Thank you very much, Mr. Chair.

I understand the committee is focusing on three issues: Whether the federal government should list the IRGC as a terrorist entity, the connection between people or assets in Canada and the IRGC, and paths forward to support Iranian human rights activists and other political refugees. Let me comment specifically on these three issues.

I won't go through the litany of all the things that the IRGC has been up to. You've heard that in the hearings, and I don't need to add to that litany. As we all know, the federal government has referred to the IRGC as a terrorist organization, called its leaders terrorists, taken measures to prevent its leadership from entering Canada and designated the Quds Force as a terrorist entity. The House of Commons has passed non-binding motions to designate the IRGC as a terrorist entity, so why not take the final step to actually list it as a terrorist entity? As I understand it, there are three, perhaps four, major concerns.

First, a terrorist designation might affect low-level individuals who are forced to serve in the IRGC as part of their mandatory military service.

Second, such a designation would be resource-intensive and place enormous demands on our security and intelligence services.

Third, under Canada's Criminal Code, a terrorist entity is defined as a person, group, trust, partnership, or fund or an unincorporated association or organization. Does the IRGC technically meet the legal test? Some would say no, because it's a state actor, not a non-state actor.

Fourth, such a designation would prevent a potential resumption of diplomatic relations with Iran. That is perhaps one of the reasons, Mr. Chair, that the United Kingdom has not designated the IRGC as a terrorist entity, a question you put to one of the previous panellists.

Let me go to the first concern.

I draw your attention to a recent publication by the Atlantic Council that points out that since 2010, 80% of the IRGC conscripts actively chose to join the IRGC. There are further reports that many of those conscripts were already members of the Basij Resistance Force, which is a volunteer paramilitary organization. Some 20% of the membership do come from unprivileged, underprivileged and poor areas, and they have probably been forcibly conscripted into the IRGC.

Concerns about sanctioning individuals who have been coerced to join the organization and have been subjected to its indoctrination programs must be weighed against the broader risk of allowing entry to Canada of members of the IRGC who may be involved in various kinds of illicit activities that support the organization and Iranian interests. Again, that litany is a long one: money laundering, illegal business activities, spying on Iranian exiles, issuing death threats and so forth.

Globally, those risks are growing. I would draw your attention to a letter sent by a group of U.S. senators to EU officials last year, wherein they pointed out that in July 2012, Bulgarian authorities arrested an IRGC operative suspected of planning an attack on a synagogue in Sofia. In 2016, German officials arrested IRGC-sponsored assassins. In April 2022, a detained IRGC operative was identified for conducting assassination plans in Germany and France.

The second concern has to do with resource implications, as has been pointed out by a number of the witnesses here, but should that be an excuse for inaction? Should we let the proverbial underfunded bureaucratic tail wag the policy dog here?

I would point out that on October 7, 2022, the Prime Minister announced that he was going to provide $76 million to strengthen Canada's capacity to implement sanctions against Iran. That's a fair bit of change, in my estimation. I think any designation of the IRGC as a terrorist organization should be accompanied by a legislative requirement to report on how existing funds are being used, and whether additional resources are required to support our intelligence and security services.

The third concern may require a legislative fix. I think Bill C-350, a private member's bill, might provide for a series of amendments to the Criminal Code and the Immigration and Refugee Protection Act that would go one step further than the Harper government's enactment of the Justice for Victims of Terrorism Act and its amendments to the State Immunity Act in 2011.

The concerns about people and assets with close ties with the IRGC are well documented by our media. In the testimony I submitted to you, I've provided hyperlinks to numerous cases, identifying individuals who have been involved with and have ties with the IRGC. I'm not going to name them publicly here, but that evidence or information is readily available in public sources.

Designating the IRGC as a terrorist organization may make it easier to expel these individuals from Canada, because the burden of evidence is lowered to do so. It will also prevent IRGC individuals from entering Canada.

Canada can also do more to support Iranian human rights activists, artists, journalists and other political refugees. The World Refugee & Migration Council, of which I am president, recently partnered with the University of Ottawa in a highly innovative program sponsored by Open Society Foundations. It supports the work of human rights activists who have been forced to leave their country of origin for challenging injustices—many of whom are located here in Canada, including Iranians—and who seek to continue their activism here to raise the flag on what's happening in their home country. That's the kind of creative approach that merits support.

Thank you.