The Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State have announced further sanctions toward Iran by designating and placing on the Specially Designated Nationals (SDN) List a China-based supplier of graphite electrodes, twelve Iranian producers of steel and other metals products, three foreign-based sales agents of a major Iranian metals and mining holding company, and a subsidiary of the Islamic Republic of Iran Shipping Lines (IRISL).  According to an OFAC press release, the Iranian metals sector “is an important revenue source for the Iranian regime, generating wealth for its corrupt leaders and financing a range of nefarious activities, including the proliferation of weapons of mass destruction and their means of delivery, support for foreign terrorist groups, and a variety of human rights abuses, at home and abroad.”  A State Department press release stated, “The United States will continue to aggressively implement sanctions with respect to the Iranian regime, those who evade sanctions, and others who enable the regime to fund and carry out its malign agenda of repression and terror.”

These actions were taken pursuant to Executive Order 13871, which imposes sanctions on several sectors of the Iranian economy, including Iran’s steel sector.  See also Update of May 10, 2020.  The list providing detailed information on each designated entity is available here.  As a result of these designations, all property and interest in property of these SDNs and any entities in which they own a 50% or greater interest are blocked and may not be dealt with by U.S. persons.  Foreign persons dealing with these entities may also expose themselves to U.S. sanctions, and any foreign financial institutions that knowingly conduct or facilitate a significant transaction for or on behalf of these sanctioned entities may be subject to U.S. correspondent or payable-through account sanctions.