On October 31, 2019, the US State Department made two determinations under the Iran Freedom and Counter-Proliferation Act that further expand sanctions on Iran.
First, the State Department determined that the construction sector of Iran is controlled by the Islamic Revolutionary Guard Corps. As a result, the transfer to or from Iran of raw and semi-finished metals, graphite, coal, and software for integrating industrial purposes will be sanctionable if those materials are for use in the Iranian construction sector.
Second, the State Department determined that certain mangenese brazing foil and stainless steel products are used in connection with Iran's nuclear, military, or ballistic missile programs. As a result of this determination, the transfer to or from Iran of such materials – regardless of the end-use or end-user – will be sanctionable.
A related State Department press release notes that these actions are part of a continuing US campaign to "maximize economic pressure on the Iranian regime".
Once again, the scope for trading with Iran free from potential exposure to US sanctions has narrowed.
Get in touch with your usual Clyde & Co contact if you need specific advice on how this affects you.
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