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Alerts and Updates

Executive Order Adds New Sanctions to Iranian Iron, Steel, Aluminum and Copper

May 10, 2019

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The EO provides for the blocking of property and interests in property of persons who have been designated by the secretary of Treasury as blocked persons.

On May 8, 2019, President Donald Trump signed an Executive Order (EO) imposing additional sanctions on Iran with respect to the iron, steel, aluminum and copper sectors of that country.

These additional sanctions are a part of the policy of the United States “to deny Iran all paths to both a nuclear weapon and intercontinental ballistic missiles… .” The EO also states that it is the intent of the United States “to deny the Iranian government revenue, including revenue derived from the export of products…” from the above described metals sectors.

The EO provides for the blocking of property and interests in property of persons who have been designated by the secretary of Treasury as blocked persons, pursuant to the EO.

Generally, the names of such persons are added to the Office of Foreign Assets Control’s (OFAC) Special Designated Nationals and Blocked Persons List and/or Sector Sanctions List.

It is worthy of note that the EO’s scope not only covers persons that knowingly are engaged in significant transactions involving the metals described above, but also covers persons that knowingly engage in significant transactions involving products produced from such metals. 

A winding-down period regarding these new sanctions may be anticipated based on how previous sanctions have been handled. Such a period would serve to protect manufacturers of products that employ Iranian-origin metals from the adverse penalties of the EO.

The EO also covers persons who have materially assisted, sponsored or provided financial, material or technological support or goods or services in support of anyone who is a blocked person, or who is “controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked… .”

In addition to the foregoing, financial institutions that conduct any activities that are contrary to the prohibitions of the EO may be subject to the specific sanctions set forth therein. These include significant prohibitions relating to opening and maintaining of correspondent accounts or payable-through accounts in the United States.

For a complete review of the scope of the EO, please refer to the OFAC Recent Actions website.

Duane Morris will continue to follow developments on this topic.

For More Information

If you would like further information about this Alert, please contact Brian S. Goldstein, any member of the International Practice Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.