New US Executive Order Targeting Iran’s Iron, Steel, Aluminium and Copper

May 2019

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On 8 May 2019, President Trump signed a new Executive Order expanding sanctions to target Iran’s iron, steel, aluminium and copper sectors.

Section 1 of the Executive Order provides for the imposition of an asset freeze against persons who:

  • operate in the iron, steel, aluminium, or copper sectors of Iran;
  • own, control, or operate an entity that is part of the iron, steel, aluminium, or copper sectors of Iran;
  • knowingly engage, on or after 8 May 2019, in a significant transaction for the sale, supply, or transfer to Iran of significant goods or services used in connection with the iron, steel, aluminium, or copper sectors of Iran;
  • knowingly engage, on or after 8 May 2019, in a significant transaction for the purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminium, aluminium products, steel, steel products, copper, or copper products from Iran;
  • materially assist, sponsor, or provide financial, material, or technological support for, or goods or services in support of any person whose property and interests in property are blocked pursuant to this Section; or
  • are owned or 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 pursuant to this Section.

Section 2 provides for the imposition of restrictions against foreign financial institutions who knowingly conduct or facilitate any significant financial transaction in respect of:

  • the sale, supply, or transfer to Iran of significant goods or services used in connection with the iron, steel, aluminium, or copper sectors of Iran;
  • the purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminium, aluminium products, steel, steel products, copper, or copper products from Iran;
  • any person whose property and interests in property are blocked pursuant to the Order.

The restrictions are subject to a 90 day winding-down period which authorises transactions related to commitments entered into pre-8 May 2019. However, the accompanying FAQs make clear that entering into any new business that would be sanctionable under the Order could be sanctioned even during the winding-down period.

Links to the Executive Order and FAQs can be found below:

Executive Order 8 May 2019

FAQs related to Executive Order 8 May 2019