U.S. Sanctions on Iranian Iron, Steel, Aluminum and Copper Sectors

The Office of Foreign Assets Controls (OFAC) announced they have amended the Iranian Financial Sanction Regulations to rename as the Iranian Sector and Human Rights Abuses Sanctions Regulations in order to implement Executive Order 13871 (E.O. 13871) of May 8, 2019, which imposed sanctions with Respect to the Iron, Steel, Aluminum and Copper Sectors of Iran.

In E.O. 13871, the President affirmed the U.S.’s policy to deny Iran paths to nuclear weapons and intercontinental ballistic missiles, and to counter Iran’s influence in the Middle East. ?The goal is to reduce Iranian government revenue derived from the export of products from their iron, steel, aluminum, and copper sectors, that may be used for funding weapons of mass destruction and military expansion.

Sanctions include the prohibition of:

  • The bringing to the U.S. of property and interests in property, from blocked parties who operates in the iron, steel, aluminum, or copper sector of Iran. Property and interests may not be transferred, paid, exported, withdrawn, or otherwise be dealt with.
  • The purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminum, aluminum products, steel, steel products, copper, or copper products from Iran.
  • Providing any financial, material, or technological support to blocked parties.
  • The donations of certain articles, such as food, clothing, and medicine, intended to be used to relieve human suffering, by, to, or for the benefit of any blocked party, unless authorized by OFAC.

Exemptions do exist for transactions which are the official business of the Federal Government or the United Nations.

OFAC provides definitions of ‘aluminum’, ‘aluminum products’, ‘aluminum sector of Iran’, ‘copper’, ‘copper products’, ‘copper sector of Iran’, ‘iron’, ‘iron products’, steel’, ‘steel products’, ‘iron sector of Iran’, and ‘steel sector of Iran’, in their Frequently Asked Questions on E.O. 13871.

A 90-day wind down period for these sanctions began on May 8, 2019, and expired on August 6, 2019.

If you have any questions regarding the status of the Iranian Sanctions on the Iron, Steel, Aluminum and Copper Sectors, Livingston can help!? Please contact either your Livingston account manager or our regulatory affairs group at usregaffairs@livingstonintl.com

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