSI’s funds to supplement

IRGC-QF budgets, likely embezzling public donations intended for the construction and 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 33 
 

maintenance of Shiite shrines in Iraq. In March 2020, the U.S. designated nine persons to disrupt

this activity. 

The IRGC-QF’s illicit financing schemes are facilitated at the highest levels of Iran’s government,

including through the Central Bank of Iran (CBI). Since at least 2016, the IRGC-QF has received the 

vast majority of its foreign currency from the CBI, and senior CBI officials have worked directly with

the IRGC-QF to facilitate CBI’s financial support to the IRGC-QF. In 2017, the IRGC-QF oversaw the

transfer of tens of millions of euros to Iraq from the CBI. In May 2018, the U.S. Treasury revealed

that the Islamic Republic’s then-CBI governor, Valiollah Seif, and the assistant director of CBI’s 

international department conspired with IRGC-QF to illicitly conceal the movement of funds to 

its partner, Hizballah. The scheme also involved co-opting the chairman and chief executive of 

Al-Bilad Islamic Bank in Iraq to act as an intermediary, which enabled the transfer of funds to

Hizballah. This scheme by the IRGC not only fueled terrorism, it also undermined the integrity of 

Iraq’s financial system and therefore Iraq’s economic growth and development. In May 2018, the

U.S. designated four individuals and one entity related to this activity. 

Despite these designations, during 2018 and into 2019, CBI continued to funnel several billion 

U.S. dollars and euros to the IRGC, transfer millions of dollars to the Houthis, and coordinate 

with the IRGC-QF to transfer funds to Hizballah. CBI also coordinated with Iran’s National 

Development Fund (NDF) to provide the IRGC-QF with hundreds of millions of dollars in cash 

disbursements. Despite the fact that the NDF was established to serve the welfare of the Iranian 

people by allocating revenues that originated from selling natural resources to durable wealth 

and productive economic investments, in reality, the NDF was used as a slush fund for the IRGCQF. The NDF worked with CBI to disperse half a billion U.S. dollars in 2017 and hundreds of millions 

of dollars in 2018 to the IRGC-QF. In September 2018, the U.S. designated both CBI and NDF for 

supporting special designated global terrorists, including the IRGC-QF. 

In September 2019, the U.S. Department of the Treasury exposed a large oil shipping network that 

was directed by, and financially supported, the IRGC-QF and its partner Hizballah. The network

was overseen by senior IRGC-QF official and former Iranian Minister of Petroleum Rostam

34 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

 

Qasemi and employed an extensive network of ship managers, vessels, and facilitators in order 

to move oil worth hundreds of millions of dollars or more for the benefit of the Assad regime,

Hizballah, and other illicit actors. The networks complex system of intermediaries allowed the 

IRGC-QF to obfuscate its involvement. The IRGC-QF relied heavily on Hizballah officials and

front companies to broker associated contracts. In September 2019, the United States designated 

sixteen entities and ten individuals to disrupt this activity and publicly identified eleven vessels

used by this network. 

The IRGC-QF’s efforts to exploit the international financial system are not limited to fraudulent

documentation or front companies. In 2017, the IRGCQF engineered a plot to print and distribute counterfeit 

currency and flout the laws of European countries. It

deceived European suppliers by using a series of companies 

in Germany to conceal its identity and end-user data to 

procure advanced printing machinery and other necessary 

materials. It then printed counterfeit Yemeni banknotes,

which were used to support its destabilizing activities in 

Yemen and prolong the conflict. In November 2017, the

U.S. Department of the Treasury designated six targets on 

account of their involvement in this operation. The UN 

Yemen Panel of Experts’ 2019 report found the Iranians

were using intermediaries to illegally ship fuel to the 

Houthis, financing their war effort and perpetuating the

Yemen conflict.

Iranian commercial airlines, particularly Mahan Air, play a key role in ferrying IRGC-QF operatives, 

weapons, equipment, and funds that fuel regional conflicts. Because of that critical enabling role,

the IRGC-QF orchestrated an extensive plot to circumvent U.S. sanctions and export controls to 

procure aircraft parts. The scheme involved a series of front companies that assisted Mahan Air 

in procuring export-controlled, U.S.-origin goods. Following an investigation into this activity, 

in May 2018, the U.S. Department of the Treasury designated nine individuals and entities. The 

United States designated Mahan Air in 2011 for providing support to the IRGC-QF, and numerous 

countries in Europe and the Middle East have suspended Mahan Air flights in recent years on

account of concerns about their activities. Mahan Air’s current chairman and chief executive, 

AP PHOTO 

Iranian President Mahmoud Ahmadinejad 

gives a medal of honor to an IRGC 

commander, who was among those who 

intercepted the 15 U.K. sailors and marines. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 35 
 

 

Hamid Arabnejad Khanooki, who is closely associated with the IRGC, was instrumental in facilitating a

shipment of illicit cargo to Syria on a Mahan Air aircraft. The U.S. sanctioned Arabnejad in May 2013 for 

acting on behalf of Mahan Air. Since 2018, the United States has also designated seven general services 

providers for continuing to maintain a commercial relationship with Mahan Air. 

FATF AND THE ISLAMIC REPUBLIC 

The Islamic Republic has continually failed to implement international standards to combat money 

laundering and terrorist financing, as established by the Financial Action Task Force (FATF), a highly

respected intergovernmental organization founded by the G7 in 1989. Despite the opportunities 

afforded to the Islamic Republic to address its strategic deficiencies – including its lack of adequate

criminalization of terrorist financing – the Iranian regime failed to live up to its commitments. Thus, for

the past decade, the FATF has identified Iran as a high-risk and non-cooperative jurisdiction and called

on FATF members to take steps to protect the international financial system from the risks emanating

from Iran. The FATF generously gave Iran more than sufficient time to correct its deficiencies, should it

have chosen to do so. 

Throughout 2019, the decision whether to comply with FATF measures was debated within Iran, 

and officials understood that continuing to flout the standards would negatively impact legitimate

transactions. In March 2019, the Iranian Foreign Ministry Spokesman said that “not joining FATF will 

undoubtedly make Iran’s international trade more difficult and, in some cases, impossible. It will make

Iran’s partners engaged in legal transactions with Iran face serious and costly problems.” One Iranian 

legislator said in June 2019 that “It is not in the interest of the country to place information from the whole 

banking system and financial transactions at the disposal of others” because there were “important

security aspects.” The “security aspects” referenced by the legislator refer to Iran’s continued practice 

of its large-scale illicit financing schemes to fund its malign activities.

From 2016 until February 2020, the FATF had suspended its call for countermeasures against Iran in 

response to a high-level political commitment from Iran’s government to implement certain reforms, 

outlined in a ten-step action plan. The Iranian regime’s action plan expired in January 2018, and the 

regime’s failure to complete nine of its ten action plan items resulted in the FATF’s specific expression

of disappointment in June 2018. Most critically, Iran failed to ratify the UN Palermo and Terrorism 

Financing Conventions. Supreme Leader Khamenei himself questioned Iran’s joining the required

international conventions on terrorist financing and money laundering, which many hardliners argued

36 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

might limit Iran’s ability to finance Hamas and Hizballah. After providing ample time for Iran to correct

course, in February 2020 the FATF lifted its suspension of countermeasures, calling on all jurisdictions to 

impose effective countermeasures on Iran such as requiring financial institutions to review, amend, or if

necessary terminate correspondent relationships with Iranian banks or limiting business relationships 

or financial transactions with Iran.

Maduro’s henchmen looted nine tons of gold bars in May 2020 and sent it to the Iranian regime. The world’s 

leading thieves have partnered with the world’s leading state sponsor of terror. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 37 
38 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 

CHAPTER FIVE 

IRAN’S NUCLEAR 

PROGRAM 
 

“As long as I am President of the United States, Iran will never 

be allowed to have a nuclear weapon.” 

PRES IDENT DONA LD TRUMP, JANUARY 8, 2020 

INTRODUCTION 

Iran’s nuclear program has has remained a threat to international peace and it has been a 

source of serious concern for the international community since Iran’s secret nuclear activities 

first came into the public view in 2002. The uranium enrichment capabilities Iran today 

possesses — and which it is now expanding and seeking to use as tools of nuclear extortion 

— are in part ones that Iran initially developed covertly, in violation of its obligations under 

its legally-binding safeguards agreement with the International Atomic Energy Agency 

(IAEA), and in violation of the Nuclear Non-Proliferation Treaty (NPT). Despite any wishful 

thinking, the 2015 Joint Comprehensive Plan of Action (JCPOA) failed to provide an enduring 

solution to the Iranian regime’s destabilizing nuclear activities given the temporary nature 

of many of the deal’s key restrictions. Proponents of the JCPOA asserted that the aggressive 

behavior of the Iranian regime would moderate under the deal. That was not the case. The 

lifting of sanctions and Iran’s degree of re-integration into the global economy under the 

nuclear deal both empowered and emboldened Iran, making it an even more dangerous actor. 

While much of the public’s attention on Iran’s nuclear program has been focused on Iran’s 

provocative steps to build up its uranium enrichment capabilities once again, Iran’s history of 

denial, delay, and deception in its engagement with the IAEA also seems to be repeating itself. 

The IAEA reported to its Board of Governors in March 2020 on questions of possible undeclared 

nuclear materials and activities in Iran, along with Iran’s refusal at that point to fully cooperate 

with IAEA requests to answer questions it repeatedly had asked since July 2019 and provide 

access to related sites for verification activities as requested in January 2020. Iran’s failure to 

fully address the IAEA’s concerns strikes at the heart of the Agency’s essential verification role 

and raises serious questions about Iran’s compliance with its safeguards and NPT obligations. 

The United States has made clear that a lasting diplomatic solution to resolve these concerns 

must be based on effective IAEA verification. The issue of possible undeclared nuclear material 

and activities in Iran has special salience in light of Iran’s efforts to preserve a vast archive of 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 39 
records from its past nuclear weapons program as well as retain key personnel from the program 

under the leadership of the former head of their nuclear weapons efforts. Fundamentally, the 

open questions about Iran’s compliance with its safeguards and NPT obligations all underscore 

the importance of ensuring the international community can have confidence that Iran has put 

its nuclear weapons ambitions behind it and no longer possesses any pathways to acquiring 

such a capability. 

IAEA SAFEGUARDS CONCERNS 

Safeguards are the technical measures the IAEA uses to verify that nuclear material and technology 

are being used only for peaceful purposes. The IAEA’s global safeguards system was established 

more than six decades ago, and today the IAEA has legally-binding safeguards agreements with 183 

nations, including Iran. The IAEA’s professional and independent verification work plays a critical

role in preventing the spread of nuclear weapons and strengthening the collective security for all 

nations. The global safeguards system has evolved over its history to incorporate lessons learned 

from past proliferation challenges, particularly in expanding IAEA verification authorities vis-àvis undeclared nuclear material and activities. The combination of a Comprehensive Safeguards 

Agreement and Additional Protocol is the de facto global safeguards standard. 

The IAEA issued its first public signal of its most recent concerns with Iran’s nuclear program in

August 2019, when it reported to its Board of Governors that it had been seeking cooperation from 

Iran on matters related to Iran’s implementation of its Comprehensive Safeguards Agreement 

and Additional Protocol. The IAEA revealed additional details in November 2019, when it reported 

that it had detected chemically-processed uranium particles at a location in Iran not declared 

to the IAEA. While the IAEA continues to evaluate Iran’s latest explanation for the presence 

of these uranium particles, it is both worrying and very telling that well over a year into the 

Agency’s investigation into this location, and despite multiple engagements by the IAEA to seek 

clarification, Iran has thus far proven unwilling or unable to conclusively answer the Agency’s

questions about the activities that occurred there, the origin and presence of those particles at

this location, and the current whereabouts of any items that may have been their source. Until 

the matter is resolved, there is no way to know the origin of the particles or how much nuclear 

material may be implicated by the IAEA’s findings.

This is not the only open safeguards question about Iran’s nuclear program the IAEA is currently

investigating. The IAEA reported to its Board of Governors in March and again in June 2020 that 

40 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

Iran had also failed to address multiple separate questions raised by the IAEA about possible

undeclared nuclear material and activities at additional locations in Iran. Additionally, the 

IAEA reported that it had notified Iran to provide access to two of the locations associated with

these questions in accordance with its standard safeguards practices and its legal rights under

the Additional Protocol with Iran. Iran had at that point refused to provide any substantive 

engagement with the IAEA on these new questions, while at the same time denying the IAEA

access to the two locations as it reportedly undertook actions consistent with sanitization at one 

location — that is, measures possibly intended to prevent IAEA inspectors from ascertaining 

the purpose and use of the locations. In his opening remarks to the March 2020 IAEA Board of 

Governors meeting, the Director General of the IAEA reported that Iran’s failure to engage with 

IAEA requests for clarifications about its concerns wasadversely affecting the Agency’s ability to

provide credible assurance to the international community that there are no undeclared nuclear 

materials or activities in Iran, a concern he repeated in his June report. Each of these matters calls 

into question Iran’s compliance with its safeguards and NPT obligations.

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 41 
 

In June 2020, the IAEA Board of Governors made an important rebuke of Iran’s actions by adopting a 

resolution calling on Iran to fully cooperate with the IAEA without further delay, including by providing 

prompt access to the locations specified by the IAEA. On 26 August 2020, the IAEA Director General and

Iran reached agreement for Iran to provide access to one of the two locations in late August and to the 

other in mid-September. The IAEA will continue to report on whether its initial questions have been

addressed based on the information collected during these visits as well as its continued engagement 

with Iran. These accesses are only the first step in addressing the Agency’s safeguards concerns in Iran.

The United States has made clear that Iran’s delay and denial cannot become the norm for the global 

safeguards regime. Its full and timely cooperation with the IAEA remains essential. 

IRAN’S HISTORY OF NONCOMPLIANCE 

For years after the initial revelations in 2002 of covert Iranian nuclear activities, Iran hid evidence of its 

safeguards violations and refused to come clean in the face of overwhelming evidence of its past covert 

nuclear weapons-related activities. The IAEA has repeatedly stated that Iran’s prior obstruction seriously 

undermined the Agency’s ability to conduct effective verification as mandated by Iran’s Comprehensive

Safeguards Agreement. In November 2004, the IAEA issued a comprehensive report on Iran’s safeguards 

violations, stating, that “it is clear that Iran has failed in a number of instances over an extended period 

of time to meet its obligations under its Safeguards Agreement with respect to the reporting of nuclear 

material, its processing and its use, as well as the declaration of facilities where such material has been 

processed and stored.” The report was followed soon thereafter by a 2005 finding by the IAEA Board

of Governors that Iran was in noncompliance with its safeguards obligations; the Board subsequently

reported its finding of noncompliance to the UN Security Council in 2006.

The world has long known that Iran pursued nuclear weapons in the past, despite Iran’s continued 

denials. In 2015, the IAEA issued a report of its investigation into specific aspects of the “possible

military dimensions” of Iran’s previously hidden nuclear activities. That report concluded “that a range 

of activities relevant to the development of a nuclear explosive device were conducted in Iran prior to the 

end of 2003 as a coordinated effort, and some activities took place after 2003.” That year, the IAEA Board

of Governors decided to close consideration of the aspects of Iran’s program dealt with in the 2015 report 

and focus instead on Iran’s implementation of commitments under the JCPOA, while leaving open the 

possibility that the IAEA would need to use all of its authorities to pursue any new questions that arose.

The “nuclear archive” acquired by Israel — a collection of documents and data from Iran’s previous

nuclear weapons program, which the regime in Tehran preserved and hid at an undeclared location 

42 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

right 

amount of uranium 

enrichment for the 

world's leading 

state sponsor of 

terror is zero." 

SECRETARY OF STATE MICHAEL R. POMPEO 

NOVEMBER 18, 2019 

after 2003 — reveals new information about the extent and nature of Iran’s past nuclear weapons program than 

was previously publicly known, and necessarily renews questions about Iran’s current covert activities and future

nuclear intentions. As we look toward a comprehensive new deal that assures Iran cannot obtain nuclear weapons 

now or in the future, the very existence of this archive raises pressing questions — most obviously about Iran’s

intentions in storing records that could facilitate a resumption of nuclear weapons work. In light of the new 

concerns regarding Iran’s safeguards cooperation raised by the IAEA, the international community must ask 

itself what else the Iranian regime may be continuing to hide. 

THE WAY AHEAD 

As the IAEA continues its work to investigate these latest questions about Iran’s nuclear program, IAEA inspectors

deserve full-throated support. The international community must make clear to Iran that it faces a choice: provide 

immediate and full cooperation or face increasing pressure and isolation. There can be no other option. If any state 

were to be allowed to ignore the IAEA’s requests for clarifications and refuse access to the IAEA with no consequence,

the integrity and international confidence surrounding the global safeguards system would be compromised;

that the state currently in question has a woeful record over multiple decades of secretly undertaking nuclear

weapons work and hiding nuclear material from the IAEA only further amplifies the gravity of the situation. The

resolution adopted by the Board of Governors in June was a clear and necessary statement. What happens next is 

up to Iran. If Iran chooses to disregard the resolution and fails to provide clarifications and access without delay,

the Board must be prepared to take further action to hold Iran accountable to its obligations. If the international 

community hopes to truly put to rest its well-founded concerns about Iran’s nuclear intent, it is imperative that it 

support the IAEA as it professionally executes its critical mandate: ensuring that no undeclared nuclear activities 

are occurring in Iran and that no undeclared nuclear material is being hidden in violation of Iran’s safeguards 

agreement required under the NPT.

Robust verification is the core of the

global nonproliferation regime and 

the bedrock on which any durable 

diplomatic solution to Iran’s nuclear 

program must be built. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 43 
44 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 

CHAPTER SIX 

HUMAN 

RIGHTS 

ABUSES 

IN IRAN 

A university student in 

Tehran protests the regime 

as a smoke grenade is 

thrown by Iranian police. 
 

“Fulfill the first duty of any government. Treat your people with

the dignity to which every member of the family of mankind is 

entitled. Uphold your commitments under your own constitution, and 

international law. Act like a normal country. Unleash your people’s 

vast potential. We urge these things out of principle, but also as a 

message of common sense to the regime. True prosperity and stability 

will never come to Iran while you terrorize and jail your people.” 

SECRETARY OF STATE MICHAEL R. POMPEO, SPEECH AT THE STATE DEPARTMENT, 

DECEMBER 19, 2019 

INTRODUCTION 

Iran has an abysmal human rights record, and the outlook for the Iranian people remains 

dire. The Iranian regime continues to violate the human rights of those in its own territory, 

frequently targeting political and civil society activists as well as members of religious and 

ethnic minority groups. The regime’s legal systems fall woefully short of providing fair trial 

guarantees, and foreign and dual nationals, including U.S. citizens, are regularly targeted for 

arbitrary detention. The Iranian regime deploys its security forces against peaceful protesters 

and authorizes unprecedented levels of excessive force to suppress the universal human 

rights to freedom of expression, association, and peaceful assembly in Iran. In response to 

widespread protests that began November 15, 2019 after a fuel price increase, the government 

blocked almost all international and local internet connections for most of a week. In a brutal 

crackdown, security forces used lethal force to end the protests, killing up to 1,500 persons 

and detaining 8,600, according to international media reports based on sources within the 

regime. There have been no indications that government entities have pursued independent or 

impartial investigations into protester deaths. 

NO TOLERANCE FOR ACTIVISM 

The Iranian government targets its citizens for their peaceful civic activities and the exercise 

of freedom of opinion and expression and freedom of religion or belief. As of April 2020, there 

are more than 500 prisoners of conscience detained in Iran. The regime regularly targets 

journalists and restricts the online exercise of freedom of expression, including through the 

arrests of bloggers and social media users because of their online posts. Reporters Without 

Borders estimated in April 2020 that ten journalists and 12 citizen journalists remain in prison 

for their work and simply expressing their views. The regime also restricts the travel and 

speech of high-profile figures, including political candidates. Former presidential candidates 

Mehdi Karroubi and Mir Hossein Mousavi, as well as Mousavi’s wife, Zahra Rahnavard, have 

been kept under house arrest without formal charges since February 2011. On September 12 the 

Iranian regime executed champion wrestler Navid Afkari following a sham trial and reported 

torture, all for Afgari’s participation in a 2018 protest. 

AP PHOTO OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 45 
MINORITIES OF IR A N 

300,000 

Baha'is 

5,000-10,000 

e 

Sabean-Mandaeans 

1 million 

Yarsanis 

9,000 

Jews 

25,000 

Zoroastrians 

0 (1) 300,000-1 million 

Christians 

several million 

Muslims who 

practice Sufism 

F1gvPS arc- :>st mates as many m..., Jr1t ., pra: '1Cf> the r fa ,.. r se 0e1 lrrage <;1,.,l'. 'rSIO< >Ur:::e l <:; D ,:xi-t-nenl )f ~ta'€' 

The Iranian regime continues to crack down on activism of all kinds. Women’s rights 

activists, for example, have faced arbitrary arrests and detentions following protests that 

gained significant momentum in 2018 against compulsory hijab. Government agents arrested 

participants in these protests and their family members, and courts issued harsh and excessive 

punishments against many of them, including prison sentences of up to 20 years. For the 

past few years, the regime has also targeted independent trade unionists and journalists who 

protested peacefully regarding the right to associate freely and bargain collectively under 

internationally-recognized worker rights. In early April 2020, thousands of workers across 

sectors staged protests related to working conditions, unpaid wages, lost benefits and firings 

during the global COVID-19 pandemic, including bus drivers, factory, railroad, and coal workers, 

toll collectors and employees at the Persian Gulf International Transportation Company. As 

they speak out in greater numbers against the government’s corruption and mismanagement 

of Iran’s natural resources, environmental activists also have come under increasing scrutiny, 

and have been jailed, and even killed under suspicious circumstances while being detained. 

Some, like U.S.-Iranian dual citizen Morad Tahbaz, were jailed simply for working to preserve 

endangered wildlife species in Iran. 

Members of Iran’s numerous ethnic minority 

groups are also targeted by the regime, routinely 

facing harassment and arbitrary arrests and 

detention. Deaths in custody are often reported 

to occur under suspicious circumstances, and it 

has been reported that enforced disappearances of 

members of Iran’s Ahwazi, Azerbaijani, Balochi, 

and Kurdish communities, among others, continue 

to take place. The regime also continues to mistreat 

Afghan migrants, including through physical 

abuse by security forces, detention in unsanitary 

conditions, forced labor, and even forced separation from families. In May 2020, Iranian guards 

on the border of Afghanistan’s Herat Province reportedly tortured and drowned dozens of 

Afghan migrants who tried to cross the border into Iran. Credible reports from 2019 assert that 

the regime unlawfully recruited Afghan migrant children as young as age 14 to fight alongside 

Syrian regime forces in Syria, and that Afghan children have been killed fighting in the Syrian

conflict.

46 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

 

TARGETING MEMBERS OF RELIGIOUS MINORITY GROUPS 

The Iranian government represses religious freedom by directly engaging in the harassment and 

targeting of members of religious minority groups, particularly members of religious minority 

groups not recognized in the Islamic Republic’s constitution. Members of minority religious 

communities such as Baha’is, Christians, Jews, Sabean-Mandaeans, Zoroastrians, and Sunni 

and Sufi Muslims face widespread harassment, discrimination, and unjust imprisonment. Those

who profess atheism or are agnostic, non-believers, or religiously unaffiliated do not publicly

identify as such because they are at risk of arbitrary detention, torture, and the death penalty for 

“apostasy.” 

The regime has escalated persecution of 

members of the Gonabadi Sufi community,

jailing at least 300 Sufis in 2017-18 for protesting

the arbitrary detention of other Sufi activists.

There were no government investigations 

into the killings of at least 20 demonstrators, 

including numerous members of the Gonabadi 

Sufi community, during the 2017-18 protests.

In unjust trials, courts reportedly handed 

down sentences that included long prison 

terms, flogging, and internal exile. Human

Rights Watch characterized the trend as “one of the largest crackdowns against a religious 

minority in Iran in a decade.” Dozens of members of the Gonabadi Sufi community remain

unjustly imprisoned, including at least 10 women who are being detained in Shahr-e Rey Prison. 

Dr. Noor Ali Tabandeh, the Gonabadi Sufis’ 92-year-old spiritual leader, died on December 24,

2019 after almost two years of house arrest and denial of urgent medical care. 

Members of other religious minority groups continue to suffer harsh treatment as well.

Christians, particularly evangelicals and converts from Islam, experience high levels of arrests 

and detention. For example, in February 2019, the government arrested Matthias Haghnejad, the 

pastor of an underground Christian church in Rasht, following a church service and confiscated

phones belonging to church attendees. On September 23, the Tehran Revolutionary Court 

sentenced Haghnejad and eight members of the church to five years in prison after a cursory trial.

Media reported the Supreme Leader intervened in Pastor Haghnejad’s case to allow the court to 

Nasrin Sotoudeh 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 47 
human rights 

violations are worse 

than unacceptable. 

They're evil, and 

they're wrong." 

SECRETARY OF STATE MICHAEL R. POMPEO 

DECEMBER 19, 2019 

uphold his sentence in February 2020 without a hearing; the pastor remains in Evin Prison. Pastor 

Youcef Nadarkhani, a Christian convert and house church leader, along with three members of his

congregation, is serving a 10-year prison sentence for “assembly and collusion against national 

security,” organizing underground churches, and preaching “Zionist Christianity.” Individuals 

belonging to the minority Sunni population are reported to face particularly harsh government 

treatment, including extrajudicial killings, arbitrary arrest, and torture in detention, and the 

Iranian regime routinely denied Sunnis permission to build houses of worship on account of 

their faith. Baha’is face severe repression by the government because of their beliefs, including 

harsh jail sentences for members of their leadership, limited access to public education and 

employment, confiscation of property, closure of businesses, and desecration and destruction of

cemeteries. There were as many as 100 Baha’is in prison in Iran as of April 2020. 

The Iranian government also targets those who stand up for the human rights of members of 

religious minority groups. In June 2019, authorities took Shiraz city council member Mehdi 

Hajati to prison to serve a one-year sentence for “propaganda against the state” following his 

initial arrest in 2018 for advocating for the release of two detained Baha’is. The regime released 

48 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

him in January 2020, but arrested him again in March 2020 after he criticized the government’s 

response to COVID-19 over Twitter. 

NO FAIR TRIAL GUARANTEES 

Court proceedings in Iran regularly fall short of the country’s own legal standards as well as 

international obligations to ensure fair trials, including access to legal counsel and the right 

of criminal defendants to a review by a higher tribunal of their conviction and sentence. The 

government frequently subverts efforts to protect individual freedoms by limiting access to

lawyers and directly targeting human rights lawyers in particular. For example, the Iranian 

regime arbitrarily arrested prominent human rights attorney Nasrin Sotoudeh in June 2018 for 

providing legal defense services to women charged with crimes for not wearing hijab. In March 

2019, a revolutionary court convicted Sotoudeh on charges of endangering national security 

despite failing to provide evidence. The court sentenced her to thirty-eight years in prison and 

148 lashes. In March 2020, she went on hunger strike to protest the Iranian government’s keeping 

political prisoners incarcerated during the coronavirus crisis. In another example, in June 2019, 

the government reportedly hastily executed Benyamin Alboghbiesh, a 28-year-old Ahwazi Arab 

who was being held at a detention center in Ahwaz believed to be under the control of the IRGC. 

Authorities initially detained Alboghbiesh, along with his brother and mother, for several months 

beginning in March 2018, on unspecified national security accusations. All three individuals were

rearrested on May 26, 2019 and the IRGC reportedly notified Alboghbiesh’s family of his death on

June 26, 2019. There was no information available on any investigation into the circumstances of 

Alboghbiesh’s death. 

Detainees in Iran face appalling conditions in prison. Credible reports indicate the Iranian regime 

regularly uses torture and other cruel, inhumane or degrading forms of punishment, particularly 

in Iran’s notorious Evin Prison, which hosts many of Iran’s political prisoners. These allegations 

include amputations, blinding, and flogging. The Iranian government also uses physical and

mental torture to coerce confessions. Political prisoners are routinely denied access to medical 

care or family visitation. In May 2018, the U.S. Treasury sanctioned Evin Prison, and in December 

2019, the State Department identified Great Tehran Penitentiary and Qarchak Prison for their gross

violations of human rights. Great Tehran Penitentiary is known for its inhumane living conditions: 

unsanitary and overcrowded quarters, and rodent infestations, in addition to insufficient food,

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 49 
 

 

water, and medical care. There have been reports of protesters detained in November 2019 in Great 

Tehran Penitentiary being subjected to violent interrogations, arbitrary beatings, and even rape. 

Qarchak Prison remains Iran’s largest women’s prison and is known for regular assaults on inmates, 

inappropriate behavior of prison guards towards female detainees, and the mixing of mentally ill and 

violent inmates with prisoners of conscience, which continue to result in cases of rape and murder. 

Reflecting the dire circumstances of prisoners of conscience in Iran today, several suspicious “suicides”

occurred in Iranian prisons in 2018, including the death in custody of environmental activist Kavous

Seyed Emami. To date, no transparent or credible investigations have occurred, nor has any Iranian 

official been held accountable for these deaths. The regime frequently claims custodial deaths are the

result of drug addictions, although the individuals in question often do not have a history of drug use.

Families of executed prisoners do not always receive notification of their scheduled executions, and

if they do, it is often on very short notice. Families of those who died in custody similarly did not 

always receive timely notification of their death. Authorities frequently deny families the availability

to perform funeral rites or an impartial autopsy. The government also does not permit independent 

monitoring of prison conditions. 

The Iranian regime continues to deliberately target and detain U.S. citizens and other foreign 

nationals, particularly dual citizens, on fabricated national-security related charges. In June 2019, the 

UN estimated there were at least 30 cases of dual and foreign nationals whom authorities had arrested 

arbitrarily and subjected to mistreatment, including the denial of appropriate medical care. The Iranian 

regime has unjustly detained American citizens, including Siamak and Baquer Namazi, Morad Tahbaz,

and Michael White. 

In December 2019, the U.S. Treasury sanctioned two judges, Abolghassem Salavati and Mohammad 

Moghisseh, who preside over branches of the Iranian regime’s Revolutionary Court and who for years 

have punished Iranian citizens, and dual- and foreign-nationals for exercising their freedoms of 

expression or assembly. In many cases, these judges sentenced political prisoners to death. 

The Iranian regime claimed it furloughed roughly 100,000 prisoners and pardoned 10,000 prisoners 

– including some political prisoners with fewer than five years remaining on their sentences – to

mitigate the spread of COVID-19. Although it did grant medical furlough to wrongfully detained U.S. 

citizen Michael White, the regime has refused to do the same for Siamak Namazi or Morad Tahbaz, or to 

release the vast majority of its prisoners of conscience, including many members of religious minority 

50 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

Donald J. Trump 0 

@realDonaldTrump 

Three individuals were sentenced to death in Iran for 

participating in protests. The execution is expected 

momentarily. Executing these three people sends a 

terrible signal to the world and should not be done! 

#StopExecutionslnlran 

12:13 PM • Jul 15, 2020 • Twitter for iPhone 

30.3K Retweets 3.4K Quote Tweets 118K Likes 

Donald J. Trump 0 

@realDonaldTrump 

Hearing that Iran is looking to execute a great and 

popular wrestling star, 27-year-old Navid Afkarai, 

whose sole act was an anti-government demonstration 

on the streets. They were protesting the "country's 

worsening economic situation and inflation" ... 

5:06 PM • Sep 3, 2020 • Twitter for iPhone 

30K Retweets 2.5K Quote Tweets 108.5K Likes 

groups being held for exercising their faith. On April 17, 2020, eight UN special rapporteurs, joined by the 

UN Working Group on Arbitrary Detentions, called on Iran to release its remaining prisoners of conscience 

and dual and foreign nationals still being held despite serious risk of COVID-19 infection. 

CAPITAL PUNISHMENT 

Iran’s per-capita execution rate remains among the highest in the world, despite recent reforms to 

reduce the number of executions for drug-related offenses. The government executes persons for 

crimes that fall well short of Iran’s international obligation to reserve the death penalty for only “the 

most serious crimes,” and executions are often carried out in a manner contrary to Iran’s international 

human rights obligations. Iran executes juvenile offenders convicted of crimes committed before they 

were 18 years of age. The Islamic Republic’s penal code permits the execution of juveniles, starting at 

age nine for girls and 13 for boys. Nearly 90 juvenile offenders remained on death row as of 2019, and 

at least seven minors were executed in 2018. The regime killed at least 23 minors during the November 

2019 protests. 

HUMAN RIGHTS VIOLATIONS AND ABUSES BY PARTNERS AND PROXIES ABROAD 

Iran and its partners’ disregard for human rights extends well beyond its borders. In Syria, Iran-backed 

groups, including Lebanese Hizballah, have repeatedly killed civilians. Since the Syrian conflict broke

out in 2011, Iran has been among Bashar al-Assad’s most reliable partners, extending almost $5 billion 

in lines of credit to the Syrian regime and pouring resources and military personnel into the region. Iran 

has continued to prop up the Assad regime despite its egregious use of chemical weapons and the massive 

casualties among civilians. Tehran has deployed thousands of soldiers on the ground in Syria—including 

Islamic Revolutionary Guard Corps Ground Forces and Artesh (Iran’s regular army)—and utilizes locations 

like Tiyas and Shayrat airfields in Homs and Al-Kiswah base south of Damascus to launch attacks.

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 51 
In Iraq, Iran directly supports hardline elements associated with Iraqi Popular Mobilization Forces (PMF),

including the designated foreign terrorist organization Kata’ib Hizballah. PMF units officially report to

the Office of the Prime Minister, but, in practice, several units are also responsive to, and take orders from,

the IRGC. There are numerous reports of intimidation, arbitrary detentions, and disappearances of Sunni 

persons by Iran-backed Shia militias. For example, Kata’ib Hizballah is reported to have kidnapped and

intimidated local Sunni Arab residents in Diyala and Babil Governorates and prevented Sunni Arab internally 

displaced persons from returning to their homes. 

Iran continues to provide military and financial support to Houthi rebels in Yemen. Since 2012, Iran has

spent hundreds of millions of dollars on this endeavor. Iran’s support of the rebels is helping to prolong the 

country’s civil war, frustrate United Nations peace efforts, and worsen an already devastating humanitarian

tragedy. According to the NGO Save the Children, Iran-backed Houthi militants reportedly engaged in the 

intentional targeting of dozens of hospitals in Yemen.

52 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 53 

CHAPTER SEVEN 

IRAN’S 

THREAT TO 

CYBERSECURITY 
“We will not tolerate the theft of U.S. intellectual property, or intrusions into 

our research institutions and universities. We will continue to systematically 

use our sanctions authorities to shine a light on the Iranian regime’s malicious 

cyber practices, and hold it accountable for criminal cyber-attacks.” 

UNDER SECRETARY OF THE TREASURY SIGAL MANDELKER, MARCH 2018 

INTRODUCTION 

The Islamic Republic is a leading threat actor in cyberspace, using espionage, propaganda, and 

other malicious cyber activities to influence events, shape foreign perceptions, and counter 

perceived threats. Iranian cyber activity is contrary to the internationally accepted norms 

of responsible state behavior in cyberspace undermines other states’ security interests, and 

regularly threatens access to an open, interoperable, reliable, and secure Internet. Similar to 

the regime’s support for proxies, Iran prioritizes plausible deniability for its malicious cyber 

activities, making attribution difficult in many cases. However, substantial evidence exists of 

the regime’s malign activity in cyberspace. 

FOREIGN TARGETS 

The Islamic Republic of Iran has developed its cyber capabilities with the intent to surveil and 

sabotage its adversaries, which is contrary to international norms of responsible state behavior 

and threatens international stability. Over the past decade, public reporting indicates that the 

Iranian regime has conducted cyber operations targeting governments as well as commercial and 

civil society entities in the United States, Israel, Saudi Arabia, and Qatar, among others. The IRGC is 

frequently the main force behind these cyber operations, though they often enlist hackers outside

of government. 

The Iranian regime typically focuses on “soft” targets, such as more vulnerable commercial entities, 

critical infrastructure, and non-governmental organizations. In the Middle East, Iranian cyber 

operations have focused heavily on Saudi Arabia and other Gulf states. In a 2012 cyber operation 

that was widely attributed to the Iranian regime, tens of thousands of computers used by Saudi 

Aramco and Qatar’s RasGas were compromised and deemed inoperable, resulting in hundreds of 

millions of dollars in damages. An updated version of that malicious cyber attack was again carried 

out between 2016 and 2017, resulting in the destruction of Saudi public and private databases, 

including those belonging to General Authority for Civil Aviation and the Central Bank. 

54 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

WANTED ~ BY THE FBI CONSPIRACY TO COMMIT COMPUTER INTRUSIONS; CONSPIRACY TO COMMIT WIRE 

FRAUD; COMPUTER FRAUD - UNAUTHORIZED ACCESS FOR PRIVATE FINANCIAL GAIN; 

WIRE FRAUD; AGGRAVATED IDENTITY THEFT 

CAUTION 

On Febroary 7, 2018, a grand jury sitting in the United States Distriet Court for the Southern District of New Yol1c, 

Indicted nine Iranian nationals for their alleoed involvement in computer lntn.1slon, wire fraud, and aggravated Identity the~ offenses. AS alleged In the Indictment, the men were Involved In a scheme to obtain unauthorized 

access to computer systems, steal proprietary data from those systems, and sell that stolen data to Iranian customers,lncludlngthelranlangovernmentandlranlanuniversilles.Eachindividualwasaleader,contractor; associate, hacker for hire, or affiliate of the Mabna Institute, a private government contractor based in the Islamic 

Republic of Iran that performed this worl( for the Iranian government, at the behest of the l slamk Revolutionary 

Guard Corps. Victims of the scheme induded approximately 144 universltie,s in the United State,s, 176 foreign unlversltle,s In 21 countries, five federal and state government agencies In the United States, 36 private companies In 

the United States, 11 foreign private companies, and two international non-governmental organizations. 

THESE INDIVIDUALS SHOULD BE CONSIDERED AN INTERNATIONAL FLIGHT RISK 

If you have any Information concerning this case, please contact your local FBI office, or the neare5t 

American EmbaHy o r Con5ulate. 

Field Office: New Yori( 

www.fbi.gov 

Outside the Middle East, the Iranian regime has 

targeted the United States and other western 

countries through cyber-enabled espionage and 

sabotage. In 2016, the U.S. Attorney’s Office for the

Southern District of New York and the National

Security Division’s Counterintelligence and 

Export Control Section unsealed an indictment 

alleging that between late 2011 and mid-2013, 

IRGC-linked entities conducted a coordinated 

distributed denial-of-service (DDoS) campaign 

against the U.S. financial sector. Iran’s DDoS

campaign temporarily disabled bank websites, 

prevented customers from accessing their 

accounts online, and collectively cost the victims 

tens of millions of dollars as the banks worked 

to neutralize and mitigate the effects of the campaign. The indictment also alleged that in 2013,

one of the Iranian hackers involved in the DDoS campaign also illegally accessed the industrial 

control system of a dam just 25 miles north of New York City. Despite the Iranian regime’s efforts

to obscure its role in these incidents, the U.S. government indicted several Iranian nationals and 

charged that these crimes were carried out by groups with ties to the IRGC. Additionally, in 2017, 

the U.S. Department of Treasury designated involved Iranians under Executive tOrder 13694, for 

engaging in significant malicious cyber-enabled activity, noting that the individuals worked for

private computer security companies affiliated with the IRGC. These examples shine a light on the

Islamic Republic’s extensive malicious cyber activity. 

The Islamic Republic’s malicious cyber activities are not limited to commercial entities or critical 

infrastructure. In March 2018, the U.S. Attorney’s Office for the Southern District of New York

unsealed an indictment charging nine individuals associated with the Mabna Institute with 

conducting massive coordinated cyber intrusions from 2013 to 2017. On behalf of the IRGC, the 

Mabna Institute attacked the computer systems of approximately 144 U.S.-based universities and 

at least another 176 universities located in twenty-one other countries. Mabna Institute hackers 

also obtained unauthorized access to the computer systems of U.S. federal agencies, U.S. states, the 

United Nations, the U.N. Children’s Fund, and many domestic and foreign private sector companies. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 55 
0 Twitter Safety 0 

@TwrttarSafety 

Working with our industry peers today, 

we have suspended 284 accounts from 

Twitter for engaging in coordinated 

manipulation. Based on our existing 

analysis, it appears many of these 

accounts originated from Iran. 

8:01 PM - 21 Aug 2018 

~ newsroom 

We've removed 652 Pages, groups and accounts for coordinated inauthentic 

behavior that originated in Iran and targeted people across multiple internet 

services in the Middle East, Latin America, UK and US. FireEye, a cybersecurity finn, 

gave us a tip in July about "Liberty Front Press," a network of Facebook Pages as well as 

accounts on other online services. They've published an initial analysis and will release a 

full report of their findings soon. We wanted to take this opportunity to thank them for 

their work 

r Fr 

The indictment charged that the Mabna Institute stole more than 31 terabytes of documents and 

data in addition to intellectual property and the contents of email inboxes. The U.S. Department 

of Treasury designated the Mabna Institute and the individuals involved under Executive Order 

13694, for engaging in significant malicious cyber-enabled activities. During the announcement of

these actions, former U.S. Department of the Treasury Under Secretary for Terrorism and Financial 

Intelligence, Sigal Mandelker, said, “Iran is engaged in an ongoing campaign of malicious cyber 

activity against the United States and our allies. The IRGC outsourced cyber intrusions to the 

Mabna Institute, a hacker network that infiltrated hundreds of universities to steal sensitive data.”

DOMESTIC TARGETS 

Within its borders, the Iranian regime develops and uses cyber capabilities to silence and 

weaken its critics, whether ordinary Iranians, members of the civil society, or elected 

government officials. IRGC-affiliated entities have also targeted the Islamic Republic’s own 

diplomatic corps, with reports indicating that even Iran’s Foreign Minister, Javad Zarif, was 

among those targeted. In addition to professionals and government officials, IRGC-affiliated 

entities have targeted Iran’s reformist clerics and moderate political leaders and activists with 

cyber campaigns that have included espionage, defacement, and credential theft. 

The Iranian regime utilizes its cyber capabilities to deny Iranians unrestricted access to the 

Internet, including by blocking access to social media sites and applications and conducting 

internet shutdowns. The regime funds a massive online censorship apparatus and restricts 

access to satellite services. Not lost on the Iranian people is the irony that while the regime 

cracks down on social media platforms like Twitter, regime officials such as Supreme Leader 

Ali Khamenei and Foreign Minister Zarif, as well as journalists sympathetic to the regime, 

regularly use the platforms to spread its propaganda to the outside world. In August 2018, 

56 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

Facebook, Twitter, and other U.S. companies reported the removal of more than 1,000 pages, 

groups, and accounts they assessed were engaged in spreading disinformation on behalf of 

the regime. The scope of the campaign was wide. On Facebook alone, it included over 600 

pages and targeted users in the United States, UK, Middle East, and Latin America. In May 2020, 

Facebook dismantled another network of over 500 accounts spreading disinformation that 

were connected to the state-owned Islamic Republic of Iran Broadcasting (IRIB). 

The Iranian regime has recently taken even more extreme measures, including an almost total 

Internet shutdown during nationwide protests in November 2019, curtailing access for nearly 

all of its 80 million citizens for more than a week. The digital darkness permitted the Iranian 

regime to commit human rights violations and abuses beyond the scrutiny of the international 

community in the most lethal crackdown on anti-government protests in the history of 

the Islamic Republic. According to Reuters sources in Iran’s Ministry of the Interior, these 

violations and abuses included the killing of as many as 1,500 protestors and bystanders as well 

as the arrests of 8,600 people. The Iranian government still has not released the names or the 

official number of peaceful protestors killed by security forces. Many of the detainees remain 

imprisoned without official charges for taking part in the November protests. 

In the last year, the U.S. Department of Treasury designated several individuals and entities 

under sanctions authorities in connection with serious human rights abuses, censorship, or 

related activities in Iran. They include Abolhassan Firouzabadi, the Secretary of Iran’s Supreme 

Council of Cyberspace, who played a leading role in the regime’s ongoing efforts to block access 

to social media sites and applications such as Telegram in Iran, and Mohammad Javad AzariJahromi, who served as Iran’s Minister of Information and Communications Technology during 

the November 2019 Internet shutdown. The Supreme Council of Cyberspace is a designated 

entity for its role in overseeing the censorship of speech and the media in Iran. On September 

17, 2020 the Department of Treasury also designated the Iranian entity Advanced Persistent 

Threat 39, its front company Rana Intelligence Company, and 45 associated individuals for their 

use of malicious cyber attacks and tools to target and monitor Iranian citizens, particularly 

dissidents, journalists, former government employees, environmentalists, students, refugees, 

and employees of international nongovernmental organizations. They also targeted hundreds 

of individuals and entities from more than 30 different countries from across Asia, Africa, 

Europe, and North America, including approximately 15 U.S. companies. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 57 
58 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 

CHAPTER EIGHT 

ENVIRONMENTAL 

EXPLOITATION 

Dried up riverbed of 

the Zayandeh Roud 

river in Isfahan, Iran. 
 

“We will not tolerate the theft of U.S. intellectual property, or intrusions into 

our research institutions and universities. We will continue to systematically 

use our sanctions authorities to shine a light on the Iranian regime’s malicious 

cyber practices, and hold it accountable for criminal cyber-attacks.” 

UNDER SECRETARY OF THE TREASURY SIGAL MANDELKER, MARCH 2018 

INTRODUCTION 

Corruption and mismanagement at the highest levels of the Iranian regime have produced 

years of environmental exploitation and degradation, with tragic results for the Iranian people. 

According to the United Nations Development Program’s 2019 Human Development Report, Iran 

scored in the bottom third of countries in most environmental categories. The unwillingness of 

Iran’s leaders to confront the challenges before them is moving the country toward pervasive 

environmental crisis. Nikahang Kowsar, an Iranian geologist living in exile, remarked, “when 

people lose their lands they lose everything, and that means they aren’t scared of anything. The 

water crisis is real and killing the country today. There are bad agricultural policies and bad 

water governance. It is like a time bomb.” 

Limited access to potable water and poor air quality are among the top concerns for many 

Iranians today. These long-standing environmental issues have also contributed to the tragedy 

of the COVID-19 outbreak in Iran and compounded the problems confronting the Iranian people. 

Hundreds of thousands of Iranians have pre-existing respiratory conditions due to years of 

breathing unhealthy air. As a result, they face heightened health risks if they are infected by the 

COVID-19. Meanwhile, water consumption has increased by as much as 40 percent during the 

outbreak, accelerating the water crisis. As Iranians speak out in growing numbers about these 

hardships, the regime has responded with force to stifle dissent and obscure its own corrupt 

practices. As one prominent Iranian scholar said, “the people at the top are too incompetent 

and too corrupt to care.” 

The regime’s failure to address critical environmental issues such as air pollution and 

potentially irreversible depletion of its water resources strikes at the heart of its inability to 

respond to the broader needs of its people. As it throws billions of dollars into misadventures 

abroad fueled by the reckless Islamic Revolutionary Guard Corps (IRGC), the Iranian regime 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 59 
 

 

neglects the most basic needs at home, including the ability of its people to drink safe water and 

breathe clean air. When Iranian environmental activists mobilize to address what are among 

the most fundamental issues in any society, they are harassed, arrested, or die under suspicious 

circumstances. 

ON THE BRINK OF CRISIS 

The Iranian people feel the pain of this regime’s environmental mismanagement in many ways, 

but limited access to water is among the most pronounced. According to a United Nations report, 

water shortages in Iran are so acute that agricultural livelihoods are no longer sustainable. The 

regime’s failure to implement sound water policies has led to aquifers being depleted at potentially

irreversible rates. Continued mismanagement, such as inefficient irrigation techniques,

decentralized water management, continued subsidies for water-intensive crops like wheat, 

and excessive dam building exacerbate this trend. Iran’s history of unsustainable water use and 

groundwater pumping has also been worsened by a years-long drought, which, according to the 

director of Iran’s Drought and Crisis Management Center, affects approximately 96 percent of the

country. Significantly increased water consumption during the COVID-19 outbreak has further

exacerbated the water crisis in Iran. 

The Iranian government has identified water as one of the country’s foremost problems but

continually fails to respond appropriately. President Hassan Rouhani previously proclaimed 

the Iranian government would address the people’s grievances and in 2015, Supreme Leader 

Khamenei called on the government to “manage climate change and environmental threats such

as desertification, especially dust pollution [and] drought.” A senior IRGC commander noted in

a public speech in 2018 that water would play a key role for Iran’s national and regional security. 

Despite public proclamations, however, little has been done to address the problem in the two years 

since those remarks. 

The current water crisis should come as no surprise. Former Iranian Agriculture Minister Issa 

Kalantari warned five years ago that, if left unresolved, the water crisis would force 50 million

Iranians to migrate in the next 25 years – more than 60 percent of the population. Reports estimate

that over 16 million Iranians have already fled the countryside and are now living in shantytowns.

Hardships resulting from a lack of water are often worst in rural areas, where many of Iran’s 

historically marginalized and oppressed ethnic and religious minorities reside. 

Since 1979, Iran has built about 600 dams. By comparison, before the revolution, Iran had seven 

60 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

 

: Voice of America, Associated Press, Reuters 

Water Shortages Spark 

Protests in I ran 

 Extreme Drought 

 Severe Drought 

 Moderate Drought 

Abnormal Dryness 

• Areas of water 

shortage protests 

ancient dams and 14 modern ones. While it is unclear how 

much has been spent on the dam projects, much of the 

money has reportedly lined the pockets of IRGC affiliates.

Abadollah Abdollahi, the commander of Khatam al-Anbiya

Construction Headquarters, the IRGC’s engineering arm, said

in 2017 that 62 dams, accounting for half of Iran’s damming 

capacity, were constructed by his firm. Poor planning and

years of drought have rendered many of the dams useless. 

In many cases the dams have actually contributed to further 

environmental damage and the loss of much-needed water 

from already marginalized communities living on the social 

and economic margins. 

Many Iranians point to Lake Urmia in northwest Iran as a textbook example of the regime’s 

mismanagement. Once the second largest saltwater lake on earth, Lake Urmia shrunk considerably 

over the years and until recently was about twenty percent of its previous size. According to 

reports, the government began building numerous dams around it in the 1990s, slowly siphoning 

off its water supply or diverting it to inefficient projects. The beneficiaries of these projects were

contractors from the IRGC, individuals close to the Ministry of Energy, and large agribusinesses, 

who all got rich as the lake drained. 

AP PHOTO 

Paddle boats sit on the parched Zayandeh Roud riverbed, 

in Isfahan, Iran. As their livelihoods are destroyed by 

years of the regime’s mismanagement of water, farmers 

have increasingly taken to the streets in protest. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 61 
AP PHOTO 

Tractors sit idle during a strike by Iranian farmers. 

Air pollution also remains a severe problem in Iran. In Tehran, schools were closed for days in 

February 2018 and November-December 2019 because the volume of hazardous particles in the air 

were six to nine times higher than WHO-recommended levels. In late 2019, one Iranian woman told 

the Associated Press, “Breathing is really difficult for me. What can I do? If I don’t leave home, how

can I take care of my daily jobs? But when I come out of the house, the air pollution really hurts me.”

In a sign of the seriousness of the situation, some politicians have proposed relocating the capital 

due to Tehran’s air pollution. According to Iranian health officials, 30,000 Iranians die every year

because of health complications from air pollution in major cities. In addition to the tragic human 

toll, ordinary Iranians pay a heavy economic cost as well. In 2018, Tehran Municipality’s Deputy 

Director of Transportation and Traffic, Mohsen Pour Seyed Aghaei, said the city’s air pollution costs

Iran over $2.6 billion a year. According to a 2016 World Bank report, the cities of Zabol, Bushehr, 

and Ahvaz are among the most polluted in the world. For much of the year, Ahvaz is blanketed with 

yellow smog and its residents suffer from respiratory and skin ailments. Across Iran, hundreds of

thousands of Iranians suffer from respiratory ailments, which put them at much greater risk if they

contract the coronavirus. 

THE IRANIAN PEOPLE SPEAK OUT 

Rampant government corruption and 

poorly implemented environmental 

policies have upended the lives and 

livelihoods of millions of Iranians, leading 

to protests throughout the country. These 

protests have been based largely in towns 

around central Isfahan and western 

Khuzestan province. The Center for 

Human Rights in Iran (CHRI), a leading 

NGO focused on human rights, said that 

towns and villages around Isfahan have 

been hit so hard by drought and water diversion that many have emptied out. Anger at the 

Rouhani administration’s plans to divert water from Isfahan has led to clashes with police. The 

Isfahan Chamber of Commerce has reported that the drying out of the Zayandeh Roud river 

basin has deprived nearly two million farmers of their income. In 2018, protests by farmers in 

the town of Qahderijan, near Isfahan, turned violent as security forces opened fire on crowds 

and killed at least five people.

62 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
 

Khuzestan, an oil-rich province with a large population of ethnic Arabs, has suffered from largescale desertification, industrial waste, and excessive dam projects, which many have said were built 

only to benefit IRGC contractors. Large protests had broken out in Ahvaz, the capital of Khuzestan 

province. Slogans by protestors outside the municipal governor’s office in 2018 included, “Ahvaz is 

our city, clean air is our right,” and “breath, breath, breath, the least of our demands in the world.” 

A constant grievance of the Ahvazis is that their water is being diverted to projects that line the 

pockets of agribusinesses associated with the regime. Hundreds of Ahvazis have taken to the streets 

to protest the regime’s exploitation of their land and water. Many have been arrested, with reports 

of protestors being killed by security forces. 

In June 2018, protests in Khorramshahr, another city in Khuzestan province, also turned violent 

with at least one protester reportedly shot. Clashes with security forces followed weeks of water 

shortages, in which the local population had no access to safe water. Local water supplies were 

reportedly undrinkable due to high salinity and mud content, making hundreds of people sick. 

According to Mehr News Agency, Khorramshahr’s water was too dirty even for cooking or laundry. 

The people were forced to buy water on the black market or stand in line in sweltering heat for water 

tankers to arrive. The protestors chanted that government officials were “useless” and “robbed us 

in the name of religion.” One Iranian political commentator writing on social media summed up 

the frustration, writing, “For how long should the people of Khorramshahr and Abadan scream they 

have no water? Their date-tree farms have been destroyed, their wetlands have dried up, and dust 

has injured their throats. 

REGIME TARGETS ENVIRONMENTAL ACTIVISTS 

As Iranians have become increasingly aware of the scope of their country’s environmental problems, 

the regime has harshly cracked down on organizations working to address them. In 2018, along 

with dozens of environmentalists, Kavous Seyed-Emami, an Iranian-Canadian university professor 

and director of the Persian Wildlife Heritage Foundation (PWHF), was arrested. Seyed-Emami, 

falsely accused of being a spy for the United States and Israel, later died in custody under mysterious 

conditions, which Iranian authorities attributed to suicide. His family’s request for an autopsy was 

denied. In May 2018, another 40 environmentalists were arrested. Most remain unjustly detained or 

have died in detention, a warning to all who once worked in this relatively safe and non-politicized 

field. In February 2020, an Iranian appeals court upheld 10-year prison sentences against six of 

the innocent PWHF wildlife conservationists, including a U.S. citizen, despite the fact that they 

were working with and had received permits from the Iranian government’s own environmental 

officials. Hadi Ghaemi, the executive director for the Center for Human Rights in Iran, notes that 

“Iran desperately needs experts to help guide the government out of the country’s environmental 

crisis that mismanagement and climate change have produced.” Instead, it has put those experts 

in jail. 

OUTLAW REGIME: A CHRONICLE OF IRAN’S DESTRUCTIVE ACTIVITIES | 63 
64 | IR AN AC TION GROUP, U.S. DEPARTMENT OF STATE 
This report was produced by the Iran Action Group 

and Iran Office of the Bureau for Near Eastern Affairs.

U.S. DEPARTMENT OF STATE | STATE.GOV