Background

The State Department has issued an advisory warning of the significant sanctions risk posed by transfers or exports to Iran of graphite electrodes and needle coke, which are essential materials for Iran’s steel industry. The consequences of being designated related to such transactions are substantial and include potential blocking sanctions. 

For more information on export controls and compliance, please contact attorney Kristine Pirnia.

The advisory states that those who engage in such transactions, including exporters, shippers, vessel operators, and others, are at risk regardless of their nationality or location. Such individuals and entities should therefore implement effective due diligence policies, procedures, and internal controls prior to conducting any transfer or export of graphite electrodes or needle coke to Iran, regardless of whether Iran’s steel industry is involved. In addition, the particulars of a transfer or export, such as the shipping line used or the intended end-user, could cause such activities to be covered by other Iran sanctions-related authorities.

The advisory reiterates that the U.S. administers and enforces comprehensive trade restrictions with respect to Iran as set forth in the Iranian Transactions and Sanctions Regulations, which prohibit most direct and indirect transactions with Iran by U.S. persons or within the U.S. unless authorized by the Treasury Department or exempted by statute. Further, absent an applicable exemption from Treasury, foreign persons, including foreign financial institutions, are prohibited from processing transactions to or through the U.S. in violation of these prohibitions, including transactions through U.S. correspondent accounts for or on behalf of Iranian financial institutions, other persons located in Iran, or where the benefit of those services is otherwise received in Iran.

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