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Financial Services Law Insights and Observations

OFAC sanctions additional actors in Iranian steel sector

Financial Crimes OFAC Department of Treasury Iran Sanctions Of Interest to Non-US Persons OFAC Designations

Financial Crimes

On January 5, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against a Chinese supplier of graphite electrodes, 12 Iranian producers of steel and other metal products, and a major Iranian metals and mining holding company’s three foreign-based sales agents. OFAC’s actions are taken pursuant to Executive Order 13871 (covered by InfoBytes here), which authorizes the imposition of sanctions on persons determined to operate in Iran’s iron, steel, aluminum, and copper sectors, which OFAC identified as providing “funding and support for the proliferation of weapons of mass destruction, terrorist groups and networks, campaigns of regional aggression, and military expansion.” As a result of the sanctions, “all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC further noted that its regulations “generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons,” and warned foreign financial institutions that knowingly conducting or facilitating significant transactions for or on behalf of the designated persons could subject them to U.S. correspondent account or payable-through sanctions.

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