Iranian women in Canada hold banners and portraits of Mahsa Amini, during a protest against her death in Toronto, Canada on September 22, 2022. REUTERS./

September 9, 2022
The House of Commons
Ottawa, Ontario, K1A 0A6 

Dear Parliamentarian,

We the members of Canadians for Democracy in Iran (CDI), an Ontario registered  nonprofit organization, write to you today with grave concerns regarding the uninvestigated criminal acts and the growing influence of the Islamic Republic Guards Corps (IRGC) in Canada.

As you know, since its inception in 1979, the Islamic Republic of Iran (IRI) through the IRGC has used terrorism as an integral part of its foreign and military policies to: 1) squash democracy movements at home 2) to spread the Iranian regime’s revolutionary ideology abroad 3) and to spark turmoil throughout the Middle East. The IRGC’s lethal activities that have taken the lives of several hundred individuals have been carried out either directly through the Quds Force, the IRGC’s elite unit, or through its proxies. However, it is of paramount importance to recognize that the IRI’s foreign policy is also pursued through other destructive means, such as non-kinetic activities, front companies, religious foundations, cultural centres, etc.

Furthermore, it is important to note that IRI’s support for terrorism is not just limited to the Middle East. Since the mid 1990s, there have been dozens of terrorist plots attributed to the  IRGC outside the region. These include the bombing of the AMIA Jewish Center in Buenos Aires that took the life of 85 people; the attempt to murder the Saudi Ambassador in the U.S.; the foiled bomb plot in Kenya; etc. More recently, the IRGCI agents have perpetuated their acts of terror in the United States. Masih Alinejad, a vocal Iranian-American political activist, was threatened outside her residence in Washington DC by an IRGC agent. According to the U.S. Justice Department, an Iranian national and member of Iran’s Revolutionary Guard Corps targeted John Bolton, the former U.S.  President’s National Security Advisor. Moreover, the evidence of serious and credible threats on the lives of former Secretary of State Mike Pompeo and former Trump-administration-Iran-envoy, Brian Hook, were disclosed by the State Department. Most recently, Salman Rushdie, an author of international renown, was nearly fatally attacked on a religious decree issued by the leader of IRI.

As you know, one of the IRGC’s  most heinous acts of terror occurred in 2020, when the terrorist group took the lives of 176 people by shooting down Ukrainian flight 752 over Tehran. Of the total number of innocent victims who died that day, 138 passengers onboard had ties to Canada.

In light of the above, our humble opinion is that Canada’s response to these threats has been inadequate. While we applaud the step taken in June 2018 by the House of Commons to overwhelmingly designate the IRGC a terrorist organization, we are deeply concerned that four years later this motion is still waiting to become passed into law. We recognize this failing,  despite several efforts by Canada parliamentarians to move this initiative forward. In serving as a beacon of hope and freedom to so many worldwide, Canada cannot allow the IRGC to be portrayed as anything other than what they are: an organized instrument of chaos, terror, and violence both inside and outside of Iran. This reality runs contrary to the IRGC’s false claim to be a “people’s army”.

Moreover, designating the Quds Force– the offshore branch of the IRGC- and not the full IRGC under the Canadian Criminal Code has created a plethora of legal anomalies. For one, the IRI would not care if Canada kept the Quds Force on the terrorist list,  given that the Quds Force does not have significant economic assets. But the regime does care about foreign investment and international business, particularly in the energy sector. On the other hand, the designation of the full IRGC under the Canadian criminal code would not just be symbolic. In fact, it would have real-world consequences by making it hazardous for many banks and companies to do business with Iran, given the number of industries that are owned or controlled by the IRGC.

It is of importance to note that the Canadian public opinion appears to be in favour of more punitive measures.  According to recent public opinion polls, there is clear Canadian consensus that foreign nationals who have not been held accountable in their home countries for gross human rights violations should not be allowed to travel or hold assets in Canada with impunity. We therefore strongly urge the government to consider subjecting the IRGC to the 2017 “Justice for Victims of Corrupt Foreign Officials Act”- Canada’s version of the Magnitsky Act- which has been designed to do just that.

Therefore, we call upon the government of Canada to extend the JVCFOA act to the entire IRGC for the following reasons:

  • The designation of the IRGC as a terrorist organization will help the families of the victims of the Ukrainian airliner by allowing them to sue the Iranian government for damages suffered as a result of the plane’s destruction.

(b)  According to Canada’s Criminal Code, an entity can be added to the terrorist list if there are reasonable grounds to believe that it has knowingly carried out, participated in, or facilitated a terrorist activity. Therefore, the recent Ontario Superior Court of Justice ruling that the shooting down of Flight PS752 by Iran was an “intentional” act of terrorism paves the way for the government to designate the IRGC as a terrorist organization.

(c)  IRGC agents are currently operating and fundraising on Canadian soil. Hence, failing to designate the IRGC in its entirety as a terrorist organization endangers not only Canada’s Iranian but also Jewish communities.

(d) Subjecting the IRGC to JVCFOA will automatically enforce travel bans against high-placed officials of the IRI, including:  Razm Hosseini, the former Iranian Vice President; Mahmoud Reza Khavari, the former chairman of the board and managing director of Bank Melli Iran (the Islamic republic’s largest bank and fugitive embezzler wanted by Interpol); and more recently, Tehran’s Police Chief, Morteza Talaie and Hamid-Reza Reza Zadeh, the son of Iran’s Vice President Ensieh Khazali.

(e) Enacting JVCFOA will counter the IRGC’s money-laundering efforts and its other illicit activities through its proxies in Canada. The IRGC is responsible for commanding and coordinating Hezbollah’s global activities, including drug smuggling and money laundering,  and thus it makes sense for the investigation to target both organizations.

(f)  Not listing the IRGC as a terrorist organization also legitimizes the very organization that funds Hamas and Hezbollah, two organizations that Canada has already placed on this list.

(g)  In a nutshell, listing the IRGC in its entirety as a terrorist organization will help decrease the risk that this organization poses to Canada and Canadians.

We thank you for taking the time to allow us to express our concerns, and we look forward to discussing this with you further. We would be most appreciative of  receiving a response from you on this matter.


CDI Board of Directors

Mr. Afshin Afshin Jam, Dr. Siavash Assadpour, Ms. Khatereh Azarfar, Dr. Ata Hoodashtian, , Ms. Venus Torabi, Dr. Farrokh Zandi

Toronto, Canada

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