To: Kaja Kallas

High Representative of the Union for Foreign Affairs and Security Policy / Vice-President of the European Commission

Copies: EU Sanctions Envoy; European Commission DG FISMA; relevant Council working groups on restrictive measures (RELEX); Member State national competent authorities for sanctions enforcement; Anti-Money Laundering Authority (AMLA)

Dear High Representative Kallas,

We write as Iranians and allies to request initial, practical measures toward supporting the EU’s IRGC terrorist designation. As first steps, we respectfully request: (i) prompt publication of the authoritative legal reference, listing language, and scope in a form the public can readily verify;

(ii) a clear, secure, non-public evidence-intake pathway that enables civil society to submit structured, verifiable information concerning IRGC proxy networks operating in Europe; and

(iii) publication of a concise IRGC proxy-network taxonomy to standardize triage, review, and follow-up. These steps will help ensure restrictive measures do not stop at a label while activity continues through other identities and structures.

This is urgent for two reasons. First, there is a publication and terminology gap: days after the designation was announced, many members of the public have been unable to locate a clear, authoritative publication setting out the exact scope and listing language, and public messaging has continued to use imprecise phrasing (e.g., “Iran’s revolutionary guard”), creating avoidable ambiguity that proxy networks can exploit. Second, the human urgency is immediate: Iranians face ongoing lethal repression and risk of execution linked to officials of the Islamic Republic and affiliated structures; delay, ambiguity, and enforcement blind spots have real-world consequences.

Immediate requested actions

1. Publish the authoritative legal reference and scope Provide the official reference for the designation, including the exact listing language and scope, in a way the public can readily verify.

2. Explicitly activate an evidence-intake channel for proxy networks. The European Union already has a sanctions reporting mechanism (including the EU Sanctions Whistleblower channel). Issue written guidance that submissions concerning proxy networks tied to the ISLAMIC Revolutionary Guard Corps (IRGC)—including entities or individuals acting on behalf of, at the direction of, for the benefit of, or owned/controlled by such networks—are in scope for assessment and, where credible, referral for follow-up.

3. Adopt and publish a clear taxonomy for IRGC “legs” in Europe. Publish a concise set of categories so investigators, institutions, and civil society can consistently identify proxy patterns and submit relevant information in an actionable format. Suggested taxonomy:

3(a) Security and repression apparatus. Networks linked to IRGC-aligned security structures and affiliated forces such as the Basij, including intelligence/security/policing cut-outs operating through intermediaries, fronts, and informal networks used for intimidation, surveillance, coercion, and repression.

3(b) Governance and political control enablers. Political and institutional structures that provide cover, patronage, or policy alignment for the security apparatus (including legislative/governance bodies and their intermediaries), and that materially enable repression or protect networks through access, influence, or narrative laundering.

3(c) Judicial and coercive legal machinery. Actors and networks connected to courts, prosecutions, detention, and coercive “legal” mechanisms that facilitate repression, including intimidation of dissidents and cross-border pressure campaigns conducted through proxies and intermediaries.

3(d) Propaganda, media, and influence infrastructure. State propaganda and influence operations, including IRIB (Islamic Republic of Iran Broadcasting), and associated ecosystems that distribute messaging, harassment, intimidation, or narrative laundering through third-party entities, non-official accounts, and coordinated influence efforts.

3(e) Sanctions evasion, procurement, and logistics. Procurement agents, brokers, facilitators, and logistics/shipping nodes that enable restricted acquisition, sanctions evasion, or circumvention—often using layered counterparties, opaque corporate structures, and intermediary jurisdictions.

3(f) Asset parking and beneficial-ownership concealment. Shell companies, layered ownership chains, trusts, nominees, intermediaries, and professional facilitation used to conceal beneficial ownership/control, park assets, and preserve access in Europe under other names.

3(g) Family intermediaries and close associates used as proxies. Immediate family members and close associates of senior IRGC/affiliated-structure officials who function as nominees, beneficial owners, directors, intermediaries, or operational liaisons—usedto hold assets, open entities, and preserve access in Europe in ways that would be restricted if conducted directly by designated actors.

4. Proactive scrutiny of reported entities to prevent safe haven Europe should not become a safe haven where regime-connected wealth and influence can be parked through proxy “legs.” Establish a risk-based enhanced review pathway, consistent with due process and applicable law, for reported proxy entities and intermediaries, including scrutiny of beneficial ownership/control indicators, nominee arrangements, unexplained asset accumulation, and circumvention or facilitation patterns.

5. Commit to basic aggregate accountability every 90 days Publish non-sensitive, aggregate metrics so the public can evaluate whether action is occurring in practice (e.g., volume of proxy-network submissions received; share assessed as sufficiently identified to be actionable; referrals made; and aggregate outcomes where legally possible).

We respectfully urge you to treat these steps as the minimum immediate operational response: publish the legal scope clearly, recognize the IRGC’s proxy ecosystem as the real operational target, and enable structured evidence intake so authorities can identify and disrupt the “legs” that keep these networks active in Europe. This is a concrete, lawful, and measurable way to ensure the designation has practical effect and does not remain only a statement.

Respectfully,

The undersigned,