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IRAN’S ISLAMIC REVOLUTIONARY GUARD CORPS:

FUELING MIDDLE EAST TURMOIL

HEARING

BEFORE THE

COMMITTEE ON FOREIGN AFFAIRS 

HOUSE OF REPRESENTATIVES

ONE HUNDRED FOURTEENTH CONGRESS

FIRST SESSION

DECEMBER 2, 2015

Serial No. 114–135

Printed for the use of the Committee on Foreign Affairs

(

Available via the World Wide Web: http://www.foreignaffairs.house.gov/ or

http://www.gpo.gov/fdsys/

(II)

COMMITTEE ON FOREIGN AFFAIRS 

EDWARD R. ROYCE, California, Chairman 

CHRISTOPHER H. SMITH, New Jersey 

ILEANA ROS-LEHTINEN, Florida 

DANA ROHRABACHER, California 

STEVE CHABOT, Ohio 

JOE WILSON, South Carolina 

MICHAEL T. MCCAUL, Texas 

TED POE, Texas 

MATT SALMON, Arizona 

DARRELL E. ISSA, California 

TOM MARINO, Pennsylvania 

JEFF DUNCAN, South Carolina 

MO BROOKS, Alabama 

PAUL COOK, California 

RANDY K. WEBER SR., Texas 

SCOTT PERRY, Pennsylvania 

RON DESANTIS, Florida 

MARK MEADOWS, North Carolina 

TED S. YOHO, Florida 

CURT CLAWSON, Florida 

SCOTT DESJARLAIS, Tennessee 

REID J. RIBBLE, Wisconsin 

DAVID A. TROTT, Michigan 

LEE M. ZELDIN, New York 

DANIEL DONOVAN, New York 

ELIOT L. ENGEL, New York 

BRAD SHERMAN, California 

GREGORY W. MEEKS, New York 

ALBIO SIRES, New Jersey 

GERALD E. CONNOLLY, Virginia 

THEODORE E. DEUTCH, Florida 

BRIAN HIGGINS, New York 

KAREN BASS, California 

WILLIAM KEATING, Massachusetts 

DAVID CICILLINE, Rhode Island 

ALAN GRAYSON, Florida 

AMI BERA, California 

ALAN S. LOWENTHAL, California 

GRACE MENG, New York 

LOIS FRANKEL, Florida 

TULSI GABBARD, Hawaii 

JOAQUIN CASTRO, Texas 

ROBIN L. KELLY, Illinois 

BRENDAN F. BOYLE, Pennsylvania

AMY PORTER, Chief of Staff THOMAS SHEEHY, Staff Director

JASON STEINBAUM, Democratic Staff Director 

(III)

C O N T E N T S 

Page

WITNESSES 

Mr. Ali Alfoneh, senior fellow, Foundation for Defense of Democracies ............. 5

Mr. Scott Modell, managing director, The Rapidan Group .................................. 57

Mr. Daniel Benjamin, Norman E. McCulloch Jr. director, The John Sloan 

Dickey Center for International Understanding, Dartmouth College (former 

Ambassador-at-Large and Coordinator for Counterterrorism, U.S. Department of State) ....................................................................................................... 65

LETTERS, STATEMENTS, ETC., SUBMITTED FOR THE HEARING 

Mr. Ali Alfoneh: Prepared statement ..................................................................... 7

Mr. Scott Modell: Prepared statement ................................................................... 59

Mr. Daniel Benjamin: Prepared statement ........................................................... 67

APPENDIX 

Hearing notice .......................................................................................................... 102

Hearing minutes ...................................................................................................... 103

The Honorable Brad Sherman, a Representative in Congress from the State 

of California: Material submitted for the record ............................................... 105

The Honorable Gerald E. Connolly, a Representative in Congress from the 

Commonwealth of Virginia: Prepared statement .............................................. 112

The Honorable Christopher H. Smith, a Representative in Congress from 

the State of New Jersey: Questions submitted for the record .......................... 114

(1)

IRAN’S ISLAMIC REVOLUTIONARY GUARD 

CORPS: FUELING MIDDLE EAST TURMOIL 

WEDNESDAY, DECEMBER 2, 2015

HOUSE OF REPRESENTATIVES,

COMMITTEE ON FOREIGN AFFAIRS,

Washington, DC. 

The committee met, pursuant to notice, at 10:09 a.m. in room 

2172, Rayburn House Office Building, Hon. Edward Royce (chairman of the committee) presiding. 

Chairman ROYCE. This hearing will come to order. Iran and its 

Islamic Revolutionary Guard Corps have really been on a roll, and 

that is the subject of this hearing today. And I want to thank our 

witnesses for being with us. 

Let me start by just giving my observations on recent events. So 

over the last few weeks, the IRGC has tested a new long-range ballistic missile, and that test is in violation of the U.N. sanctions. 

They also released a video of dozens more of these ICBMs staged 

in an underground bunker. The IRGC Quds Force has stepped up 

efforts in support of the murderous Assad regime in Syria, and we 

have seen those attacks on the ground. And by all accounts it appears that the IRGC has prevented international investigators 

from assessing the information needed to conclusively finish a report on the possible military dimensions of Iran’s nuclear program. 

It is on IRGC territory, so. 

From nuclear proliferation to support of international terrorism, 

to human rights abuses, the IRGC has made Iran the global menace that Iran is today. The IRGC is responsible for squashing democracy movements at home, for spreading the Iranian regime’s 

revolutionary ideology abroad, and for sparking turmoil throughout 

the Middle East. Its forces operate again, independent of Iran’s regular army. It answers directly only to one man, Iran’s Supreme 

Leader. 

While most understand the role of the IRGC in fueling conflict 

throughout the region, its hidden grasp on the Iranian economy is 

just as important. People don’t realize that most of the major businesses were nationalized basically and turned over to the IRGC to 

control. So they have about 30 percent of the Iranian economy. The 

IRGC has been labeled Iran’s ‘‘most powerful economic actor’’ by 

the U.S. Treasury Department, which has noted its deep reach into 

‘‘critical sectors of Iran’s economic infrastructure.’’ The IRGC’s biggest, largest entity is this construction arm which controls 800 affiliated companies. That it also controls billions of assets, is often 

I think lost, on the public here. The fact that much of the money 

2

that is held in escrow that when released is going to flow through 

the IRGC, I think that point has been lost on us. These activities 

in turn fund Iran’s ballistic missile program, its military activities, 

its regional aggression. 

Of course none of this appears to disqualify Iran from receiving 

sanctions relief under a nuclear deal that allows Iran to keep a 

path to a weapon. Within months Iran could have access to tens 

of billions in new cash as this money comes out of escrow. And this, 

what I call a ‘‘stimulus package,’’ this stimulus package for the Supreme Leader will only strengthen the IRGC. And as trade restrictions with Iran loosens, that in turn of course, will increase its access to dual-use technology for its military and its missile programs. 

An IRGC with more cash means more threats to the United 

States and our allies. Even when Iran’s sanctions were fully in 

place, Iran’s support to the Assad regime in Syria totaled every 

year $6 billion. I am going to guess now that that is going to go 

up. IRGC support on the ground, combined with Russian air support, worsened the already horrible conflict in Syria, drawing in 

foreign fighters and giving ISIS room to grow. 

And more resources for the IRGC also promises to create problems in Iraq, and in Yemen—where the guards are backing Shia 

militias responsible for violence against Iraq’s Sunni minority and 

against the Houthi rebels fighting Saudi forces in Yemen. This 

combined with Iran’s continued support for terrorist groups such as 

Hezbollah and Hamas—and I will just remind people that the 

other story that surfaced a few months ago, was that the IRGC will 

now try to transfer—and I think this is in direct violation of the 

agreement—try to transfer guidance systems, GPS guidance systems, to the 90,000 rockets and missiles that are already in 

Hezbollah’s inventory, and has also offered to resupply the inventory that Hamas spent in the Gaza war and rebuild the tunnels to 

boot. So, the major source of instability in that region is the IRGC. 

In selling its flawed nuclear deal to Congress, I believe Secretary 

Kerry testified, that there would be no let up on Iran’s terror and 

destructive regional behavior. That was my takeaway as I listened 

to his words, but I want to now understand how that is going to 

be followed with action. We have yet to see any effective strategy 

from the administration to pushback against IRGC’s regional advances which have emboldened Iran, which have undermined our 

allies, and this morning we will hear from our witnesses on what 

such a strategy might look like, and how Congress can help. 

And I will now turn to the ranking member for any opening comments he may have. Mr. Engel. 

Mr. ENGEL. Thank you, Mr. Chairman. Thank you for calling this 

hearing, and I want to welcome all witnesses to the Foreign Affairs 

Committee. In the wake of the Paris attacks, the world is focused 

on the fight against ISIS, and announcements yesterday by the 

Secretary of Defense, about new measures that we are taking to 

fight ISIS are welcome, and I think that there is obviously a lot 

more to go. 

We are reminded of the ongoing threat posed by terrorism, and 

so I am glad our committee is focusing on the world’s leading state 

sponsor of terrorism, Iran. I want to echo the concerns the chairVerDate 0ct 09 2002 12:17 Feb 17, 2016 Jkt 000000 PO 00000 Frm 00006 Fmt 6633 Sfmt 6633 F:\WORK\_FULL\120215\97751 SHIRL
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man just mentioned, the fact that Iran is the leading state sponsor 

of terrorism. And in the past several years when Iran had no 

money, it still found money to be the leading state sponsor of terrorism. 

Under the deal negotiated with Iran, they will be awash in cash. 

They will have lots of money, and imagine how much destruction 

they can do in support of terrorist activities and terrorism. That is 

very deeply troubling to me, and it was and has been throughout 

our discussions about U.S. relations with Iran and the entire nuclear deal with Iran. 

Now, since ceding power in 1979, the Iranian regime has built 

an ugly record supporting terrorist proxies. Let’s remember this: 

The seizure of our Embassy in Tehran 1979, the bombings of our 

Embassy in the Marines barracks in Beirut in the early 1980s, killing nearly 300 Americans, the attacks in Buenos Aires that targeted Israel’s Embassy and a Jewish community center, the 

Khobar Towers bombing in Saudi Arabia, which also cost American 

lives, and just a few years ago, a plot to assassinate the Saudi Ambassador right here in Washington. And every one of these horrible 

events is covered in Iran’s fingerprints. 

The Iranian regime uses the Quds Force, an elite unit of the Islamic Revolutionary Guard Corps, as a tool to support terrorist 

proxies and spread instability throughout the region. And in recent 

years, Iran’s leaders have doubled down on this reprehensible policy, and let’s just look at what is going on today. In Syria, Iran is 

committed to propping up the Assad regime and now is working 

with Putin in pursuit of that objective. So much for P5+1. It has 

mobilized Hezbollah and organized militias composed of Shi’ite 

fighters from Iraq, Afghanistan, and Pakistan to support the regime. It has also deployed hundreds if not thousands of the Quds 

Force fighters in a direct combat roll. And the result of Iran’s actions, a longer, more costly war, a graver humanitarian crisis, and 

more and more innocent lives lost. 

In Iraq, the Quds Force continues to support hard-core Shia militias, some of which were involved in targeting American troops 

during the Iraq war. These violent groups drive sectarian division, 

making it harder to build the inclusive Iraqi Government necessary 

to help defeat ISIS. And in Yemen, Iran’s support for Houthi rebels 

has fomented a bloody civil war that is now spilling over Yemen’s 

borders. Chaos in that country has hampered U.S. counterterrorism efforts, focused on AQAP, one of the most dangerous Al 

Qaeda affiliates. Iran also supports Shi’ite elements in other Gulf 

states, including Bahrain and Saudi Arabia, that are involved in efforts to destabilize those governments. And, of course, the Iranian 

regime has repeatedly expressed its support for wiping Israel off 

the map. By providing a steady flow of missiles to Hezbollah and 

arms to Hamas, Iran is a grave threat to our close ally Israel. 

Finally, it is important to note that Iran’s support for terrorism 

is not just limited to the Middle East. Just this past week Kenyan 

security forces arrested two men suspected of working with the 

Quds Force to plan attacks in that East African nation. This dangerous pattern is one of the reasons I remain concerned about the 

Iran nuclear deal. Once the nuclear sanctions on Iran are lifted, 

the regime will have access to tens of billions of dollars in new 

4

wealth, and I will bet my money that some of it will end up in terrorist coffers. 

So I agree with what the chairman said: Iran was a leading and 

has been a leading state sponsor of terrorism when they had no 

money. Imagine now when they are going to have sanctions lifted, 

how much money they have which will directly go to terrorist activities. So in my view, these factors all point to the likelihood of 

greater case and instability in the years ahead. So today I hope we 

can discuss what can be done to counter Iran’s maligned activities 

in the region beyond. 

I want to mention just a few areas I think are most important. 

First, we must aggressively enforce terrorism, proliferation, and 

human rights sanctions on Iran. This includes existing sanctions on 

the IRGC, and we should continue to designate all entities connected to Iran’s support for terrorism. We need to send a clear message that working with Iranian firms linked to the IRGC is risky 

business. 

Next, we need to keep making our case to our EU allies and others that Hezbollah as an organization, not just its military wing, 

is a terrorist organization and should be treated like a terrorist organization. Our friends in Europe try to split hairs by saying that 

only part of Hamas is a terrorist organization. The other part is a 

humanitarian organization. Baloney. It is a terrorist organization, 

and we should say it, and our allies should say it. 

We should ramp up our efforts to track the resources Iran receives as a result of sanctions relief. We need to know just how 

much money Iran is funneling to these violent groups. We need 

final closer cooperation with our Gulf allies on defense intelligence, 

counterterrorism, maritime security, and other key areas. And, 

lastly, we need to maintain a very close security relationship with 

Israel, our closest ally in the region. This includes the negotiation 

of a new memorandum of understanding, or MOU, that reflects the 

new security environment in the region. 

We must also redouble our commitment to supporting missile defense systems, including Iron Dome, so that Israel is able to defend 

itself. And I hope going forward Congress and the administration 

do what is needed to pursue those aims. I look forward to ideas and 

insight from our witnesses, and I yield back. 

Chairman ROYCE. Thank you, Mr. Engel. So this morning we are 

joined by a distinguished panel. We have Mr. Ali Alfoneh. He is a 

senior fellow at the Foundation for Defense of Democracies. He is 

an expert on civil military relations in Iran as well as the author 

of ‘‘Iran Unveiled: How the Revolutionary Guard is Transforming 

Iran from a Theocracy into a Military Dictatorship.’’

Mr. Scott Modell is managing director of the Rapidan Group, and 

prior to this he served at the Central Intelligence Agency where he 

conducted operations throughout the Middle East, including as part 

of the post-9/11 operations in Afghanistan. 

And we have Ambassador Daniel Benjamin with us. He is the 

Norman E. McCulloch director at Dartmouth College. Previously 

Ambassador Benjamin served as the Ambassador-at-Large and Coordinator for Counterterrorism where he was the principal advisor 

on counterterrorism to Secretary of State Clinton. 

5

And we welcome our panel. Without objection, the witnesses’ full 

prepared statement will be made part of the record here. And 

members will have 5 days to submit statements or questions or any 

extraneous materials for the record. And Mr. Alfoneh, please summarize your remarks. 

STATEMENT OF MR. ALI ALFONEH, SENIOR FELLOW, 

FOUNDATION FOR DEFENSE OF DEMOCRACIES 

Mr. ALFONEH. Good morning, Mr. Chairman, Ranking Member 

Engel. Thank you very much for your kind invitation, and thank 

you for providing me with the opportunity to share my analysis 

with you, along with the members of this distinguished panel. 

You mentioned, sir, the Iranian revolution of 1979 as a historical 

event of the past, and that is, indeed, the American perception of 

the revolution. In Iran, however, the leaders of the Islamic Republic, they subscribe to Trotsky’s theory of a permanent revolution. 

For them the revolution of 1979, is not a historical event of the 

past which took place and is over. From their perspective, the revolution is permanent, is happening every single day, and the engine 

of that revolution, Mr. Chairman, is the Islamic Revolutionary 

Guard Corps. 

This is also why I do not share the optimism of some of my colleagues here in Washington who believe that the emergence of 

President Rouhani, his promise of engaging in bilateral talks with 

the U.S., the nuclear negotiations and the deal which was negotiated, and even emergence of a common threat of Islamic State, 

is going to make life easier in the Islamic Republic of Iran. Because 

of the very simple reason that President Rouhani and his technocratic government, they are not in charge of the portfolios which 

are of interest to us today. The Islamic Revolutionary Guards 

Corps is in control of Iran’s regional policies. 

Let’s take a quick look at the problems that I see. First of all, 

as the chairman and the ranking member pointed out, the Revolutionary Guard not only is in control of the policy, they have also 

benefitted most financially from the nuclear deal. Much of the 

money which the Government of the Islamic Republic has received 

is going to be channeled to companies owned by the Revolutionary 

Guards, or directly to the military budget of the Revolutionary 

Guards. Apart from this, the Islamic Revolutionary Guard is pursuing policy objectives in the Middle East region which are in contrast and totally opposed to U.S. objectives. 

The United States desires to see a future of Syria in which 

Bashar al-Assad, who is personally responsible for destruction of 

his own country, does not play a role. The Revolutionary Guard’s 

goal is to keep Bashar al-Assad in power, and to that effect they 

are trying to mobilize, and they have managed to mobilize, a panShi’ite international brigade to Syria, and that deployment of 

course is increasing the risk of spread of the conflict in Syria to 

other countries. The home countries of those militia men, which is 

primarily Lebanon, Iraq, Afghanistan, and even distant and geographically far away Pakistan. 

The United States desires to fight ISIL. That is not the case with 

the Revolutionary Guards. From their perspective, it is fine that 

there is an enemy called the Islamic State. Which is not really 

6

threatening the existence of the Islamic Republic of Iran, and at 

the same time, is the only alternative to Bashar al-Assad and his 

dictatorial regime in Syria. This is why we see that the Iranian 

forces and unfortunately also the Russian forces in Syria, are not 

targeting the ISIL threats. They are targeting the secular opposition to Mr. Assad. 

We also see that these mechanisms are perpetuating the war in 

Syria. Because of the exact presence of the Revolutionary Guards 

in Syria, we see more and more Sunni radicals from all over the 

world travelling to Syria to fight the Shia threat, and to counter 

it, and this is, of course, something which is perpetuating the conflict and keeping ISIL, in its existence, it is prolonging the existence of ISIS. 

So some of the policies which I believe the United States could 

apply in order to counter those measures is first and foremost to 

attack those units of the Revolutionary Guards which were deployed to Syria by designations. Those groups of the Revolutionary 

Guards, they are engaged in support to Mr. Assad’s regime. They 

are engaged in terrorist activities, and they should be designated 

as such. And also I believe that the United States should never accept demands of the Islamic Republic of Iran or others that Mr. 

Bashar al-Assad should be kept in power in Syria because that 

would only serve the interests of the Revolutionary Guards. And 

will perpetuate not only the war in Syria, but also the revolution, 

the permanent revolution which I mentioned in the beginning of 

this presentation. Thank you, Mr. Chairman. 

[The prepared statement of Mr. Alfoneh follows:]

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STATEMENT OF MR. SCOTT MODELL, MANAGING DIRECTOR, 

THE RAPIDAN GROUP 

Mr. MODELL. Chairman Royce, Ranking Member Engel, members 

of the committee, fellow panelists, good morning. Thank you for the 

opportunity to speak today. 

As the Middle East continues to burn, the U.S. and its allies 

have numerous reasons to believe that Iran really hasn’t changed 

all that much since President Rouhani took office in September 

2013. President Rouhani was elected to rescue Iran’s economy. 

That was his mandate, and he is on his way to achieving that. 

Rouhani may appear moderate next to outspoken hardliners in the 

IRGC, but I believe that both continue to be driven by the same 

revolutionary ideals that inspired the Ayatollah Khomeini to create 

the Islamic Republic in 1979. Rouhani has been outspoken in his 

disagreement with some of the methods chosen by the IRGC, but 

there is little that he can do, as Mr. Alfoneh has said, to stop the 

IRGC. 

The recent unwillingness of the Obama administration to weaken 

the IRGC seems to me incompatible with its apparent belief that 

the JCPOA will strengthen moderates in Iran who favor internal 

reform and rapprochement with the West. I think it is worth it to 

look at some of the core missions of the IRGC, particularly it is 

Quds Force in the region, some of which are not regularly mentioned, others which were mentioned by the chairman and the 

ranking member. 

In addition to some of the lethal activities that were suggested 

and the more destabilizing military activities that the IRGC engages in, they are heavily involved in covert influence, grass roots 

foundation building across the region, via culture, socioeconomic, 

political, and business organizations, and in my testimony I have 

given a graphic of some of the ways in which they approach the 

whole of government, grass roots, bottom-up approach to building 

influence across countries, which is sectarian driven. 

The IRGC is also working very closely with Lebanese Hezbollah 

to build a global commercial apparatus that is designed to acquire 

new technologies, assist with covert action programs, create new 

sources of revenue, and actually add to Iran’s existing threat facilitation networks. The importance of covert action to Iran’s revolutionary export strategy has been clear from day one, particularly 

in the last 4 years. 

Since May 11, there have been dozens of terrorist plots attributed to Iran, from an attempt to murder the Saudi Ambassador in 

the U.S., to a foiled bomb plot in Kenya, covert action continues to 

remain a key tool of Iranian foreign policy. 

The Quds Force is engaged in various nonkinetic activities, as I 

said, and they will continue to play a role in its external resistance 

mission, whether it is front companies religious foundations, cultural centers, and so on. 

Some of the ways in which IRGC is destabilizing the region have 

already been mentioned. I would like to point out a couple of things 

that are given less attention I think, and that is the IRGC is part 

of a sectarian repopulation strategy across the region. Few people 

are talking about the IRGC’s leading role in Iran’s strategy to alter 

the sectarian balance across the region, beginning in the Levant. 

58

So when and where it can, Iran-sponsored militias are creating 

Shia support bases across Iraq and Syria and even getting to the 

point of pressuring Sunni’s entire communities to relocate. It perpetuates Sunni distrust, hatred, and organized opposition to Iran, 

Iran-backed militias, and even Shiites. 

Bahrain is mentioned also. I think it is a particular problem. The 

propaganda war between Manama and Tehran continues to intensify as a result of persistent messaging on the part of Iranian 

hardliners that Bahrain actually belongs to Iran. The recent arrest 

of 36 Bahraini Shiites on charges of spying for the IRGC, the 400 

or so others in prison on similar charges, and the dozens of incidents over the years, almost always lead back to the IRGC. 

In Saudi Arabia while President Rouhani and Foreign Minister 

Zarif have made some attempt at diplomatic outreach to the 

Saudis, the IRGC has been on a much more confrontational path, 

both openly and covertly. Saudi Government continues to uncover 

IRGC attempts to penetrate and militarize Shia communities in its 

oil-rich eastern province. The IRGC’s Department 1000 operating 

out of Basrah continues to play a key role in these and other efforts 

against the Kingdom. 

I look forward to talking about some of my policy recommendations as well. Thank you for the opportunity. 

[The prepared statement of Mr. Modell follows:]

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Chairman ROYCE. Thank you. Ambassador. 

STATEMENT OF MR. DANIEL BENJAMIN, NORMAN E. 

MCCULLOCH JR. DIRECTOR, THE JOHN SLOAN DICKEY CENTER FOR INTERNATIONAL UNDERSTANDING, DARTMOUTH 

COLLEGE (FORMER AMBASSADOR-AT-LARGE AND COORDINATOR FOR COUNTERTERRORISM, U.S. DEPARTMENT OF 

STATE) 

Ambassador BENJAMIN. Chairman Royce, Ranking Member 

Engel, distinguished members of the committee, thank you very 

much for the opportunity to speak today about Iran’s Revolutionary 

Guard Corps, and more broadly, the country’s destabilizing behavior in the Middle East. As a prefatory note though, I want to mention that the United States has over recent decades compiled a 

record of success in dealing with Iran. We have certainly had our 

losses, such as at Khobar Towers in Beirut in 1983, but overall our 

Nation has, together with our partners in the region and around 

the world, prevented the Islamic Republic from causing far greater 

damage to regional stability and the security of some of our closest 

friends. 

And today I am convinced that we are on a course to continue 

the success and, indeed, to strengthen security in the region 

through the JCPOA, which if Iran fulfills its obligations, will end 

the country’s pursuit of a nuclear weapon for at least 15 years. 

As President Obama has said on many occasions, this deal does 

not address all of Iran’s behavior, nor was it intended to, but it 

does address one of the foremost security challenges of our time, 

and that is Iran’s nuclear aspirations. And as we consider the other 

ways in which Iran challenges us, we should be mindful of the 

JCPOA achievement and leery of anything that would undermine 

it, and we should also recognize that, the problems we face would 

be, without the JCPOA, far more problematic if we were facing off 

against a nuclear-armed Iran. 

The charge has been made that Iran is going to get a vast influx 

of cash with which to carry out terrorist attacks and subversion. 

We certainly have well-founded fears of Iranian plotting, and we 

must continue to show vigilance, but the argument I think needs 

to be examined in two ways. First, how likely is it that Iran will 

devote massive resources to such a course, and second, to what extent does the Islamic Republic’s behavior, current behavior, represent a continuation of earlier conduct. It seems to me that the 

hypothesis is flawed in two ways—In several ways excuse me. 

First, the Iranian leadership’s goal in negotiating the JCPOA 

was to improve economic conditions at home that were eroding support for the regime. So much seems clear from the rhetoric and the 

behavior of Iran’s leaders. It would follow, therefore, that the bulk 

of the money will be used to ameliorate domestic concerns. According to press reports, the U.S. intelligence community has arrived 

at the same conclusion. And I would add here that Iran usually 

makes rational calculations about advancing its interests, and having invested the time, energy, and political capital in the JCPOA, 

it is undoubtedly aware that a new and enhanced campaign of terrorism or subversion would risk scuttling the agreement. 

66

Second, as has been mentioned before, the country has never restricted resources for its foreign policy, especially not for such activities as its direct support to the Assad regime and Iranian fighting in Syria. I think that suggests that it considers those areas to 

be well-funded. It is unlikely to spend vast new sums. It will certainly continue pouring money into those activities, but it is also 

important to remember that terrorism and subversion are inexpensive activities, and we have learned that through hard experience. 

Iran, of course, remains by significant margin the foremost state 

sponsor of terrorism, and we have seen no indication that there has 

been any change in the belief that terrorism is a legitimate instrument of policy. But what I would like to note is that, to pick up 

on what Mr. Modell was saying, you know, the sectarian dimension 

of all this requires an awful lot of attention, and I would suggest 

that the situation that we confront today is far different from one 

that we have seen in the past. And I think it is one we really need 

to examine closely. Whether we are talking about what is going on 

in Yemen, in Bahrain, in Syria, these reflect dynamics in the region that have changed dramatically. 

And it is important to recognize also that the trigger for sharpening in revival of sectarian tensions was our invasion of Iraq, 

which destroyed the region’s fragile equilibrium and upended the 

regional politics. And the second trigger was the Arab Spring, 

which opened up a new opportunity in Syria for Sunnis to even the 

score having lost the capital in Baghdad. 

There is a lot more to say, but I want to just close my remarks 

by saying that I don’t think there is any expectation that Iran is 

going to be a good global citizen, but I think that the United States 

is well postured to deter and to prevent increased subversive and 

terrorist actions through a raft of different sanctions regimes, both 

as well as U.N. Security Council resolutions that enable all kinds 

of actions to constrain Iran, and I think that we are in a good position to manage the problems that we face. Thank you very much. 

[The prepared statement of Ambassador Benjamin follows:]

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Chairman ROYCE. Let me go to a question that I think impacted 

all of us back in October. October 15 you had the missile launch, 

the most advanced missile yet in the IRGC’s inventory, and 2 

months later there has still been no action in the wake of that test, 

which I think clearly violated United Nations Security Council Resolution 2331. 

So Mr. Modell, if I could ask you here, about next steps, because 

given that the EU sanctions are going to be lifted against the traditional home of their ballistic missile programs, which is the IRGC 

Air Force at their Ghadar missile command, what are the chances 

that the administration will actually implement sanctions against 

Iran for this advancement in its ballistic missile program? 

Mr. MODELL. I don’t see any indications that there is a good 

chance that the Obama administration is going to take any punitive actions with regard to this ballistic missile launch. It was 

clearly in violation of U.N. Security Council Resolution 1929 and 

the updated resolution as you said. I think it is worth pointing out 

that the IRGC’s aerospace force has not gotten a lot of attention 

when you look at the IRGC’s role in externalizing this revolution 

throughout the region. And if you look at the development of Iran’s 

missiles, it has been a key part of their conventional military buildup over the last 20 years, particularly since the end of the IranIraq war. They believe it goes hand in hand with their idea of selfsufficiency in promoting the revolution. 

And I think when you look at the pace at which they are developing new missiles, the pace at which they are trying to use precision-guided technology, not only in the missiles that you mentioned 

that are going into the hands of Hezbollah and Palestinians, it 

could be used against Israel but throughout the region, I think it 

is something that needs to be addressed. And I——

Chairman ROYCE. Let me change directions then, because obviously with the IRGC being the most probable economic actor in the 

equation there in the government in Iran, what is the risk of any 

company looking at reentering the Iranian market, from major 

Asian firms in Japan or in South Korea with U.S. exposure to 

small companies in eastern Germany? What is the risk of doing 

business with the IRGC? 

Mr. MODELL. One of the things I would say, I am glad it was 

mentioned that companies going back, particularly the European 

companies going back into Iran, should be well advised to look at 

the fact that the IRGC is not going away, and the IRGC has deeply 

penetrated every corner of every industry in Iran for the most part. 

And I think that one of the things that needs to be talked more 

about is the fact that IRGC-linked companies and businesses have 

already started the process of hiding their IRGC links in anticipation of trying to get into business deals with European companies 

and Asian companies and others who are going to be reentering 

Iran. There is a process underway, among IRGC individuals and 

entities, that are sanctioned, to ensconce themselves in companies 

that are clean, in business deals that are clean, so that means erasing old contracts, erasing records and business registries, and different things. So I think it is a very dangerous proposition for any 

company going back into Iran not knowing exactly who they are 

going to be dealing with. 

75

The other issue, Mr. Chairman, that I would mention is over the 

last decade, you have seen a terrible problem in the growth of corruption in Iran. So if you believe that the Foreign Corrupt Practices Act should be any deterrent for companies going back in, 

again, Oil Minister Zanganeh 2 days ago, at the launch of a global 

meeting, to talk about the reemergence of the Iran’s oil and gas industry, had to go out of his way to say any companies doing business with Iran who are asked to pay bribes, those contracts will be 

null and void. He had to go out of his way because it is a tremendous problem, and the IRGC is at the heart of that problem. 

So, what I would advise companies going back into Iran, one 

thing, what has emerged is there are a number of data analytic 

firms here in DC and elsewhere that are specializing in due diligence, so the idea of enhanced, know-your-customer measures that 

will need to be taken for anybody going back into Iran will require 

outside support. 

Chairman ROYCE. Let me ask Mr. Alfoneh the last question here, 

and that goes to the two goals that you talked about in your testimony that they are seeking in Iran. 

First, they are working to keep Bashar al-Assad in power by coordinating Shi’ite militias to maintain control over western Syria. 

By the way, I would add to that something that Mr. Modell mentioned in his testimony, but I have been briefed on the fact that 

they are even bringing in militia from Hezbollah and their families 

into Sunni-dominated neighborhoods in Damascus and running the 

Sunni population out as they basically do an ethnic cleansing campaign. But that is part of it. 

And secondarily, you said they are combatting secular opposition 

in Syria while maintaining ISIS is a worse alternative to al-Assad. 

Can you explain how the IRGC is accomplishing that dual mission? 

Mr. ALFONEH. Yes, Mr. Chairman. If we look at the combat fatalities of the Revolutionary Guards in Syria, we see that the place 

of death is usually the places which have been bombed by the Russian Air Force, so in other words, the Revolutionary Guard is in 

practice acting at the infantry force, the ground force, of Russia. 

And we also know from U.S. Government sources that Russia is 

not bombing the Islamic State. Russia is bombing the secular opposition to Bashar al-Assad’s regime, and then after Russia has 

bombed those specific areas, we see an influx of Revolutionary 

Guards members going into those areas, and also the place of death 

is reported in those exact areas. So unfortunately, this is a very, 

very cynical strategy that the Assad regime and the Revolutionary 

Guards are pursuing in combination. 

Concerning your comment about the role of the Revolutionary 

Guards and the economy, Mr. Modell is absolutely right. If you look 

at the assets of the Revolutionary Guards on Tehran’s stock exchange, it is more than $17 billion worth of companies registered 

on Tehran’s stock exchange that the Revolutionary Guard has purchased during the time that the government of President 

Ahmadinejad was privatizing these companies. So the Revolutionary Guards’ claims that its front companies are private sector 

actors and they do not belong to the public sector. This is why they 

were allowed to bid for ownership of those companies, and they acVerDate 0ct 09 2002 12:17 Feb 17, 2016 Jkt 000000 PO 00000 Frm 00079 Fmt 6633 Sfmt 6633 F:\WORK\_FULL\120215\97751 SHIRL
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quired, they purchased those companies on Tehran’s stock exchange. 

Just to mention one example, Iran Telecommunication, which is 

the largest phone company in Iran, was purchased by the Revolutionary Guards in 2009 for $7 billion. Back then in 2009, the military budget of the Revolutionary Guards on an annual basis was 

only $5 billion, but they could pay for the company, the phone company, $7 billion cash because of all the other economic activities 

that they have. 

Chairman ROYCE. I assume that makes it easier for the IRGC to 

monitor citizens’ communications as well. We will go to Mr. Engel. 

Mr. ENGEL. Thank you. Thank you very much, and thank you for 

your excellent testimony. Ambassador Benjamin, I agree with you 

when you said that the invasion of Iraq really changed, upset the 

apple cart, and really in hindsight, we eliminated Iran’s major adversary. Therefore, we helped unfortunately to make Iran the hegemony power in the region, and I think that is very, very true. 

But I couldn’t disagree with you more when you say that the fact 

that Iran has been the leading state sponsor of terrorism when 

they had no money doesn’t necessarily mean that now that they 

have money, they will continue or increase their terrorist activities. 

I think that logic says that if the goal of the Iranian regime, the 

Revolutionary Guards and the entire regime, is to sponsor terrorism to destabilize the region, now that they have money and it 

is not going to be a sacrifice, they are going to use it for terrorism. 

When the Rial, their currency was in the toilet, when their people clamored for more freedoms or more things that they needed, 

Iran, the government, the regime didn’t care. The regime made 

sure, though, that groups like Hezbollah and even Hamas, which 

of course is the other side of the Sunni-Shia spectrum, had enough 

money. So now that Iran has money and it is not going to be so 

painful, I think that it is very easy to imagine, and it is not imagination, that they will have more money to support more terrorism. 

And finally, you had mentioned the Security Council resolutions. 

I don’t think that Iran cares about Security Council resolutions. 

They had a resolution had been passed at a Security Council which 

demanded, I think there were six or seven or five resolutions that 

Iran stop spinning centrifuges, that Iran stop spinning. And one of 

the problems I had with the negotiations with Iran is that we 

didn’t make a precondition of our sitting down with them and talking with them that they stop spinning. And once we didn’t demand 

that as a prerequisite to sit down with them, you knew that in the 

conclusion of any agreement we had with them, the demand that 

they stop spinning, as the Security Council resolution said, would 

not be a final decision in any kind of agreement. So I think we essentially ceded that. 

I just want to mention this because Members here are very 

thoughtful, and some voted no, and some voted yes. I voted no. I 

respect every Member’s thoughtfulness. But I think that what really bothers me is I think that we have almost stamped the fact that 

the Iranian regime is going to be there for a long time to come. We 

have helped them. We have given them all kinds of relief, and any 

hope we had of regime change so the Iranian people could live in 

77

a democracy I think, went out the window because frankly regimes 

that have lots of money are able to use it. 

So I just wanted to point that out, and if you care to answer, I 

would be grateful. 

Ambassador BENJAMIN. Mr. Engel, you have put a lot of issues 

on the table. Let me just try to answer a few of them quickly. You 

mentioned your skepticism about Security Council resolutions. 

Well, the issue is not what Iran thinks of them. It is that they empower the international community to take certain actions. And so 

for example, at the end of September, a weapons system from Iran 

to Yemen was seized on the high seas under the provisions of the 

relevant Security Council resolution. So the point is we can have 

an effect, a real material, concrete effect on Iran’s ability to play 

the kind of role that everyone here deplores because of those instruments. 

You mentioned the money issue. So I think that there is a few 

things to say. One is that there is basically an absorption issue. 

There is just not that many different things to spend the money on. 

They have been spending lots of money on these activities for a 

long time. They will pour more in. I expect to see that more resources will make their way in particular to Syria. And by the way, 

although we all deplore what is going on in Syria, I think it is important to remember that Iran’s policy there is fundamentally a 

conservative one. They are trying to preserve the status quo. Trying to preserve their one important ally in the international community. And——

Mr. ENGEL. I might say——

Ambassador BENJAMIN. I am sorry? 

Mr. ENGEL. I might say they are trying to preserve it, and in trying to preserve it, they are using the terrorist group Hezbollah to 

do the fighting and to guarantee that they can preserve it, so that 

is another element of support for——

Ambassador BENJAMIN. Without a doubt, and they have been 

funding Hezbollah for many, many years, and I don’t dispute that 

in any way. I am just saying that, first of all, one of the main constraints has been manpower and not money, and, you know, you 

don’t need $50 billion to fund your terrorism or subversive activities. 

I do find it hard to imagine why Iran would make a quantum 

leap in its provocative behavior if that would throw into doubt the 

future of the agreement that they worked so hard to get. I think 

that the Iranian leadership definitely saw that their position was 

eroding as a result of public discontent. And so I think that those 

resources will primarily, although not exclusively, go to ameliorate 

social conditions and to restart the economy. 

I would just also point out, because several people have mentioned Hamas, that Hamas has been essentially cut off by Iran because Hamas refused to support Iran’s policy toward Syria. And I 

think that this is an absolutely perfect illustration of how the sectarian upheaval in the region has changed the rules of the game. 

And we should remember that King Salman, the new king of Saudi 

Arabia, didn’t find time to come to the United States for a meeting 

at Camp David with President Obama, but he did have time to entertain a Hamas delegation in the hope of bringing Hamas under 

78

the Saudi wing. So things are in dramatic flux, and I think we 

need to think very hard and fast about what America’s role is in 

the context of this sectarian conflict. 

Finally, just on the issue of IRGC benefits from the deal, you 

know, it has gone unmentioned that there is still a raft of U.S. unilateral sanctions on IRGC, Treasury sanctions, which if we want 

can have secondary effects and which are levied against IRGC for 

terrorism, for proliferation, for human rights violations, and the 

like. And I do believe that actually companies around the world 

recognize that we have these sanctions, that we may reassert them 

in a stronger sense, that is in a secondary sense, and therefore they 

are going to be cautious about getting involved with IRGC-dominated entities. Thank you. 

Mr. ENGEL. I just want to ask one quick question to anybody who 

would care to answer. We have seen some recent reports that have 

been unconfirmed that the head of the Quds Force, Soleimani, was 

severely injured in Syria. Have any of you heard that? Have you 

had any confirmation or lack of? 

Mr. ALFONEH. Sir, we only have heard the rumors, but he seems 

to be alive, and of course the Islamic Republic propaganda machinery is trying constantly to communicate the message that Major 

General Soleimani is still alive, so there is no news of the contrary 

and certainly not proof. 

Mr. ENGEL. Thank you. Thank, Mr. Chairman. 

Chairman ROYCE. So we go to Ileana Ros-Lehtinen of Florida. 

Ms. ROS-LEHTINEN. Thank you so much. Excellent hearing, Mr. 

Chairman and ranking member. As we have heard, and I agree 

with the chairman and the ranking member that the administration downplays concerns that Iran will use the sanctions relief it 

gets from the nuclear deal for its terror activities, instead of arguing that the money will be used to shore up a failing Iranian economy. But as we have heard, the IRGC is one of the major actors 

in the Iranian economy with a presence in nearly every sector. 

It has a particularly large presence in the same sectors that the 

administration is arguing that sanctions relief will go to: Construction, infrastructure, energy, finance. The administration is telling 

only one small part of the story and that we have only scratched 

the surface of what we should be sanctioning, including designating 

the IRGC and the Quds Force as foreign terrorist organizations. 

And, Mr. Alfoneh, in your written testimony, you mention your 

colleague Dr. Ottolenghi, who testified at our Middle East subcommittee on this IRGC issue 2 months ago, and you both argue 

that the administration should be reporting on the IRGC in much 

greater detail, including the subsidiaries of IRGC parent companies, the companies that have an IRGC controlling interest, and 

the exact nature of the IRGC support to Assad. How effective can 

our remaining sanctions be if we are not targeting the IRGC subsidiaries and commercial interests? 

And for Mr. Modell, you highlighted the nonkinetic activities of 

the Quds Force, including its work in setting up religious organizations, foundations, cultural centers, and testified that progress on 

U.S. efforts to counter this irregular warfare has been very limited. 

And as Mr. Duncan continually points out, we have seen a lot of 

Iranian activity in the Western Hemisphere throughout the Middle 

79

East to set up these types of influence, destabilization, recruitment 

centers, but very little effort by us in the United States to counter 

this. 

What is Iran’s strategic goal in all of this, and where has it been 

more active, and why have our efforts to counter Iranian influence 

in this arena been so ineffective? Mr. Alfoneh. 

Mr. ALFONEH. Thank you. This is a very, very important point 

that you are raising, madam. The Revolutionary Guard, of course, 

is trying to hide its assets. There are so many front companies that 

the Revolutionary Guard is constantly creating, and, therefore, the 

Treasury here in the U.S. must, of course, also be extremely vigilant and be careful that they do not create companies that we are 

unaware of. 

One of the good allies of the U.S. in this cat-and-mouse game of 

course is what remains of the private sector in Iran because they 

certainly do believe that the Revolutionary Guard is trying to make 

their business impossible in Iran. And they also would be willing 

to cooperate identifying some of those companies of the Revolutionary Guards which is constantly popping up. 

And as you also pointed out, many of these activities are going 

to, you know, the money that flows into Iran goes back to the Revolutionary Guards because of their activities, particularly in the construction sector. Khatam al-Anbia construction headquarters of the 

Revolutionary Guards is the largest contractor in the entire Islamic 

Republic of Iran. Most of the public projects, development projects, 

in Iran, are handed over to the Khatam al-Anbia construction base 

on no-bid basis. So the private sector has no say. If they do participate in those projects, it is as subcontractors to the Revolutionary 

Guard. 

Ms. ROS-LEHTINEN. Thank you, and I am going to interrupt you 

here to give a minute to Mr. Modell. 

Mr. MODELL. Thank you for your question. One of the things is, 

when you think about the way that Iran externalizes revolution, 

when you think about when Iran goes into a place like Iraq or 

Syria or Yemen or anywhere else, there is a lot of building from 

the ground up. So when I mentioned religious centers, mosques, 

cultural centers, and so forth, I think that that is a firm belief that, 

like Mr. Alfoneh suggested, it is more than just about terrorism 

and subversion. It is about actually altering the fabric of the places 

where they want to have control and influence in. 

So when they go and do this, it requires a lot of money. So, you 

know, when you think about the money that it takes to do this, one 

thing I would mention is a lot of people are speculating as to 

whether or not the Iranian Government is going to take this windfall that it is going to get from sanctions relief and direct it into 

the IRGC or the MOIS and other security elements of the government. I think, and Mr. Alfoneh might be among them, people have 

written about the fact that after the negotiations began in 2014, 

the IRGC budget went up. The Ministry of Intelligence budget 

went up, and this was just in anticipation of sanctions relief. This 

was publicly stated. This was publicly declared. 

So I think if you are asking yourself how the Iranians are going 

to spend the money, they have already been very clear in indicating it. But again it is not—and I agree with Ambassador BenVerDate 0ct 09 2002 12:17 Feb 17, 2016 Jkt 000000 PO 00000 Frm 00083 Fmt 6633 Sfmt 6633 F:\WORK\_FULL\120215\97751 SHIRL
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jamin that it is cheap to pull off a terrorist attack or to do subterfuge, but we are talking about something that is much more transformational than that. 

Ms. ROS-LEHTINEN. Thank you very much. Thank you, Mr. 

Chairman. 

Chairman ROYCE. Thank you, Ileana. Mr. Brad Sherman of California. 

Mr. SHERMAN. Thank you. Terrorism may be cheap. War is expensive. One of the things that happened, just as soon as it was 

clear to those observing Congress that this deal would go through, 

and Iran would get its hands on $130 billion is Russia deployed 

sources to Syria. There was like a day between when I concluded—

and I watch Congress—that this deal would be implemented and 

when Russia began its planning and deployment. I won’t ask you 

gentlemen whether there is any proof that Iran is paying some or 

all of Russia’s costs because my guess is that the Iranians don’t 

share that information with you. 

Ambassador Benjamin when you say that we are on course to 

continue our success, you may be out of step with what Americans 

are seeing and feeling about the Middle East. Mr. Alfoneh, you say 

that Iran is moving from a theocracy to a military dictatorship. In 

a real short answer, can you tell me: Is the next generation going 

to be run by clerics who are true scholars of Islam based in Qom, 

or are guys with guns going to select the next grand Ayatollah? 

Mr. ALFONEH. Thank you for the fantastic question, sir. About 

the next generation of rulers in Iran, I think that Ayatollah Khomeini, the Supreme Leader of Iran, has committed the worst mistake any civilian politician can make, and it is that he is systematically using the Revolutionary Guards to suppress his domestic opposition. And of course what happens is that when you invite a 

military organization to participate and intervene in domestic politics, you cannot throw them out again because they have guns and 

you are a civilian and do not have. 

Mr. SHERMAN. Got you. I do want to agree with some that have 

pointed out the dangers of the Quds Force and the Iranian regime 

in general. The Shi’ite alliance has killed hundreds of thousands of 

innocent people in Syria and killed far more Americans in Iraq, Afghanistan, and the Marines in Beirut, than ISIS has ever aspired 

to. The difference is that ISIS when they kill 50 people, put it on 

YouTube. When Iranian-paid-for barrel bombs kill 1,000 villagers 

in Syria, Assad has the good taste to deny it. And for that reason, 

we tend to be focusing on ISIS as the most dangerous enemy. 

The question, I think it was Lenin asked, is what is to be done? 

You have convinced us that the Guard Force is a bad organization. 

We still have sanctions that are allowed under the nuclear agreement, tough sanctions on banks that conduct business on behalf of 

companies designated as a proliferator of WMD, which includes the 

IRGC, the Quds Force, many others. And what is often not mentioned in Section 302 that remains in force that provides for sanctions of those who engage in any significant activity with an IRGC 

entity. 

One problem is that we are not applying this to the National Iranian Oil Company, which I think you would agree is heavily involved with the IRGC. I am going to be distributing to all members 

81

of the committee a discussion draft of a statute aimed at the IRGC, 

and we now have a menu of sanctions that can be imposed against 

a bank or a company that does business with the IRGC. It 

shouldn’t be a menu where maybe they just get some parsley, but 

rather an absolute ban on doing business in the United States 

which then can be lifted with specific licenses. So that a company 

that does any significant business with the IRGC would feel that 

it is going to lose all access to the U.S. market in doing business 

in the United States, and then it would have to go ask the administration for a license to go do this or that. 

And, second, in order to avoid neglect of the statute, it would 

have the GAO give Congress a list of those organizations that appear or are most likely to be doing business with the IRGC or its 

front groups, and those companies would be sanctioned unless the 

President within 6 months came to Congress and said, well, we 

shouldn’t sanction this one and we shouldn’t sanction that one. So 

if the administration did what the last three administrations have 

done, and just ignore Iran’s sanctions, those sanctions would go 

into effect. 

So I look forward to working with the chairman and all the members and the ranking member on this discussion draft, and I also 

want to distribute it to our witnesses and ask you to comment on 

it for the record. I yield back. 

Chairman ROYCE. And I want to thank Congressman Brad Sherman for that draft. We will circulate it to all the members of the 

committee. We go now to Congressman Dana Rohrabacher of California. 

Mr. ROHRABACHER. Thank you very much, Mr. Chairman. This 

hearing sort of cements my view that we are entering into a new 

historic era, and the cold war is over, and now I think the postcold war is coming to a close, and I don’t know what we are going 

to call this new era that we are in. Perhaps history will record it 

as the era of Islamic terrorism or Islamic resurgence, depending on 

how we see what unfolds in the next few years. But we are in a 

different world than we were 10 and 20 and 30 years ago. 

And I want to thank Chairman Royce. I want to thank Ranking 

Member Engel. We are facing a whole new era, and they are providing leadership so that we can understand the challenges that we 

face in this new era, and they both in sort of a bipartisan spirit 

and a spirit of getting to the facts, and I appreciate their leadership. 

Let me ask some specific questions, then about—knowledge questions. How many members does the IRGC have? What are we talking about in Iran? Talking about 50,000 people? What are we talking about there? 

Mr. ALFONEH. Sir, estimates are between 120 and 150,000 active 

members, active duty members of the Revolutionary——

Mr. ROHRABACHER. Are they armed or are just others—anybody 

who is in a business owned by them or are we talking about the 

armed people? 

Mr. ALFONEH. These are the armed people, sir, in uniform. 

Mr. ROHRABACHER. Okay. What is the regular army in Iran, and 

what is its size and how does it interact with this IRGC? 

82

Mr. ALFONEH. The regular military is sightly larger, but its bases 

are alongside the international boarders of Iran. And that is because of the constitution of Iran which gives a different mission to 

the regular military. The regular military has the mission of protecting the territorial integrity of the Islamic Republic of Iran. The 

mission of the Revolutionary Guards, according to the constitution, 

is to protect the revolution and its achievements in the abstract. 

Mr. ROHRABACHER. Does the regular army get along with that? 

Is there any friction points there? 

Mr. ALFONEH. There are many ideological political commissars, 

in the regular military, which is, you know, a classical military organization. It is not ideological. 

Mr. ROHRABACHER. Which would then be friction—cause friction 

between the two. 

In the IRGC, what ethnic makeup is that? We know in Iran 

about half the people are not Persian, but is the IRGC basically a 

Persian group, or do they have Kurdish people in it or Azeris, or 

Baluchs or Azeris or whoever? What is the makeup of——

Mr. ALFONEH. Yes, sir. We do believe that it actually reflects the 

ethnic composition of Iran as a whole. 

Mr. ROHRABACHER. So there are Kurds who are——

Mr. ALFONEH.—yes, sir. 

Mr. ROHRABACHER [continuing]. Members of that as well as——

Mr. ALFONEH. Shiite Kurds, yes. 

Mr. ROHRABACHER. Okay. Now, in terms of the support of the 

IRGC for terrorism around the world, how many missiles, for example, we have all seen these rockets that go off and are shot by—

out of the Gaza Strip into Israel, and I consider that to be a terrorist act. Anytime you shoot rockets into a country, especially if 

it is indiscriminately to try to just murder people, I would say that 

is terrorism. 

How many of these terrorist rockets that are going into Israel 

from the Gaza Strip and elsewhere, were either manufactured or 

paid for by the IRGC? 

Mr. MODELL. Thank you for the question. I think the vast majority if not all of them. And not only that, the next generation is actually providing them with the ability to manufacture them themselves. 

Mr. ROHRABACHER. I didn’t catch that last part. 

Mr. MODELL. I would say the vast majority have been provided 

to them by Iran. They are linked to Iran, Iranian manufacturers, 

but what Iran’s next phase of support in providing missiles to 

groups operating in the West Bank and in southern Lebanon is to 

actually give them the capacity to develop those missiles themselves. 

Mr. ROHRABACHER. I see. And we might note Congressman Engel 

and myself, and Ed—I am not sure if Ed was with us on that trip 

or not, but I remember when we crawled in—you were with us, 

when we crawled into these tunnels that were dug. And that was—

they were not just crawl spaces. These were very expensive construction projects. Are those things being paid for by the IRGC? 

Mr. MODELL. You know, from years ago I can tell you that the 

intelligence community I think was divided on that question. But 

I think the Iranians were working very closely with Lebanese 

83

Hezbollah in developing those, those tunnels. But as far as financing goes——

Mr. ROHRABACHER. These terrorists, whether they are people 

who are Palestinians who are conducting terrorism on Israel or 

these other, they don’t have really a large source of money and 

what we are talking about when we say financing. This is a vital 

component to the existence of these terrorists. 

One last note, Mr. Chairman, and I know my time is running 

out, is that we have a similar situation from what you described 

in China, where you have the People’s Liberation Army controls 

and actually receives the profit from a large number of commercial 

operations. And if people are investing in that and those companies 

are making a profit, it is going to the People’s Liberation Army and 

not to the people of China. So go ahead. 

Mr. MODELL. I would just like to make one comment on that. I 

think you raise a very important point. And if you go back in time 

to the origin of Lebanese Hezbollah when Iran was—in the early 

1980s when Iran was instrumental in figuring out what is the 

grand vision going to be for this organization, what is their mission 

going to be, one of the things that took years and years for them 

to develop was a global commercial apparatus that was composed 

of businesses, that was composed of a lot of things you just mentioned, that actually create independent streams of revenue that 

they are off the books. And Iran is doing it. Hezbollah is doing it. 

And Hezbollah’s dependence on Iranian official funds over the 

years has gone down for that reason. 

Mr. ROHRABACHER. Thank you. 

Chairman ROYCE. Yes. You raised the point, Mr. Rohrabacher, on 

those tunnels and who paid for their construction. I would just 

make the point, myself, and Mr. Engel, and Mr. Rohrabacher, and 

Mr. Gregory Meeks, were in those tunnels shortly after the Gaza 

operation. And it was reminiscent to me, in 2006, the Iranian constructed tunnels done for Hezbollah, their engineers were involved 

in that. We know that from ID badges that were picked up after 

the 2006 second Lebanon War. I was there during that conflict. 

And in this particular case, not only do you have indication that 

Iran was involved in also the tunnels under Gaza, this particular 

tunnel that we were in, came up underneath a village. And the 

plan apparently was to capture students, because it was a school. 

It was an elementary school that it was under. And to pull them 

back into Gaza so that the IDF would have to fight house by house. 

But the most important point is that after the conflict was over, 

the report surfaced which was in the Wall Street Journal, as I recall, in which Iran committed to rebuilding those tunnels that were 

closed, some 30 plus were discovered, for Hamas. Now, we understand Iran also supports, you know, the Palestinian Islamic jihad. 

In other words, they are not just supporting Hamas in Gaza. They 

have a secondary organization that they would prefer. But they are 

providing Hamas. The story also mentioned they committed to providing again to resupply the rockets to Hamas. 

So, you know, it is an on-again/off-again depending on geopolitics 

in the area in terms of how much support they provide Hamas. 

They clearly would prefer Islamic jihad as an organization, but I 

think it is unquestionable that they have been involved in this enVerDate 0ct 09 2002 12:17 Feb 17, 2016 Jkt 000000 PO 00000 Frm 00087 Fmt 6633 Sfmt 6633 F:\WORK\_FULL\120215\97751 SHIRL
84

terprise. And, indeed, those reports regularly appear in the media. 

So I would just, Ambassador, point that out for posterity. 

Ambassador BENJAMIN. If I may, Chairman Royce, historically 

there is no question that Iran was a principal sponsor of Hamas, 

and I believe the exclusive sponsor of Hezbollah. However, I believe 

the best information we have today is that Iran is not transferring 

any resources to Hamas now. And Hamas’ budget is dependent entirely on its international fundraising efforts. 

And that includes money that it receives from Qatar and from 

Turkey, that is to say, from the Sunni side of the equation. And 

it doesn’t appear likely after repeated meetings between Hamas 

and Saudi Arabia that Iran is going to forgive Hamas, what it 

views as treasonous activities. So I think it is important that these 

distinctions be recognized. 

Chairman ROYCE. Well, thank you. Hopefully they don’t follow 

through on their commitment to rebuild those tunnels. 

We will go, then, to Albio Sires from New Jersey who is next in 

the queue. 

Mr. SIRES. Thank you, Mr. Chairman. And thank you for being 

here today. 

You know, I have been to a number of hearings, and every time 

I sit here and sooner or later the comment is made that the Supreme Leader is losing support from the Iranian people. 

I was just wondering, after the nuclear deal, have the Iranian 

people lost hope that there could be a change, or has the Supreme 

Leader solidified his position, and have the Revolutionary Guards 

solidified their positions now that they have a deal, and they are 

going to get all this money? Sir? 

Mr. ALFONEH. Sir, it is an important point that you are making 

and a good question. I am not sure if I know the answer, but I will 

try my best. Mr. Khomeini needed someone, a technocratic type, 

like Mr. Rouhani to get people to vote for the regime in order to 

secure some degree of legitimacy for this regime. And the only reason Mr. Rouhani was elected as President of the Republic was because that he promised the Iranian public a nuclear deal with the 

U.S. This is why the Iranian people elected him. 

However, now that he is elected and now that the nuclear deal 

is made, Mr. Khomeini no longer needs Mr. Rouhani. He no longer 

needs the technocratic elites of Iran. So I think the best test is 

going to be the parliamentary elections of February. Is Mr. Khomeini going to allow Mr. Rouhani and his technocratic elites of 

Iran to be elected into the Parliament, for example? Or is he systematically going to filter every single supporter of Mr. Rouhani 

among those candidates? And if he does that, and I strongly suspect it is going to happen, then we will see the rise of the Revolutionary Guards and a reaction among the Iranian public which is 

one of hopelessness. 

So in one sense, yes. The Iranian public has lost faith twice; once 

during the Green Revolution of 2009 when unfortunately the administration extended a hand of friendship to the regime, to Mr. 

Khomeini and not to the Iranian public, and second time when a 

nuclear deal was made where the greatest beneficiary is the Revolutionary Guards and not the Iranian public. 

85

Mr. MODELL. Thanks for your question. The only thing I would 

add to that is I think that there is somewhat of a misconception 

when you talk about Khomeini as being an all powerful figure in 

Iran. I think there is—to a certain degree he is weak in the sense 

that he is constantly forced to balance conflicting factions of a very, 

very—in fact, much more developed series of political factions than 

when he took over in 1989. You have a much more mature playing 

field that he has to balance. And he needs the IRGC just as much 

as the IRGC needs him. 

So, you know, if Iranians ask themselves was the election of 

Rouhani and the JCPOA, do those give us hope or not, I think the 

Iranians are hopeful. If you look at polls, Iran is hopeful. But they 

don’t equate it to a simple will Khomeini allow us to continue to 

have freedoms and advance or not. The Iranians recognize the complexity that Khomeini has to balance, and it is not an easy thing 

to do. And like Mr. Alfoneh pointed out, I think next February is 

going to be very critical in seeing just how much the IRGC has 

done to actually push back and ensure that, you know, if there is 

any momentum toward Rouhani, it slows down. 

Mr. SIRES. Ambassador? 

Ambassador BENJAMIN. Both of my colleagues have made very 

insightful remarks. I would just add that if there is one tried and 

true pattern in history, it is that the frustration of rising expectations is profoundly dangerous for rulers. And expectations have 

been raised dramatically in Iran. Rouhani is extremely popular. 

The notion that Iran is going to have an opening to the West, that 

the Iranian economy will get a new rush of oxygen, and that they 

will see greater prosperity I think is now quite clear. And so I 

think that the Supreme Leader, you know, has to walk a fine line 

if he wants to maintain his own standing while not disappointing 

the expectations of the Iranian people. 

This brings me back to something actually that Mr. Engel said 

before about regime change. I think that we found over the last 30-

plus years that regime change anywhere in the world is a perilous 

course of action. And I think that the virtues of the JCPOA have 

largely been underestimated in terms of creating a 15-year period, 

which is a significant period of time, in which those expectations 

can arise, flourish, and shape the course of the Iranian future. To 

be sure, we have to be vigilant about bad behavior, but I think this 

is no small achievement. 

And we can’t say for certain that in 15 years Iran will be a more 

hopeful place, but we, I think, can say with some certainty that 

without it we would be facing a very dire situation. And now we 

have given the Iranian people, you know, some reason to, shall we 

say, vote with their feet. 

Mr. SIRES. Thank you very much. My time is up. 

Chairman ROYCE. Mr. Matt Salmon. 

Mr. SALMON. Thank you. In your view, and this question is to all 

panel members, is the administration’s growing diplomatic outreach to Iran, and some might say acquiescence, particularly considering Iran’s support for strife in the region, undermining U.S. 

credibility in the region? Start with you, Ambassador. 

Ambassador BENJAMIN. Well, I think it is an interesting and important question. There is no question—there is no doubt that 

86

among our Sunni allies our, Sunni partners, there is significant 

doubt about this, and they are committed to a policy, by and large, 

of not talking to Iran although they do themselves, and of doing everything they can to beat back what they see as the Shia tide. Having said that, it is not entirely clear to me that their perception of 

what is going on is accurate. 

You know, the Sunnis are also culpable, it seems to me, particularly the Gulf Sunnis, for the humanitarian catastrophe that is 

Syria, because they have been pouring more and more resources in 

at every juncture to try to topple the Assad regime. And there has 

been very little desire to find an off ramp there. Similarly, although 

the, you know, the Yemenconflict is extremely complicated, what 

has I think been lost sight of is that one of the critical changes was 

that longtime strongman Ali Abdullah Saleh, which sides essentially, and tried to relitigate what happened in the Arab Spring 

and the election of—or the installation of President Hadi, and so 

this has been seen as another bit of Iranian perfidy. It is true that 

we don’t like what they are doing with the Houthis, but this has 

also led, you know, to a campaign against, you know, an outside 

war against Yemen that has caused another humanitarian catastrophe. 

So I think that the situations is very complicated. I think, you 

know, the Israeli Government’s view was quite clear. But having 

said that, it is impressive how much of the Israeli defense establishment, I think, has come around to approve of the JCPOA and 

has been encouraged by the direction things are taking. 

Mr. SALMON. Thank you. I am going to shift gears because I have 

a couple of other questions. I did want to get that one out there. 

But I have a question for you, Mr. Alfoneh, and then one for you 

as well, Mr. Modell, if I can just throw them both out. 

First to you, you recommend that the U.S. should still pursue the 

dual goal of toppling Assad regime and fight ISIS at the same time. 

Even if we are able to topple the Assad regime, which will be increasingly difficult with the overt support of Assad by Russia and 

the covert support by Iran, what next? And wouldn’t the most likely outcome be an Iranian or Russian puppet or a controlled puppet 

regime? Or perhaps even worse a fractured lawless Syria that will 

give ISIS a larger power base and more territory to control? Is this 

really the policy that is going to bring stability to the region? 

And my add-on question to you, Mr. Modell, is very similar. Do 

you think Iran or ISIS poses the bigger threat to national security, 

our national security, both in the short and the long term? I would 

like your thoughts on that. 

Mr. ALFONEH. Sir, I do believe that one of the reasons that the 

Alawite elites in Syria are backing Bashar al-Assad is that they 

have absolutely no alternative as things are right now. If they are 

given an alternative, if there are security guarantees that there is 

not going to be genocide of Alawites after the Sunnis also take part 

in government. And if a government like the United States is willing to give that type of guarantees to the Alawites, why should 

they stick with someone who has led to destruction of their own 

countries? I do believe that there is dissatisfaction even among 

Alawite elites in Syria, but they have honestly nowhere else to go. 

Mr. SALMON. Mr. Modell. 

87

Mr. MODELL. As to your question as to what presents a greater 

short- or long-term risk to U.S. national security between Iran and 

ISIS, you know, I guess it depends. I mean, you know, if you are 

talking about lone wolf terrorist attacks in the United States or, 

you know, bombings like 9/11 or the Paris attacks, obviously ISIS. 

But at the same time, I think if you look at the heart of what Iran 

is doing, okay, the ideologically driven externalization of its Islamic 

revolution and everything that represents, if you believe the vast 

majority of our allies, our current allies at least, in the Gulf and 

elsewhere, are never going to be okay with that. And they are 

going to always be opposed to that in a fundamental way, then I 

think as long as we have a long-term fundamental reason to stay 

in the Middle East, that is the bigger term of threat in terms of 

creating a permanent destabilizing presence in the region. 

Mr. SALMON. Thank you. I yield back. 

Chairman ROYCE. Mr. David Cicilline of Rhode Island. 

Mr. CICILLINE. Thank you, Mr. Chairman. Thank you to our witnesses. And I think all of us, particularly after viewing your testimony and several other hearings we have had on this issue understand that we have to do everything that we can and use all of the 

tools available to us to keep the pressure on and really took to confront the IRGC and Iran and the region. 

So my questions are first to you, Mr. Modell. You said the 

Obama administration has demonstrated an unwillingness to 

weaken the IRGC. So I am asking you what you think the administration should be doing to effectively weaken the IRGC? 

Mr. MODELL. One of the things that I mention in my recommendations was the fact that the IRGC, if you want to look at 

one of the things that concerns the IRGC and the Supreme Leader 

and the conservative establishment in Iran, is that is the ongoing 

credibility of the IRGC. The IRGC—we have had one serious kingpin designation against the Iranians, against an IRGC general who 

was involved in narco trafficking with the Taliban and others. He 

is based in Balochistan and——

Mr. CICILLINE. I have limited time so can——

Mr. MODELL. Oh, sorry. 

Mr. CICILLINE [continuing]. You just tell me, you know, what you 

think we should do. 

Mr. MODELL. Recommendations? I think naming and shaming. I 

think there needs to be a campaign, a media campaign, not a covert. I think an open media influence campaign that points out all 

the things that the Iranian—that the IRGC, in particular, is doing 

to destabilize the region. I don’t think we have done nearly enough 

of that. 

Mr. CICILLINE. Okay. And with respect to the designation of the 

IRGC as a foreign terrorist organization, does anyone on the panel 

think they don’t meet that definition? And if you don’t, why not? 

And what would be the implications of that designation, particularly on Americans being held, but on any other facets of this conflict? Ambassador? 

Ambassador BENJAMIN. So the designation of the IRGC as a 

State Department-designated foreign terrorist organization, would 

be at odds with the entire history of designations, first of all, in 

that it would be a designating a state organ, a state entity. Iran 

88

is a state sponsor of terrorism, and as such is covered by a wide 

raft of different sanctions that are extremely comprehensive. And 

to add the IRGC to this, it seems to me, would add, practically 

speaking, nothing to our arsenal of tools, nothing meaningful. 

And what is more is that there remains in effect a large array 

of Treasury designations against the IRGC as I mentioned before 

for terrorism, proliferation, human rights violations. We have all 

the instruments we need. And I think that to do something additional like this would both be unnecessary from a functional standpoint. And from a signalling standpoint, I am not sure that it is 

exactly what we need at precisely the moment that we want to see 

more—we want to see an effective implementation of the JCPOA. 

Mr. CICILLINE. Well, with respect to that, Ambassador Benjamin, 

you said in your testimony that additional terrorism campaign or 

an additional terrorist campaign by Iran would scuttle the agreement, referring to the JCPOA. Why do you think that would scuttle 

the agreement? I don’t see anything in the agreement that would, 

in fact, be in violation if they engage in terrorism. 

But the argument was made that it is better to confront a nonnuclear Iran than a nuclear Iran, which I agree. And you said the 

U.S. is in a good position to deter and prevent increased terrorist 

activity. Through what means? What do you think would be the 

most effective way for the United States to do that, particularly 

since I don’t think engaging in terrorism is a direct violation of the 

JCPOA. 

Ambassador BENJAMIN. I think as a political matter if there were 

a widespread perception that Iran was using this opportunity to 

carry out a widespread—a massive terror campaign, I think that 

it would inevitably cause a reaction by Washington. I think that is 

just pure commonsense politics. 

In terms of being able to deter, let’s just break it down. And I 

will recap some of my testimony. So Iran has, since 1996, not carried out a terrorist attack against the United States, and has only 

had one major plot revealed, and that was the very, very strange 

Arbabsiar plot involving the desire to kill the Saudi Ambassador 

here in Washington. 

I think that the Iranians have a healthy respect for our counterterrorism capabilities, for our intelligence gathering, and for our 

law enforcement, and are unwilling to be caught and to risk the 

kind of global opprobrium that they experienced after the 

Arbabsiar plot when there was an overwhelming U.N. general assembly resolution condemning them. 

I do believe that they will continue to try to provoke Israel, and 

I think that they will try to show that they can do two things at 

once and that they are still the leaders of the resistance. And I 

think for that reason our commitment to Israel’s security has to be 

unwavering. We have to continue funding Iron Dome and continue 

the very robust support for Israeli defense, intelligence, and counterterrorism activities. 

And as for how we work with our Arab partners, you know, I 

think that the solution, the secret of our success has been excellent 

intelligence. And I think that we should deepen that intelligence 

cooperation with these countries. But, you know, I just note that 

the circumstances are becoming more difficult as some of these 

89

countries are themselves doing things that cross red lines for us, 

including, for example, their support of extremist groups in Syria. 

And so to come back to my main theme, we are living in a different Middle East. And I think that we need to think long and 

hard about what America’s role is in the midst of this sectarian 

conflict. 

Mr. CICILLINE. Thank you. And my time is up. Thank you, Mr. 

Chairman. 

Chairman ROYCE. Mr. Jeff Duncan of South Carolina. 

Mr. DUNCAN. Thank you, Mr. Chairman. 

Ambassador Benjamin, I want to go to your statement for just 

a minute which I thought was spot on in so many ways. But you 

say that Iran remains by a significant margin the foremost state 

sponsor of terror today. You go on to talk about Iranian terrorist 

activity focused primarily on support to groups like Hezbollah, 

Hamas, and Palestinian Islamic jihad. And then you say roughly 

5 years ago Iran and its proxy Hezbollah appeared to be laying the 

groundwork for a renewed campaign of terrorism outside of the 

Middle East. Notable arrests in places like Thailand, Kenya, India, 

Azerbaijan, Cypress, Bulgaria, and that operatives responsible 

were traced back to Lebanon and Hezbollah. 

So we are very familiar with the Iranian Hezbollah connection. 

So let’s take a moment, and I chair the Western Hemisphere Subcommittee. Let’s bring this closer to home. January 8 of this year 

there was an attempted bombing in Montevideo, Uruguay, that targeted the Israeli Embassy. A few days later, an Iranian diplomat 

Ahmed Sabatgold, 32, a political consultant of the Iranian Embassy 

suspected of being involved in placing the explosive device, fled the 

country. Wasn’t expelled, but fled the country. We also know that 

very close to Uruguay is the tri-border region, which is heavily Lebanese Hezbollah. Lot of financial transaction and other things. You 

could tie that into the bombing in Buenos Aires. You could go back 

a long ways, but just keeping it present day, January in Uruguay. 

And then we had five Syrian refugees, migrants, whatever you 

want to call them, who traveled on fake Israeli passports to, hello, 

the tri-border region where they were able to purchase, through 

Hezbollah, other fraudulent passports which turned out to be 

Greek passports. After travelling a little bit in South America, 

made their way to Honduras on fake Greek passports. Now, they 

may have been farmers, may have been students. We don’t know 

what their plans were, but there is a connection between illicit activity in the tri-border region and Hezbollah, which is an Iranian 

proxy organization, tied to terrorism all over the globe, not just the 

ones that I mentioned in Uruguay and Argentina. And if you think 

about what you mentioned in your statement about, and I can’t 

pronounce his name, but the Iranian that was implicated in the assassination attempt of October 2012—is that right—trying to come 

across the southern border with the help of the Mexican cartel, and 

lo and behold, it was a DEA agent. We got lucky. May not always 

get lucky. 

Then you factor in the issue that General Kelly at SOUTHCOM 

brings up that Iran has opened 80 cultural centers in Latin America in the last, what, 15 years or less, where there is not really a 

large Muslim population. Okay? So we got tri-border region and 

90

Hezbollah. We have got 80 cultural centers in Latin America. We 

got an attempt by a Quds Force operative to assassinate the Saudi 

Ambassador by coming across our southern border working with 

the drug cartel. We have got General Kelly pointing out the cultural centers and raising the alarm. 

So I just want to hear your thoughts on how we combat Iran and 

the Quds force here in the Western Hemisphere knowing all of this. 

And am I wrong to start raising the flag about this issue? Ambassador. 

Ambassador BENJAMIN. So Hezbollah has been present in many, 

many countries around the world since, really, the 1980s. And their 

presence is overwhelmingly in the Western Hemisphere and in 

West Africa where there are lots of Hezbollah operatives. It has 

been overwhelmingly about economic activity, but we still need to 

be very vigilant about the possibility that they may seek to get involved in violence. 

The United States has close liaison relations with most of the 

countries in the hemisphere, and takes the responsibility to surveil 

these operations very, very seriously. With the exception of Venezuela, I think we have had very good cooperation from most of our 

partners. And of course you didn’t mention Venezuela which has 

been a subject of concern regarding Hezbollah, in particular Iran, 

for many years. And I think that, you know, this is the world we 

live in. 

I have written and said on many times that we need to continue 

our investments in intelligence and in law enforcement, and work 

with these countries to ensure that we have tabs on everyone who 

is doing anything, and then to prompt them when the time comes 

to take legal action or to expel these people. And on many occasions 

they have done so. I actually think that the level of Hezbollah infrastructure, and I haven’t had an intelligence community assessment on this in some time, and I am no longer in the government, 

but I think the level of Hezbollah infrastructure is somewhat diminished from what it was in, say, the 1990s. 

And we have had some really impressive successes against 

Hezbollah. For example, the case involving the Lebanese Canadian 

Bank which led to the forfeiture of I believe $140 million in assets, 

including the uncovering of this large-scale operation that involved 

sending used cars to West Africa in which—from the Western 

Hemisphere where they were then sold across Africa and the profits were mingled with Hezbollah drug money, for example, and 

then passed on to Hezbollah in Lebanon. 

So, we can’t eliminate all of these bad actors everywhere at once, 

but I think that we have shown over time that we have a very, 

very capable intelligence community and our leaguettes around the 

world are working very, very hard, our FBI representatives, and I 

think that we continue this to keep the pressure on the group. 

Right now it is a group that is somewhat stretched by its involvement in Syria, and a group that I think wants to avoid being embroiled in an even wider conflict than the one it is. So it is, for example, being careful vis a vis Israel. 

But, you know, at the State Department when I was coordinator, 

we kept a very close eye on this and were in touch with our colleagues around the world whenever we felt there was a need. And 

91

I think that we can continue those policies to curb Hezbollah activity. I believe you have to go back to the bombings in Argentina to 

find any violent activity in this hemisphere by Hezbollah. 

Mr. DUNCAN. And for your information, for the record, the State 

Department now doesn’t take the Iranian activity, Hezbollah’s activity in the Western Hemisphere much of a threat. And I have got 

the report that shows they did a very poor job in evaluating that. 

So——

Ambassador BENJAMIN. Well, I think—so I would have to go back 

and look at the country reports or anything that they have submitted to you. I think that it is probably justified to say that the 

threat level is low but that the economic activity remains a matter 

of concern. 

Compared to the Sunni threat, compared to ISIS, compared to Al 

Qaeda in the Arabian Peninsula, I think that the threat from 

Hezbollah to Americans specifically is quite low. 

Mr. DUNCAN. Okay. I am out of time. I appreciate your frankness 

and I yield back. 

Chairman ROYCE. Thank you, Mr. Duncan. 

We go now to Mr. Ted Deutch of Florida. 

Mr. DEUTCH. Thank you, Mr. Chairman. Thanks to the witnesses 

for being here. And, Mr. Chairman, thanks for holding this hearing 

and giving us the opportunity to be reminded of Iran’s sport for terrorism and the actions of the IRGC in particular. 

And I would like to focus in on one part of the JCPOA that we 

have touched on briefly, but I really want to understand better. We 

are moving forward under this deal, and there is a long list of individuals and entities who will see sanctions relief under the JCPOA. 

Coming off of the sanctions coming off are nuclear proliferation 

sanctions. 

This hearing is about Iran’s support for terrorism. And we know 

that under existing law, individuals and entities can and should be 

sanctioned for their support for terrorism and for violation of 

human rights. So the question for all three of you is, shouldn’t we, 

in advance of providing any sanctions relief to those individuals or 

entities for proliferation sanctions, shouldn’t we go through all of 

them, determine which ones should still be sanctioned for their 

support for terrorism and never let them off to begin with? 

Mr. ALFONEH. Sir, I think in this context we need to distinguish 

between U.S. sanctions and EU sanctions because what we see is 

that most of the—actually all, every single individual and entity 

owned or connected by the Revolutionary Guards, still remains 

sanctioned by the U.S. Government. 

But when it comes to the European sanctions regime, they are 

going to remove actually most of the Revolutionary Guards units 

and personnel 8 years from the time of the implementation day. So 

the Europeans 8 years from now may be doing, engaging in——

Mr. DEUTCH. I understand that, Mr. Alfoneh. But I am focused 

on those individuals and entities who will get sanctions relief when 

sanctions relief is initially granted, not 8 years from now, but when 

they meet their nuclear related obligations. And from everything 

that I have read, there are—everyone will acknowledge that some 

of them are on that list, some may be on there and are on there 

dual sanctioned for proliferation and for terrorism, but there are 

92

others who are on the list because it is easier to put them on the 

list for proliferation than it would have been to prove their support 

for terrorism. 

But if we are serious about stopping Iran from supporting terrorism, have any of you looked at that list and identified the individuals and entities who support terrorism and who should not be 

considered for sanctions relief at all? Mr. Modell. 

Mr. MODELL. Let me just say one of the recommendations I made 

the last time I testified which addressed this same question was, 

Treasury, which does a lot of great work, one of the things they either—and when asked by me directly to some people over there: 

Have you ever undertaken a comprehensive study to look at all the 

people who have been sanctioned and designated on the SDN lists, 

sort of where they are today, where that are now, how have they 

been impacted, are they still in business, how are they subverting 

sanctions, so forth. And the answer is, you know, they are poorly 

resourced. That is a different issue. 

But the answer I think to your question is is yes they should because a number of the people that are coming off the list, and I 

have seen a few that I haven’t—that I am thinking of in particular 

were part of what is nothing short of a global trends national organized crime effort on the part of Iran. And in this case it was to 

circumvent sanctions and nuclear related issues. But those people 

were willing to commit crimes on behalf of the Iranian Government 

then. Now that you are taking them off the list, they are not going 

to stop being part of this global apparatus that is involved in illicit 

procurement activities. 

Mr. DEUTCH. Right. And, Ambassador Benjamin, there was a 

statement within the past few weeks from the Supreme Leader 

who said—I think it was the Supreme Leader who said that any 

effort to re-impose sanctions will be a violation of the deal. But 

clearly that wouldn’t be a violation of the deal. The terror related 

sanctions were never meant to be a part of the deal. That is what 

we were told throughout. That is clearly the view of this committee, of the administration. So shouldn’t we be, before granting 

sanctions relief, shouldn’t we be pushing back to disabuse anyone 

in Iran of the notion that lifting of sanctions for nuclear proliferation means lifting of sanctions altogether? 

Ambassador BENJAMIN. Well, I think your point is well taken. I 

think that the administration has been doing that pretty clearly in 

statements by the President, Secretary Kerry, Wendy Sherman, 

and the like. No one has been, to my mind, delisted for terrorism 

activities. If anything, everyone has been reaffirming that Iran is 

and will remain designated as a state sponsor. 

I cannot really say anything informed about the listings the 

Treasury has on individuals for terrorism, but I have certainly 

never heard that there have been people listed under proliferation 

because it was easier to do that than to do them for reasons of terrorism. Obviously these lists should be scrubbed regularly. There 

are issues of resources, but I think we just continue to repeat the 

message over and over again that bad behavior absolutely will not 

be tolerated. 

Mr. DEUTCH. Right. I understand. But, Ambassador Benjamin, 

shouldn’t we scrub that list now, before sanctions relief is granted, 

93

to any of those individuals or entities to make sure that if someone 

on that list has been supporting terrorism and should be subject 

to sanctions that they continue to be subject to sanctions and they 

never come off that list? 

Ambassador BENJAMIN. I think that is self-evident. I think that 

if you find people who are sanctionable because of terrorist activity, 

they should be sanctioned, and we have made it clear that we will 

do that. We did it before and we should do it again. 

Mr. DEUTCH. And we should do it before there are sanctions relief granted. I appreciate it. 

Thank you, Mr. Chairman. I yield back. 

Mr. ENGEL [presiding]. We will go to Mr. McCaul. 

Mr. MCCAUL. I thank the chairman. 

Mr. ENGEL. That sounds nice, Mr. McCaul. We have a good 

chairman right now. 

Mr. MCCAUL. Yes, we do. 

Let me just—in 2012 the Obama administration basically admitted that the IRGC was one of the most powerful economic actors 

within Iran, that they own a network of front companies all over 

the world, essentially. And so while they claim that upon implementation day that the sanctions will still be in place on the IRGC. 

Wouldn’t these front companies that are owned by the IRGC benefit? And, therefore, wouldn’t the IRGC benefit directly from the 

lifting of these sanctions? I will start with you, Mr. Alfoneh. 

Mr. ALFONEH. Yes, sir. You know, to the extent that the Revolutionary Guards manages to establish new front companies, it would 

of course benefit, you know, by sanction evasion from the United 

States, but would also most directly benefit from the sanctions relief because the Iranian Government is funding the Revolutionary 

Guards’ engagement in the economy of Iran. 

Even during the Presidency of Mr. Rouhani who certainly does 

not seem to be a fan of the Revolutionary Guards, there seems to 

be more Revolutionary Guards participation in development of 

Iran’s economy, in many public projects which have been granted 

to the Revolutionary Guards, and I also think that this is the miscalculation of President Rouhani. He thought that he could buy and 

bribe the Revolutionary Guards not to oppose a nuclear deal. But 

what of course what will happen now is that the Revolutionary 

Guards takes the money and they will oppose the nuclear deal during the implementation phase. 

Mr. MCCAUL. That is interesting. 

Mr. Modell? I am sorry. Let’s go down the—okay. Ambassador. 

Ambassador BENJAMIN. I would just point out that there is sort 

of this belief that we are headed into a completely binary change. 

And the fact is, as I think has been well demonstrated over the 

years, the threat of Treasury sanctions is an enormous threat and 

a big hammer. We have unilateral sanctions remaining on lots of 

IRGC entities. And I think that the likelihood that foreign investors—of course no Americans will be investing because of the retention of our sanctions. 

But the likelihood that, say, European or Asian investors are 

going to suddenly strike deals with these entities if there is any 

shadow hanging over them is quite limited. Because in the end, the 

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U.S. is still going to be prepared to cut those companies off from 

credit markets, and our ability to do so is quite remarkable. 

So, yes, in theory there is a danger there, and it is one we need 

to be vigilant about. But the Treasury has never been particularly 

shy about sharing information about those connections. And I expect they will be very aggressive in the future too. 

Mr. MCCAUL. And maybe, Mr. Modell, I will let you comment, 

and I will just throw out the last question because my time is running out. And that is there has been some discussion that under 

the section 219 of the Immigration Nationality Act that the IRGC 

should qualify as a foreign terrorist organization. I think that 

would give complete certainty that the lifting of sanctions would 

not benefit the IRGC. But I would throw that out to you. 

Mr. MODELL. One of things I want to mention on your front company question before was that when you look at the ability of—and 

this is based on my own experience, but with the experience in 

talking to people who are serving—U.S. Government officials serving in the region now. When they approach our allies, particularly 

in the Southern Gulf, and ask for cooperation on trying to dismantle front companies, try to get more cooperation in working 

against front companies, working closely with the financial intelligence units to learn more about how they are moving men and 

money and material throughout the region, a lot of walls are put 

up. 

And I think if you are going to get serious about it, you need to 

go to places like the Emirates where there are hundreds and hundreds of companies that are springing up all the time that are in 

very few ways deterred by any sanctions that have been going on. 

So that is something I think needs to be addressed. 

Mr. MCCAUL. That is a great point. What about the designation 

as a foreign terrorist organization? Would you agree that they 

should be? 

Mr. MODELL. You know, I just think it is so intertwined. I appreciate, you know, Ambassador Benjamin’s point earlier that it would 

go against historical precedent, but I think when you look at the 

way the dimensions of the IRGC and how interwoven they are with 

regard to a singular mission of—that happens to overlap with terrorism and a lot of the illicit activities they do around the world, 

I just don’t know how you are going to deter them otherwise. 

And I think one point that needs to be made is the Iranians have 

been very clear in saying, maybe not explicitly, but their main goal 

has always been to get rid of European sanctions. That is how it 

was before 2012. They were perfectly fine to live with a comprehensive trade ban. They can survive with it or without it. 

So I think if you are going to get—you know, it is worth exploring that if you did do that you would have an extra deterrent for 

Europeans to do business with them, and that might be an extra 

way of prodding them to change their behavior——

Mr. MCCAUL. Mr. Alfoneh, do you have any opinion on that? 

Mr. ALFONEH. My organization agrees with Mr. Modell’s suggestion that the entire organization should be designated as a foreign 

terrorist organization. I have a slightly different approach in this 

regard because I would like to punish those entities of the RevoluVerDate 0ct 09 2002 12:17 Feb 17, 2016 Jkt 000000 PO 00000 Frm 00098 Fmt 6633 Sfmt 6633 F:\WORK\_FULL\120215\97751 SHIRL
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tionary Guards which take part in the war in Syria. And we can 

document their presence in Syria. 

And the difference, I think, hopefully, and both are methods, I 

think, you know, have their own, you know, merits, but I also believe that my approach would have the added value of starting a 

process and discussion hopefully within the Revolutionary Guards. 

So they try to understand the price that they are paying for supporting Basar al-Assad’s regime and keeping on his throne of blood. 

Mr. MCCAUL. And, Ambassador, I presume you would be opposed 

to that designation? 

Ambassador BENJAMIN. Yes. I did summarize my reasons before. 

Again, it would be, on the one hand, a complete break with our tradition of how we do foreign terrorist organizations. We have never 

designated at the State Department a government organ. And I 

think that actually the existing sanctions under the designation of 

Iran as a state sponsor of terrorism, as well as the whole array of 

other executive order, Treasury designations and the like, are more 

than ample currently for—certainly for enforcement purposes. And 

I don’t see any additional messaging purpose that would be fulfilled 

through this. 

Mr. MCCAUL. I see my time has expired. 

Chairman ROYCE. Lois Frankel of Florida. 

Ms. FRANKEL. Thank you, Mr. Chair. Thank you. This has been 

a very interesting discussion. And I have some very, I will say, simplistic questions. 

First of all, in terms of—we have been saying IRGC, and then 

we are talking about Iran. For the funding of Hezbollah, is it the 

IRGC that funds Hezbollah, or is it Iran, or is it both? How does 

that exchange happen? 

Mr. ALFONEH. I only do my analysis, you know, in open source. 

So it is very difficult for me to give you a precise answer. But, you 

know, the way that it operates is usually indirect. 

So the Iranian Government, in the old days, in the 1980s, for example, they would on the national budget tell the entire world that 

Iran is supporting, let’s say, Islamic jihad or Hezbollah, and be so 

and so many millions of dollars. But then in mid-1980s there were 

several lawsuits against the Government of the Islamic Republic of 

Iran in the U.S. because there were victims and family members 

of victims of terrorists who could refer to the national budget of the 

Islamic Republic of Iran and prove that Iran is a state sponsor of 

terrorists. 

So ever since mid-1980s, the Islamic Republic has been trying to 

hide the mechanisms through which they send money to Hezbollah. 

So we do not have open source information available for you. But 

some of that money is through Revolutionary Guards. Some of that 

money is through the office of the Supreme Leader. Some of that 

money is through the cultural centers. Even the construction base 

of the Revolutionary Guards, Khatam al-Anbia, is engaged in housing projects in Lebanon, particularly after the 2006 war. So there 

are multiple channels through which the Islamic Republic is funding Hezbollah. 

Ms. FRANKEL. Did you want to answer? Because I have a couple 

other questions. 

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Ambassador BENJAMIN. I would just say very quickly, I think it 

is a kind of distinction without a difference. Hezbollah is funded 

because it is a national priority of the Government of Iran. 

Ms. FRANKEL. Okay. So my next question really has to do with, 

I guess, the relativity of Hezbollah’s efforts in the Middle East toward the conflict. If Hezbollah was not present in Syria, how much 

difference do you think that would make? 

Mr. ALFONEH. Well, the Bashar regime would have collapsed because the Islamic Republic was not ready a few years ago to deploy 

large-scale forces of the Revolutionary Guards in Syria. Hezbollah 

has been doing the job of the Revolutionary Guards and seems also 

to have been suffering a large number of casualties. 

My study of the Iranian casualties shows me that since January 

2012, 201 Iranians have been killed in combat in Syria. The number for Lebanese fighters, Hezbollah fighters in Syria, in the same 

period of time seems to be above 1,000, possibly 1,500. 

Ms. FRANKEL. So does anyone else want to take a stab at that? 

So let me say, if Hezbollah was removed or if—let me put it this 

way: If Hezbollah was not being funded by Iran, would there be 

more likely a collapse of the Assad regime? 

Ambassador BENJAMIN. I think I would only say, and we are in 

a very hypothetical world here——

Ms. FRANKEL. Yes. 

Ambassador BENJAMIN [continuing]. That it is kind of hard to 

imagine what that world would be like because Iran’s interest in 

Syria is above all about the resupply and the connection with 

Hezbollah. So, you know, we would be taking the heart out of the 

jigsaw puzzle. 

Ms. FRANKEL. No, no, the reason I guess—well, my motive for 

asking that question is because I think a lot of us were concerned 

with this Iran agreement because we saw a direct connection between Iran getting money, more money, funding Hezbollah, and 

creating this horrible conflict in Syria. So let me just ask another 

question if I could follow up. If Iran was not funding Hezbollah, 

what would you think would be the affect on peace in Israel? 

Mr. MODELL. Again, that is a big hypothetical, but let me just—

let me make a couple of comments on the Iran/Hezbollah relationship, the way I have seen it evolve, particularly since 2012. Point 

number one is when sanctions really started to hit, okay, entire 

operational units of the IRGC itself had to—their funding levels 

went down. Their activities, as a result, went down. And not only 

IRGC, but Hezbollah as well and other groups that were on the receiving end of Iranian Government funding also were put on hold. 

So before the JCPOA took place and the Iranians were feeling 

the brunt of this pain of sanctions, their operational activity did decline, and but I would also say that Hezbollah has evolved into its 

own organization. It has its own identity. And to a certain extent 

by Hezbollah—over the last decade, if not more, Hezbollahhas developed its own ways of generating revenue. They don’t depend entirely on Iran as they did in the earliest years of the revolution. 

Ms. FRANKEL. Okay. Well, that was really what my question was. 

So you are saying now that—well, what would you say percentagewise their own funding versus relying on Iran? 

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Mr. ALFONEH. The open source, I cannot give you a precise estimate, madam, unfortunately. 

Ms. FRANKEL. Mr. Chairman, I have one more—I think it is 

like—well, three of us are left here. We have had so many different 

meetings in the last month or 2 months or whatever, or the year, 

about what is going on in Syria. In your opinion, will the IRGC be 

okay with a transition out of Assad? 

Mr. ALFONEH. The clear answer is no, madam. They have invested in the person of Bashar al-Assad. All the commanders, senior commanders, of the Revolutionary Guards have supported 

Bashar al-Assad personally in the Iranian press. It would be a terrible loss of face for them. But there seems to be discussions within 

the regime. So the President of Iran, President Rouhani, he has 

sent some signals which we could interpret as some degree of readiness to cooperate with someone else, you know, than Bashar alAssad. But that is not the signals we hear from the Revolutionary 

Guards. 

Ms. FRANKEL. Anybody else? 

Ambassador BENJAMIN. I would just say that it is very hard to 

conceive of any Iranian acquiescence in a peace plan that involves 

both the removal of Assad and his non-replacement by one of his 

inner circle allied senior leaders, I think that that is—that is kind 

of a non-starter for the Iranians, even if they do come to the conclusion that the person himself does not have to stay there forever. 

Ms. FRANKEL. Okay. Thank you very much. I yield back. 

Chairman ROYCE. All right. Mr. Curt Clawson from Florida. 

Mr. CLAWSON. Thank you, gentlemen. 

Ambassador Benjamin, you have stated that the administration 

will still be able to rely on U.N. Security Council resolutions that 

levy arms embargoes against key areas of concerns such as Shia 

militias in Iraq, Hezbollah, and Lebanon, and in folks in—Houthis 

in Yemen. 

Now, Iran does billions of dollars’ worth of trade with the Gulf 

States. They do billions with Europe. No oneis going to stop that 

unless it is us. I mean, you know, I don’t know all the different 

lists. This list, that list, the other list, the Treasury Department. 

But I know everybodyis doing business with everybody. And if we 

were serious and we really wanted to stop it, we would stop it. 

Last time I checked, we were almost a third of the global GDP. 

Our trade deficit is $40 billion a month. And a lot of that goes to 

the people that we would need to cooperate with us from Europe 

and from that region. And no one can survive without our financial 

system. No one. If we wanted to stop Iranians enriching themselves, we wouldn’t be talking about lists, and we wouldn’t be talking about the U.N. We would just say: Hey, anybody doing business 

with you-all can’t do business with us. And that is going to shut 

your economy down. And anybody taking their money can’t do business with our banks, and that would shut their financial access 

down. 

It seems to me that this is just some sort of economic charade. 

I wouldn’t depend on the U.N. to shut down the money into Iran. 

We have a third of the global GDP. Why would we go to the Security Council? If we wanted to stop these folks from getting guns to 

point at Israel and to point at our allies, we ought to get serious 

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about economic sanctions and economic leverage that we have. And 

it just always make me irate when we go through these lists when 

we just allow everyone to trade with these folks. You know we do. 

You know we do. 

Are we ever going to get serious about stopping the trade? Because if we wanted to, we are the only folks—now, I know Russia 

won’t, but our friends in Europe trade with them. And so do folks 

in the region. And we all know it. We just allow it to happen. Are 

you going to tell me they are not doing trade or that we couldn’t 

stop them? What are you going to tell me here? 

Ambassador BENJAMIN. Well, first of all, your points about America’s economic power I think are largely on point, and it was because we exercised that economic power that we got the Iranians 

to the table to negotiate over their nuclear program. 

What I said about the, and what I testified about the Security 

Council resolutions, is that they give us the authority under international law to stop certain kinds of trade. So for example, as I 

mentioned before, weapons from Iran designated for the Houthis in 

Yemen were seized on the high seas because we had the right 

under a Security Council resolution. 

Mr. CLAWSON. But my question, Ambassador, is why would we 

outsource our economic leverage to someone else? We have the 

largest market in the world. I don’t want to ask permission from 

somebody else to use my market access as leverage. We will only 

get a fraction of our leverage. 

You are saying that we are making progress by using the U.N. 

and all these things you are talking about today. It may be a little 

bit, but why wouldn’t we use the full force of our financial system 

and the full force of our market leverage with everyone that does 

business with Iran? Because I don’t think the U.N. uses the full 

force of our economic leverage due to our market capacity. 

Ambassador BENJAMIN. I am not sure, sir, to what end you want 

to use all that? 

Mr. CLAWSON. To keep Israel safe and our friends from getting 

killed and thousands or millions of refugees. That is what I would 

like to use it for. 

Ambassador BENJAMIN. Well, I think that history has shown that 

a mixture of different instruments, diplomacy, sanctions, military 

pressure, and the like, are the way to go. When we have tried in 

the past to have far-ranging secondary sanctions, we have had 

some success, but we also have encountered some very, very serious resentment from our allies, and it puts us in a very difficult 

position when we want to get other things from them as well. So 

the policymakers’ job is to mix the instruments in a way that produces the desired effect. I think that our European friends if we 

suggest that we cut off all trade would say that is fine for you but 

not fine for us. 

Mr. CLAWSON. And you know what, I would say that if they 

wanted to do business in our big box retailers, which they all do, 

they may not like it; but they will go along. 

Do the other two of you all have anything to add? On what my 

point is? Am I off point here in any way? Am I wrong? Am I overstating the case of American power of economic leverage? 

99

Mr. MODELL. No, I don’t think you are overstating the economic 

leverage we have. I just think we have taken a dramatic shift to 

doing things in the way that Ambassador Benjamin has laid out in 

a multilateral sense, and we are not making——

Mr. CLAWSON. Well, it is not working. It is not working. 

Mr. MODELL. Until the Europeans see that doing business with 

Iran is not in their interests, and we can’t convince them otherwise, I don’t see any way of how it is going to go otherwise. 

Mr. CLAWSON. I yield back. Thank you. 

Chairman ROYCE. Thank you. I thought I would return just with 

the panel here to a couple of news reports from April of this year. 

One includes a report from Israel’s Security Service, publishing details of information on Hamas’ preparation for war with respect to 

new tunnels being dug, and the Security Service said they had obtained from a Hamas fighter and tunnel digger arrested in that 

month, he provided a wealth of information on the terror groups’ 

tunnel digging in the Gaza Strip, as well its methods for obtaining 

cash from Iran for the purpose of digging those tunnels. Iranian 

support, according to the report, came in the form of cash, weapons, and sophisticated electronic equipment meant to interfere with 

control signals for drones over the coastal enclave. 

And then the second report in the Wall Street Journal, according 

to a senior Western intelligence official, Iran’s Revolutionary 

Guards during the last few months have transferred tens of millions of dollars to Hamas’ brigades. Intelligence reports show that 

the funds have been transferred on the direct orders of General 

Soleimani, the commander of the Revolutionary Guards elite Quds 

Force who also directs the annual budget to finance Hamas’ military operation. 

The funds, according to the intelligence reports, are being used 

primarily to help Hamas rebuild the network of tunnels that were 

destroyed during the Israeli defense forces response to rocket attacks launched by Hamas, militants from Gaza last summer. So at 

least one or two intelligence agencies have a different assessment. 

Just for the record since we had a dialogue on that, Ambassador, 

I raise that point again. 

Ambassador BENJAMIN. I would just say that those reports, so 

there were signs of rapprochement. You know, Hamas was expelled 

from Tehran some years ago. There were signs of a rapprochement 

earlier this year. I believe that rapprochement didn’t happen during the summer because of Hamas’ extensive meetings with the 

Saudis. But I am relying here on open source, and I strongly recommend that you request a briefing from the CIA on the subject. 

Chairman ROYCE. Well, thank you very much, Ambassador. I appreciate that. And, again, I appreciate the testimony of all of our 

witnesses here today. And so with that, we will stand adjourned. 

[Whereupon, at 12:13 p.m., the committee was adjourned.] 

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