US Sanctions Team: Richard Burke, Nicole Erb, Claire A. DeLelle, Cristina Brayton-Lewis, Kristina Zissis, Peter Chessick, Emily Holland, Sandra Jorgensen, Margaret Spicer, Alana Toabe, Ata Akiner
On January 10, 2020, the President signed a new Executive Order (EO), “Imposing Sanctions With Respect to Additional Sectors of Iran,” targeting Iran’s construction, mining, manufacturing, and textiles industries. On the same day, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted Iran’s metals industry by blocking the property of Iran’s largest steel, aluminum, copper, and iron manufacturers, and targeted its senior leadership by blocking the property of eight senior regime officials, adding them all to its list of Specially Designated Nationals and Blocked Persons (SDN List).2 US Persons that deal with the parties designated on January 10, 2020, or that are designated in the future pursuant to the EO, would be in violation of US sanctions. Non-US parties that deal with such designated parties risk being found to engage in sanctionable activity, which could result in their becoming sanctioned parties and restrict them from commercial and financial dealings with the United States.
New Iranian Executive Order
The new EO, effective January 10, 2020, authorizes blocking and visa sanctions against persons determined to be operating in targeted sectors of the Iranian economy and foreign financial institutions facilitating certain related transactions, as discussed below.
Sanctions Targeting Iranian Construction, Mining, Manufacturing, and Textiles Sectors
The EO prohibits dealings involving the United States or US persons in the property and interests in property of persons determined by the Secretary of the Treasury, in consultation with the Secretary of State, to:
• Operate in the construction, mining, manufacturing, or textiles sector of the Iranian economy, or any other sector of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State;
• Have knowingly engaged in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with a sector specified in or determined pursuant to this EO;
• Have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person blocked pursuant to this EO;