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U.S. Expands Scope of Iran Metals Sanctions.

Posted onJuly 31, 2020

The U.S. State Department has expanded its Iran sanctions pursuant to Section 1245 of the Iranian Freedom and Counter-Proliferation Act to include 22 specific materials (see below) used in connection with Iran’s nuclear, military, or ballistic missile programs. Those who knowingly transfer such materials may now be subject to U.S. sanctions.

The State Department has also continued in its belief that the Islamic Revolutionary Guard Corps (IRGC) controls Iran’s construction sector. As a result of this belief, the sale, supply or transfer of certain metals, including graphite or raw or semi-finished metals, to be used in connection with the construction sector of Iran may constitute conduct subject to U.S. sanctions. See U.S. the State Department's press release here.

The State Department has determined that the following materials are used in connection with Iran’s nuclear, military, or ballistic missile programs:

ALUMINIUM 319
ALUMINIUM 1100
ALUMINIUM 225
ALUMINIUM 6061
ALUMINIUM 6063
ALUMINIUM 6082
ALUMINIUM 7075
ALUMINIUM BROZE ALLOY UNS C63600 (CDA alloy 636)
ALUMINIUM OXIDE (Al2O3)
STEEL 302
STEEL 4130
STAINLESS STEEL 321
STAINLESS STEEL 316
A877 STEEL
A228 STEEL
100Cr6-52100 STEEL
350 MARAGING STEEL (also known as MARAGING STEEL350)
300 MARAGING STEEL (also known as MARAGING STEEL300)
UNS Cl7200-TDO1 [BERYLLIUM COPPER]
UNS C37000 – CuZn38Pb1
TUNGSTEN COPPER
ALUMINIUM POWDER with purity above 98 percent

See more information on Export Controls & Sanctions here.

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