Through their brave protests, the Iranian people are sending a message to the world: the Islamic Republic is repressive and unreformable. Its fearsome security services are the beating heart of the Iranian establishment. Long overdue were the recent U.S. sanctions on the regime’s Morality Police force, which harasses and detains women for purported immodest dress, and in whose custody twenty-two-year-old Mahsa Amini died on September 16.
But that entity cannot be viewed apart from Iran’s broader command-and-control structure, headed by Iranian Supreme Leader Ali Khamenei and President Ebrahim Raisi. That’s why America should not lift any sanctions on those two officials in order to revive the Iran nuclear deal. Quite the opposite: the U.S. and European Union need to impose new sanctions on Khamenei and Raisi for abusing the human rights of Iranians.
Sanctions Need to Hold, and Increase
The Biden administration sanctioned the Morality Police last week under Executive Order (E.O.) 13553, which then-President Barack Obama issued in 2010. The E.O. authorized freezing property and banning visas for Iranian government officials, or their agents, “responsible for or complicit in, or responsible for ordering, controlling, or otherwise directing, the commission of serious human rights abuses” against Iranians, people in Iran, or the families thereof.
Iran’s Police Complex Structure
The Morality Police reports to the Islamic Republic’s Law Enforcement Forces (LEF), itself sanctioned under E.O. 13553. The LEF, in turn, is technically affiliated with the Interior Ministry, whose head is nominated by the president only after being preapproved by Khamenei. However, in practice, the supreme leader and the Islamic Revolutionary Guard Corps (IRGC) have primary influence over the police enterprise. Further, Khamenei retains approval power over the appointments of the senior brass of the LEF, including its commander—traditionally an IRGC officer—and deputy commander. Likewise, the interior minister chairs the National Domestic Security Council (NDSC)—and holds a seat on the Raisi-chaired Supreme National Security Council (SNSC)—which has executed crackdowns on protests. The SNSC answers only to the supreme leader.
This is why Iranians marching throughout the country are chanting “Death to Khamenei” and “Death to the Dictator.” They know who their ultimate oppressors are—the men giving the orders.
Biden Administration Still May Lift Sanctions
And this is why lifting existing U.S. sanctions on Khamenei and Raisi—as reports claim the Biden administration might do as part of a return to the nuclear deal—would be a very negative signal to the Iranian people. The regime is reportedly insisting on the rescinding of E.O. 13876, which authorizes sanctions on the supreme leader’s office and appointees. Some of the most repressive regime figures are sanctioned under that order, including Khamenei, his son Mojtaba, and Raisi. And 13876 is a non-nuclear executive order—nowhere in its text is Iran’s nuclear program even mentioned.
Instead of rescinding 13876, Washington should go even further and sanction Khamenei and Raisi under E.O. 13553 for human rights abuses in addition. Both men should have been sanctioned accordingly years ago, well before Mahsa Amini’s death.
For example, amid gas protests in 2019, Khamenei reportedly told security officials, “The Islamic Republic is in danger. Do whatever it takes to end it. You have my order.” The regime proceeded to kill as many as 1,500 Iranians. Khamenei could be giving similar directions to suppress the current demonstrations.
In fact, for years, Khamenei’s direct subordinates in his office have been sanctioned under E.O. 13553. One is Asghar Mir Hejazi, his intelligence and security advisor, who is likely part of the deliberations regarding responding to the protests. Also in this power center is Mojtaba Khamenei, who liaises with the IRGC and its Basij paramilitary force, both of which form the core of Iran’s multilayered domestic security network and are deployed as necessary to reinforce the police. But Mojtaba, like his father, is only sanctioned under E.O. 13876 and not 13553, despite being implicated in grave human rights violations. It’s time to correct that as well. Iranians have been chanting against Mojtaba in the ongoing protests, saying, “Mojtaba, may you die and not become supreme leader.”
Raisi also merits these same penalties. As first deputy chief justice in 2009, he personally “was involved in the regime’s brutal crackdown” on the Green Movement protests, the U.S. government said. Later, Raisi served as chief justice and a standing member of the SNSC when it coordinated the organized brutality against Iranian citizens during the 2019 gas protests. And now he is signaling that the regime will violently suppress the ongoing marches, saying Iran must “deal decisively with those who oppose the country’s security and tranquility.”
European leaders should undertake similar targeted sanctions. Since 2013, the EU has levied only two rounds of sanctions on Iran’s security dragnet, undercutting the EU’s stated commitment to human rights. In 2019, it sanctioned Iran’s Intelligence Ministry following an attempted bomb plot in France. Then, in 2021, the EU belatedly applied human rights sanctions to Iranian officials following the state-sanctioned violence against the 2019 protesters. Those designated included the heads of the IRGC, Basij, and LEF—all of whom ultimately report to the supreme leader, whom the EU should therefore sanction as well. The Europeans should list Raisi, too, given that he served on the SNSC during this timeframe, that the EU has sanctioned past chief justices like Sadegh Larijani, and that Raisi’s own role as president places him in a position to crack down on demonstrations through the SNSC.
As Iranians risk their lives seeking freedom, America and the EU must stand with them. Standing with Iranians means punishing the Islamic Republic—from Khamenei and Raisi down—for human rights abuses, instead of rewarding it with sanctions relief to resuscitate the nuclear deal. It means listening to the demands of the Iranian people, not the demands of their oppressors at the negotiating table.
Jason M. Brodsky is the policy director of United Against Nuclear Iran (UANI). His research focus includes Iranian leadership dynamics, the Islamic Revolutionary Guard Corps (IRGC), and Iran’s proxy and partner network. He is on Twitter @JasonMBrodsky. Alan Goldsmith is an adviser for UANI. His research focus is Iranian human rights abuses. He previously served as a professional staff member for the U.S. House Committee on Foreign Affairs. He is on Twitter @AlanGoldsmith.