PHILADELPHIA – October 7 – 2026. The Middle East Forum today published its Iran accountability record: two reports, a briefing, a fact sheet, and the Iran Ledger, a public database of the officials, forces, banks, and companies of the Islamic Republic of Iran. Together they document the killings, mass detention, torture, and executions that followed the uprising of December 28, 2025, name those responsible, and show which governments have sanctioned them and which have not.
Blood Money: Crimes against Humanity in Iran
“Blood Money” (39 pages) covers December 28, 2025, to October 4, 2026. It records the Iranian government’s own figure of 3,038 dead; 7,007 deaths and 53,777 arrests documented by the Human Rights Activists News Agency (HRANA) in the first 50 days; 4,219 dead identified by name by Iran Human Rights, among them 281 children; and at least 31 protesters executed, according to a joint statement of more than 40 states at the U.N. Human Rights Council on September 30, 2026. The U.N. Independent International Fact-Finding Mission on Iran found that the violations include the crimes against humanity of murder, imprisonment, torture, and other inhumane acts (A/HRC/63/61, para. 121). The report traces the chain of command from the Supreme Leader through the Islamic Revolutionary Guard Corps, the Basij, and the Revolutionary Courts and finds that these acts satisfy the elements of crimes against humanity under Article 7 of the Rome Statute.
The report asks the European Union, the United Kingdom, Canada, and Australia to designate Supreme Leader Mojtaba Khamenei and Supreme National Security Council secretary Mohsen Rezaei, neither of whom appears on their lists, and asks universities, pension funds, and asset managers to divest from the designated IRGC and foundation conglomerates. A two-page fact sheet gives each figure with its source. Every figure is a minimum count from a named source, and deaths in the war that began on February 28, 2026 are counted separately.
The Hammer and the Anvil
“The Hammer and the Anvil: Iran’s Post-MOU Repression and the Economic Network That Sustains It” (31 pages) examines June 1 to August 10, 2026, the 10 weeks around the Islamabad Memorandum of Understanding. Twelve U.S. Treasury and State Department actions in that window produced 170 new U.S. designees: 46 individuals, 90 entities, and 34 vessels. Allied governments added 13 in total. Exactly one of the 170 has any allied counterpart, and Canada and Australia made no Iran-related designation in the ten weeks. Twenty-five companies the Commerce Department placed on its Entity List in October 2025 for diverting U.S. technology to Iran’s weapons and drone programs are still absent from Treasury’s sanctions list. The report sets out eight recommendations, from allied mirror-listing of the 170 to an OFAC review of the 25 companies.
Iran Watch Briefing
The “Iran Watch Briefing” (18 pages) reports 40 verified developments from June 1 to August 10, 2026, with developments to October 4. It leads with the finding of U.N. High Commissioner for Human Rights Volker Türk that Iran executed at least 56 people on national-security charges between March 19 and August 5, 2026, 27 of them linked to the January protests, with more than 100 others at risk.
The Iran Ledger and the Crimes against Humanity Campaign
The Iran Ledger holds 959 public profiles; 891 carry at least one designation. It records 905 designation events across the United States, the European Union, the United Kingdom, Canada, and Australia, and 259 open gaps across 58 profiles, cases where one of those governments has screened a party and not designated it. Data are current as of October 6, 2026. The Sanctions Monitor shows each party’s status in all five jurisdictions, the Blood Money List names the officially designated targets, and the Evidence File gives each casualty and detention figure by source and date.
The campaign is built on that record. The Ledger’s Take Action docket sets out 12 asks for the people who can act on them:
- Legislators and their staff in the five governments, beginning with mirror-listing the 170 post-memorandum U.S. designees.
- Compliance officers and correspondent banks, who screen the parties named in the record.
- Institutional investors, asked to report exposure to the screen by name.
- Universities and pension boards, asked to use the divestment statutes already on the books.
- Each ask copies as a sourced paragraph, ready for a letter, a memo, or a screening note.
“The regime killed thousands of its own citizens in a matter of days and has hanged protesters since. That is a matter of record, set out by the United Nations and by the monitors who counted the dead one name at a time,” said Gregg Roman, executive director of the Middle East Forum. “The money that pays for it moves through parties that one government has sanctioned and four have not. The Iran Ledger names each of them, so that governments, banks, and pension boards can close those gaps.”
Corrections and source questions go to info@meforum.org.
About the Middle East Forum
The Middle East Forum, an applied policy research organization founded in 1994, promotes American interests in the Middle East and protects the West from Middle Eastern threats.
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