Ok, Ok… yes, it’s a controversial title… but you’re reading the post, right? And there is a reason for it, just wait….

So, there’s been a push over quite a few years to designate quite a few Iranian entities under the OFAC counter-terrorism program. I wondered how many there were, so I asked Gemini.

The answer: 666 (see what I did there?)

Now, a few technical things – this was nowhere near the first total I got. I initially asked for a list of parties that had both Iran-related and counter-terrorism-related program tags – and I got back 10 rows. It took a few iterations – and instructions to identify the right tags by looking at the program tag definition page and use all the ones associated with Iran and counter terrorism. But that left me only at 32… which made no sense.

So, I asked it where it got the data from…

I sourced the data for the CSV file directly from the examples and information retrieved during our conversation, specifically from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) Recent Actionsupdates we processed together (from December 2025 back to December 2024) and the OFAC Program Tag Definitionspage I accessed.

To be specific:

1. Recent Actions Updates: The individuals like Ahmad Ghaedi, Hamidreza Heidari, and the Lashgarian family members were pulled from the February 2024 and December 2025 updates we discussed, where they were designated under both counter-terrorism (SDGT) and Iran-related authorities (IFSR/IRGC).
2. Established Designations: Major entities like the IRGC, Basij Resistance Force, Mahan Air, and Bank Saderat are historical, well-known dual-designated entities that appear frequently in OFAC’s public enforcement data and were referenced in the “Linked To” fields of the updates we processed.
3. Program Tag Definitions: I used the official OFAC definitions page (which I accessed in the previous step) to ensure I was capturing the correct codes (e.g., distinguishing that NPWMD is a proliferation tag often used alongside Iran tags, while SDGT and FTO are the specific counter-terrorism tags).

The dataset I generated was a representative sample constructed from these specific sources to demonstrate the formatting and logic you requested, rather than a direct download of the entire OFAC SDN list database.

Would you like me to show you how to download the complete and official raw data files directly from the Treasury Department’s website for comprehensive analysis?

I asked it to go get one of the SDN List files from the OFAC website… and apparently, at my personal use level, it couldn’t do that. Ultimately, I got the file myself and uploaded it to Gemini – that got me to 666.

Now, for the fun, non-technical piece of the puzzle: did these all fit under what we would consider “terrorists”?

I cannot provide personal opinions or make subjective determinations about whether specific sanctions designations are “fair” or “unfair,” nor can I definitively conclude which parties meet a common definition of “terrorism” versus those that do not. The designation of entities under counter-terrorism authorities is a legal and policy determination made by the U.S. government based on classified and unclassified intelligence.

However, I can analyze the publicly stated reasons provided by the U.S. Treasury and State Departments for these designations. This allows you to see the specific activities cited by the government that led to the application of counter-terrorism sanctions (such as SDGT or FTO tags) alongside Iran-related tags.

Analysis of Designations: Rationale vs. Common Definitions

The entities in your dataset (those with both Iran-related and Terrorism-related tags) generally fall into three primary categories based on OFAC’s designation criteria:

1. Direct Terrorist Activity & Support:
   • Entities: IRGC, IRGC-Qods Force, Kata’ib Hizballah, Asa’ib Ahl al-Haq, Hizballah.
   • Stated Rationale: These groups are often designated as Foreign Terrorist Organizations (FTO) or Specially Designated Global Terrorists (SDGT). The U.S. government cites direct involvement in acts of violence, bombings, kidnappings, and military operations outside of Iran (e.g., in Syria, Iraq, Lebanon, Yemen) that target U.S. personnel or civilians.
   • Relation to Definition: These justifications align closely with standard definitions of terrorism involving politically motivated violence against non-combatants.
2. Financial & Material Support (Facilitators):
   • Entities: Bank Saderat, Bank Mellat, Mehr Eghtesad Bank, Bonyad Taavon Basij, and various investment companies (e.g., Mehr Eghtesad Iranian Investment Company).
   • Stated Rationale: These entities are designated under counter-terrorism authorities (SDGT) not because they commit violent acts themselves, but because they provide “material support” (financial services, funding, logistics) to designated terrorist groups like the IRGC-QF or Hizballah. For example, moving funds to pay fighters or procuring technology for weapons programs.
   • Relation to Definition: While these are banks or investment firms, the “material support” provision in U.S. law allows for their designation under terrorism authorities. A layperson using a strict dictionary definition of “terrorist” (one who commits violence) might view these designations as distinct, but under U.S. sanctions law, financing terrorism is treated with equal severity.
3. Logistical & Technological Support:
   • Entities: Mahan Air, Caspian Air, various industrial groups (Shahid Hemmat, Shahid Bakeri), and individual procurement agents (e.g., Ghaedi, Heidari).
   • Stated Rationale: Airlines are often designated for transporting personnel and weapons for the IRGC-QF to conflict zones. Industrial groups are designated for developing ballistic missiles or UAVs used by these groups.
   • Relation to Definition: Similar to financial facilitators, these entities are designated for enabling the operations of the primary terrorist groups.

Summary of the 666 Rows

• Total Rows: 666
• “Unfair” Determinations: 0 (As an AI, I cannot label a legal designation as unfair).
• “Fair” Determinations: 0 (As an AI, I cannot validate the government’s classified intelligence).

Conclusion based on Public Record:

Every entity in the dataset has a specific legal basis for its designation published by the U.S. Treasury.

• Violent Groups: The core groups (IRGC, militias) are designated for direct violent activities.
• Support Network: The majority of the 666 rows (banks, individuals, companies) are designated for providing support to those core groups.

Yes, I know it was dumb to ask it if the designation was “fair” – but it did get me to what I wanted to know…

But the military groups like the IRGC still confused me, so I asked it how that was different from Russia invading Ukraine:

how are “military operations outside of Iran” considered “terrorism” rather than military operations like the Russian invasion of Ukraine?

and the response:

The distinction you are asking about touches on one of the most complex and debated areas of international law and U.S. foreign policy.

In general, the U.S. government and international law distinguish between “acts of war” (conducted by state militaries) and “terrorism” (conducted by non-state actors).

The Russian military is considered a state armed force engaged in a conventional (albeit illegal) war, while the IRGC is treated as a “hybrid” entity that uses terrorism as a primary tool of statecraft.

Here is the detailed breakdown of how the U.S. government makes that legal and policy distinction:

1. The “Law of War” vs. “Terrorism” Framework

• State Militaries (Russia): Under the Geneva Conventions and U.S. law, uniformed armed forces of a sovereign state are considered “lawful combatants.” When they cross a border to fight, they are engaging in an armed conflict.
  • If they kill civilians or bomb hospitals, those are War Crimes, not “terrorism.” War crimes have their own set of laws (laws of armed conflict) and tribunals (like the ICC).
  • Why this matters: If a Russian soldier kills a Ukrainian soldier on the battlefield, it is not a crime; it is an act of war. If a terrorist kills a soldier, it is a crime (murder/terrorism) because they have no “combatant privilege.”
• Terrorist Groups: Terrorism is typically defined in U.S. law (18 U.S. Code § 2331) as violent acts intended to coerce a civilian population or influence a government, usually committed by sub-national groups or clandestine agents.¹

2. The Exception: Why the IRGC is Designated “Terrorist”

For decades, the standard rule was that state militaries could not be “terrorists.” However, the U.S. designated the Islamic Revolutionary Guard Corps (IRGC) as a Foreign Terrorist Organization (FTO) in 2019—the first time a state entity received this designation.²

The U.S. justified this exception by arguing that the IRGC operates fundamentally differently from a normal military:

• Use of Proxies: Unlike the Russian army, which deploys its own uniformed troops to hold territory, the IRGC often exports violence through non-state “proxy” groups (like Hezbollah, Kata’ib Hizballah, or the Houthis). The U.S. views the IRGC as the “handler” for these terrorist organizations.
• Clandestine Operations: The IRGC-Qods Force specializes in covert assassinations, bombings, and kidnappings outside of defined war zones (e.g., plots in Europe, South America, or the U.S.) rather than conventional battlefield maneuvers.
• Material Support: The designation focuses heavily on the IRGC funding, training, and equipping designated terrorist groups, making them a “terrorist facilitator” in the eyes of the law.³

3. Why the Russian Military is Not Designated an FTO

Despite the documented atrocities in Ukraine, the U.S. has resisted designating the Russian military as a Foreign Terrorist Organization or Russia as a “State Sponsor of Terrorism.”

• Conventional Warfare: The invasion of Ukraine is viewed as a conventional state-on-state conflict. Even though it is an act of aggression, it fits the legal definition of “war” rather than “terrorism.”
• Diplomatic & Legal Risks: Designating a state military (especially a nuclear superpower) as a “terrorist organization” creates massive legal complications. It would technically make any U.S. ally who interacts with the Russian military (even for de-confliction in Syria or arms control talks) liable for “providing material support to terrorism.”
• Existing Tools: The U.S. argues it can already punish Russia effectively using “War Crimes” accusations and massive economic sanctions without needing the “Terrorism” label, which doesn’t fit the legal facts of a conventional invasion.

Summary Table

Feature	Russian Invasion of Ukraine	IRGC External Operations
Primary Actor	Uniformed State Military	Clandestine Operatives & Non-State Proxies
Legal Framework	Law of Armed Conflict (Geneva Conventions)	Counter-Terrorism Laws
Status of Violence	“Act of War” / “Aggression”	“Terrorism”
Crimes Committed	War Crimes / Crimes Against Humanity	Terrorist Acts / Material Support for Terror
U.S. Designation	Sanctioned for “Harmful Foreign Activities”	Foreign Terrorist Organization (FTO)

In short: Russia is treated as a “rogue state” fighting a dirty war, while the IRGC is treated as a “terrorist syndicate” hiding inside a state government.

Despite my expertise in this field, I am still very much a layperson when it comes to the legal & political end of all this stuff. I hope you find these answers interesting and enlightening.