Michael Jacobson is a senior fellow in The Washington Institute's Jeanette and Eli Reinhard Program on Counterterrorism and Intelligence.
Brief Analysis
As wider peace negotiations continue, U.S. officials should carefully consider the many moving parts needed for a proxies deal to succeed—and what Washington would do if Tehran starts flagrantly violating its terms.
Late last month, the Trump administration presented Iran with a fifteen-point plan to end the war, including a demand that Tehran cut off its support for foreign proxy and partner groups like Hezbollah, Hamas, and the Yemeni Houthis, among others. The regime appears likely to reject this proposal—unsurprising given how vital these groups have been to “exporting the revolution” and extending Tehran’s influence throughout the region. Yet it is still important to consider what such an agreement would entail, and how the United States could verify and enforce its terms—in part to bolster the international community for potential postwar scenarios in which the regime simply redoubles its terrorist proxy activities.
Composition of an Agreement
Any U.S.-Iran agreement on “proxy” support would need to be as detailed and comprehensive as possible, covering the full scope of financial, military, terrorist, and training activities in support of such groups, and tailored to reflect the nuances of Iranian assistance to each specific group. (Note: for simplicity’s sake, the term “proxy” is hereinafter used to mean any subnational terrorist group or militia that has operationally allied with the Iranian regime; this includes groups like the Houthis, whom many experts regard more as strategic partners with Tehran than fully subordinate proxies.) The aim would be to leave Tehran with minimal space to exploit any ambiguities. Policymakers also need to understand that effectively enforcing such a deal would be an incredibly complex effort, requiring the cooperation of many governments, multilateral organizations, and the private sector, not to mention top-priority U.S. attention in terms of allocating diplomatic, intelligence, and law enforcement resources.
Broadly speaking, Iran would need to agree not to provide support of any type to any terrorist or militia entities or individuals—whether defined using U.S. government terrorist designation lists or a newly agreed list formulated at the United Nations. As a starting point, the list would need to include Hezbollah, Hamas, Palestinian Islamic Jihad, the Houthis, and several Iraqi Shia militias. And in either case, it must have the flexibility to include new entrants, if needed, to ensure that Tehran and its proxies cannot circumvent the process by renaming entities or creating new ones. More specifically, the regime would have to accept the following conditions:
Iran will no longer provide money, valuables, or any other type of financial support or resources to such proxies, whether through the formal financial sector or informal channels (e.g., exchange houses, hawalas, cryptocurrency platforms). In particular, it must shut down the oil smuggling schemes that have served as one of its primary means of supporting proxies (particularly the Houthis and Hezbollah) in recent years.
Iran will cease providing proxies with any military equipment, including missiles, rockets, drones, and large or small arms. It will also refrain from technical assistance intended to help them design or improve weapons on their own.
Iran will no longer provide proxies with any dual-use items that could have military applications, including drone components, chemical precursors, and guidance and communications systems.
Iranian military personnel, particularly from the Islamic Revolutionary Guard Corps (IRGC), will no longer provide any type of training to proxies inside Iran or abroad.
Iran will cease all types of military, terrorist, and operational planning with all proxies, shutting down any joint units and planning cells currently involved in such efforts.
Iran will cease engaging in deceptive techniques to hide its involvement in transactions with proxies, such as creating front companies, falsifying documents on end users, and using false flags for shipping.
Iran will stop providing any intelligence to proxies, particularly information that could be used to plan or conduct attacks.
Iran will expel all proxy officials currently residing on its territory, as well as remove all IRGC personnel located in proxy territories.
Iran will turn over al-Qaeda members located on its territory to the United States or another appropriate country, and refrain from providing safe haven to any other designated terrorist groups or figures.
Major Gaps
Even if Iranian negotiators agree to cease support for proxies as part of a larger deal, the regime’s track record suggests it is highly unlikely to fulfill all of these commitments. Monitoring, uncovering, and stopping violations would therefore be essential. Yet several extant gaps would hinder U.S. and international efforts in this regard:
There are no UN Security Council resolutions formally declaring that key Iranian proxies like Hezbollah and Hamas are terrorist organizations. Unless this changes, many countries would not feel obligated to take action against Tehran’s support for such groups.
Some governments have allowed Iranian proxy activity on their soil because they are ideologically aligned with the regime or the proxies themselves, or because they have other motivations for doing so.
Many governments lack the capability to track or disrupt illicit Iranian networks and schemes.
Many private institutions—including in the financial sector—lack the information necessary to uncover Iran-linked actors and are currently ill equipped to be on the front lines of this battle. For example, companies that make or transport dual-use items are often unwilling or unable to conduct the due diligence necessary to determine the end user of their products. As a result, Tehran and its proxies can easily create front companies, with minimal fear that companies or financial institutions will uncover the Iranian connections.
Even if a proxies agreement is implemented and authorities obtain evidence that Iran has violated the prohibition against transferring military equipment or technology, determining whether these items were provided before the agreement or after would be a challenge.
The bottom line is clear: in the current environment, Iran would not have much difficulty evading sanctions and enforcement efforts in order to continue arming, financing, and training its proxies around the world.
Toward Effective Monitoring and Verification
To give a proxies agreement any chance of success, the United States and its partners would need to take several steps:
Dramatically increase U.S. resources dedicated to this issue set, particularly on the law enforcement, intelligence, and diplomatic fronts. The State Department has suffered major cuts over the past year, so it would need to be staffed up to lead a diplomatic campaign aimed at mobilizing the international community behind the enforcement campaign. Likewise, counter-proxy efforts would need to become a top priority for the FBI, the Department of Homeland Security, and the broader intelligence community. The Trump administration would also need to surge resources to the Treasury Department’s Office of Terrorism and Financial Intelligence, empowering it to issue new sanctions against entities involved in any violations and to track and counter any evasion efforts. Currently, this office is relatively small and saddled with responsibility for numerous sanctions programs (e.g., against Russia, Venezuela, and cybercriminals), so increasing its duties without providing sufficient resources could overwhelm it.
Greatly deepen cooperation with the private sector. This includes major collaborative efforts with companies that track cryptocurrencies. To date, such firms have done impressive work on identifying IRGC and proxy use of crypto; Washington could help expand those efforts by providing government funding. U.S. authorities should also ramp up information sharing with financial institutions—for example, declassifying intelligence that helps them better understand Tehran’s modus operandi, identify bad actors linked to the regime, and track their activities.
Seek more cooperation from countries where Iran and its proxies have been the most active. The following countries would be particularly critical to this effort: China, Iraq, Lebanon, Oman, Qatar, Syria, Turkey, the United Arab Emirates, and Yemen. Iranian proxies are active in all of these locales, and their governments have done far too little to address the threat. Washington should convince them to do more—either willingly or through ramped up pressure.
Enlist critical multilateral support. A UN Security Council resolution acknowledging Iran’s commitment to the agreement and prohibiting further support to proxies would be essential. Even if the UN is unwilling to label these proxies as terrorists, it could still bolster the deal by barring Iran from materially assisting them. This in turn would give member states additional cause (and cover) to investigate and crack down on the regime’s activities abroad. For example, authorities could ramp up inspection and detention regimes related to Iranian maritime shipments and cross-border transfers. They could also use travel bans to highlight the activities of significant IRGC operatives and trainers. In addition, an expert panel could be established to monitor and publicly report on Iranian compliance with the UN resolution. For countries that continue allowing Iran and its proxies to exploit their territory, Washington could press the Financial Action Task Force (FATF) to add them to its black list or “gray list.” Two countries—Turkey and the UAE—were removed from the gray list in 2024, but problems persist, so the Trump administration should press them to improve their performance or risk being relisted. As further leverage, the Treasury Department could sanction any countries or financial institutions that continue serving as havens for illicit Iranian activities.
Provide technical assistance to willing countries that lack the capability to detect and disrupt Iranian financial, procurement, and logistical activity. This could include training, mentorship, and equipment for entities such as the Yemeni Coast Guard, financial regulators in Iraq, and border security forces in Djibouti, Lebanon, Oman, and Syria.
Continue building broad international coalitions against Iran-linked terrorism. The United States should use the Law Enforcement Coordination Group (LECG) and the Countering Transnational Terrorism Forum (CTTF)—the sole global platforms established to deal with Iranian terrorism—as primary platforms to educate other governments and increase international cooperation on these issues.
Conclusion
Although the outcome of the Iran war is still uncertain, the hardline IRGC will likely maintain major influence over the government, so supporting proxies will presumably remain a regime priority for the foreseeable future. As negotiations continue, U.S. officials should therefore give careful attention to what a “proxies agreement” would encompass, what steps Washington could take to successfully implement such a deal, and—perhaps most important—what the United States and its partners would do if Tehran decides to violate whatever terms are reached.
Michael Jacobson, a senior fellow in The Washington Institute’s Reinhard Program on Counterterrorism and Intelligence, formerly served as director of strategy, plans, and initiatives in the State Department’s Counterterrorism Bureau.
