overturn any secular law. Id., 21. He ―wields sole authority to command, appoint, anddismiss every major leadership figure of any importance in the <strong>Iran</strong>ian governmentsystem,‖ all military commanders, the chief of the judicial system, all heads of importantfoundations, directors of national television and radio, ―and even the Friday prayerleaders in major mosques.‖ Ex. 6, Lopez-Tefft Affid. 20.There have been only two Supreme Leaders during the entirety of the IslamicRepublic of <strong>Iran</strong>: the leader of the Islamic Revolution, Ayatollah Ruhollah Khomeini,and, after his death in 1989, the current Supreme Leader, Ayatollah Ali Khamenei. Id.,19; Ex. 8, Clawson Affid. 22-23; Baer, The Devil We Know, p. 55. The SupremeLeader is assisted by an informal politburo, which has no name and no publicaccountability; indeed, its membership shifts with the secret currents of regime politics.Ex. 11, Banisadr testimony, pp. 13-14; 22; Baer, The Devil We Know, p. 66; see also Ex.6, Lopez-Tefft Affid. 21.Other than the Supreme Leader and a few influential ayatollahs, the mostpowerful entities in <strong>Iran</strong> are the elite <strong>Iran</strong>ian Revolutionary Guards (―IRGC‖), alsoknown as the Sepah Pasdaran, and the Ministry of Intelligence and Security (―MOIS‖ or―VEVAK‖ or sometimes ―VAJA‖). Baer, The Devil We Know, pp. 34-36, 127; Ex. 8,Clawson Affid. 29-39.Established in the wake of the 1979 revolution, the IRGC is the key component ofthe revolutionary political structure of <strong>Iran</strong>. As both the guardian and the ―striking arm‖of the Islamic Revolution, the IRGC is answerable only to the Supreme Leader, not to thepresident. Ex. 8, Clawson Affid. 29-35. The IRGC is a special entity unto itself, partmilitary force, part paramilitary force, and part business conglomerate. Baer, The Devil43
We Know, p. 127; Ex. 6, Lopez-Tefft Affid. 23. It has its own arms procurementnetwork and its own prisons. IRGC officers have powers of arrest, and they hold aplurality of seats in the parliament. It owns and controls Imam Khomeini InternationalAirport in Tehran. 28 Indeed, the IRGC is a major factor in the <strong>Iran</strong>ian economy: it ownshundreds of companies and commercial interests, particularly in the oil and gas sector,telecommunications and infrastructure, and it holds billions of dollars in assets andgovernment contracts. For example, one IRGC company has been awarded contractsworth billions of dollars by government agencies and the National <strong>Iran</strong>ian Oil Company.Baer, The Devil We Know, pp. 34-35; Ex. 8, Clawson Affid. 37; Ex. 2, Timmerman 2ndAffid. 202; see also Ex. 11, Banisadr testimony, pp. 19-20.The IRGC also has a special foreign division, known as the Qods (or Quds,meaning ―Jerusalem‖) Force, which ―is the arm of the IRGC that works with militantorganizations abroad and promotes terrorism overseas . . . .‖ Ex. 3, Byman Affid. 62;see also Ex. 6, Lopez-Tefft 25; Ex. 11, Banisadr testimony, p. 19. (The sealedtestimony of Witnesses X, Y, and Z provide additional information about the activities ofthe Qods Force in international terrorism.) The Qods Force has a long history ofengaging in coups, insurgencies, assassinations, kidnappings, bombings, and armsdealing. It has a well-deserved reputation for being the most organized, disciplined, andviolent terrorist organization in the world. Baer, The Devil We Know, pp. 35-36. TheIRGC and its Qods Force are ―deeply integrated into the regime‘s leadership,‖ ―[t]heIRGC commander reports directly to <strong>Iran</strong>‘s Supreme Leader,‖ and ―in some instances theIRGC is the most important voice in determining <strong>Iran</strong>‘s foreign policy.‖ Ex. 3, Byman28 The IRGC‘s nearly arbitrary power was evident by the manner in which it simply seized the new ImamKhomeini International Airport just before its opening and dedication in May 2004. The IRGC nowowns and controls everything there. Baer, The Devil We Know, p. 72.44
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provided material support to al Qae
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