brief - Iran 911 Case

Affid. 63; see also Ex. 8, Clawson Affid. 35; Ex. 6, Lopez-Tefft Affid. 24-25.The fact that the IRGC has provided funding and training for Hizballah, HAMAS,and al Qaeda terrorist operations targeting American and Israeli citizens has been welldocumented for more than two decades. Ex. 8, Clawson Affid. 36. For more than aquarter century since its creation, Iran has provided Hizballah with $100 million to $300million in direct financial support annually. Ex. 8, Clawson Affid. 66; Ex. 6, Lopez-Tefft Affid. 31; Ex. 7, Bergman Affid. 26.In providing support to these three organizations, the IRGC isacting as an official agency whose activities are tightly andcarefully controlled by the Iranian government through theSupreme Leader and his representatives. The terrorism trainingprovided to Hizbollah, HAMAS, and al Qaeda by the IRGC is partof an official policy of the Iranian government.Id. (emphasis omitted). Less than two weeks after 9/11, on September 23, 2001, the U.S.Treasury Department designated the IRGC-Qods Force as a terrorist organization for―providing material support to the Taliban and other terrorist organizations,‖ and, on June28, 2005, the U.S. State Department designated the IRGC as a ―foreign terroristorganization.‖ Ex. 6, Lopez-Tefft Affid. 65 (emphasis omitted).The MOIS (in Farsi, VEVAK) is Iran‘s world-class intelligence agency. With30,000 employees, it is the largest intelligence agency in the Middle East. Its annualbudget is somewhere between $100 million and $400 million. Ex. 8, Clawson Affid.38; Ex. 11, Banisadr testimony, p. 12. Created in 1985 after the ouster of presidentAbolhassan Banisadr, its predecessor was not the Shah‘s intelligence agency, SAVAK,which had been dissolved, but rather Supreme Leader Ayatollah Khomeini‘s ownintelligence service, which had no name and was engaged in the business ofassassinations. Ex. 11, Banisadr testimony, pp. 11-12. Many of the U.S. State45