No, it is accurate. Connection to 9/11 is irrelevant.
What is relevant is listed in tne designation announcement of the IRGC as an FTO.
Particularly:The Iranian regime is responsible for the deaths of at least 603 American service members in Iraq since 2003. This accounts for 17% of all deaths of U.S. personnel in Iraq from 2003 to 2011, and is in addition to the many thousands of Iraqis killed by the IRGC’s proxies.