Background

The Office of Foreign Assets Control has imposed sanctions on a China-based supplier of graphite electrodes, a key element in steel production; 12 Iranian producers of steel and other metals products; and three foreign-based sales agents of a major Iranian metals and mining holding company.

Specifically, these entities have been added to OFAC’s List of Specially Designated Nationals and Blocked Persons for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, an Iranian company designated under Executive Order 13871 for operating in Iran’s steel sector.

As a result, all property and interests in property of these entities that are or hereafter come within the U.S. or the possession or control of U.S. persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in.

OFAC emphasizes that persons who engage in certain transactions with the designated entities may themselves be exposed to sanctions. Furthermore, any foreign financial institution that knowingly conducts or facilitates a significant transaction for or on behalf of these entities could be subject to U.S. correspondent or payable-through account sanctions.

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

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