534. Before October 13, 2017, wasn’t the IRGC already subject to sanctions? What’s different about applying terrorism-related sanctions to the IRGC and foreign persons that are officials, agents, or affiliates of the IRGC?

Before October 13, 2017, the IRGC was blocked under Executive Order 13382 (relating to WMD proliferation), 13553 (relating to Iranian human rights abuses), and 13606 (relating to Iranian and Syrian human rights abuses via information technology), and persons who engaged in certain activity involving the IRGC were already subject to secondary sanctions. OFAC’s October 13, 2017 action designating the IRGC under E.O. 13224 (relating to counterterrorism) and OFAC’s October 31, 2017 action under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR), to block the property and interests in property of foreign persons that have been identified by OFAC as officials, agents, or affiliates of the IRGC carry additional consequences that limit certain activities with respect to the IRGC and foreign persons identified by OFAC as officials, agents, or affiliates of the IRGC. Certain exemptions available under the International Emergency Economic Powers Act (IEEPA) relating to personal communications, humanitarian donations, information or informational materials, and travel do not apply to transactions with persons designated under E.O. 13224 or otherwise blocked pursuant to the GTSR, which include the IRGC and foreign persons that have been identified by OFAC as officials, agents, or affiliates of the IRGC.