President Trump issued Jan. 10 an executive order authorizing the imposition of additional sanctions against any individual or entity owning, operating, trading with, or assisting the textiles, construction, manufacturing, and mining sectors of the Iranian economy. Administration officials said these will be both primary and secondary sanctions, meaning they could be imposed against third-party countries in Europe, Asia, and elsewhere. Treasury Secretary Steve Mnuchin said the measures will remain in place until the Iranian regime “stops the funding of global terrorism and commits to never having nuclear weapons.”  

In addition, the Treasury Department’s Office of Foreign Assets Control announced specific sanctions against Iran’s largest steel, iron, aluminum, and copper manufacturers; 17 Iranian metals producers and mining companies; a network of three China- and Seychelles-based entities doing business with Iranian metals producers; and a vessel involved in the purchase, sale, and transfer of Iranian metals products as well as the provision of critical metals production components to Iranian metal producers.

According to Treasury, all property and interests in property of these persons that are in the U.S. or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the U.S. that involve any property or interests in property of blocked or designated persons. 

Persons that engage in certain transactions with these persons 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 persons could be subject to U.S. correspondent or payable-through account sanctions.

For more information, please contact export attorney Kristine Pirnia.

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