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Web Alert: Wind down period ends on US sanctions against Iran’s metal industries

09 August 2019

On 8 May 2019 President Trump issued Executive Order (EO) 13871 which imposed broad sanctions on Iran’s iron, steel, aluminium and copper sectors, as they are the regime’s largest non-petroleum-based source of export revenue. It also imposed sanctions against those who engaged in transactions which supported these sectors. Further details are provided in an earlier web alert which can be found in the link on the right.  

The sanctions imposed under the EO were subject to a 90 day winding down period whereby persons engaged in transactions that involved the Iranian metal sectors were given time to wind down these transactions without exposure to sanctions. This winding down period ended on 6 August 2019.   OFAC has made it clear that entering into new transactions that would be considered sanctionable under the EO on or after 8 May 2019 would not be considered winding down activity. It also means that any transactions subject to sanctions under the EO which were not concluded by the 6 August 2019 are now subject to potential sanctions.

The US Treasury Department’s Office of Foreign Asset Control (OFAC) has issued frequently asked questions (FAQs) which provide further details regarding the EO which can be found here.

Shipowners are at risk of being subject to US sanctions and having their property blocked in the US if they transfer to or from Iran significant goods or services used in connection with the iron, steel, aluminium or copper sectors of Iran. These risks now exist even if the underlying sales transaction for the cargo pre-dated 8 May 2019. Further details can be found in a client alert issued by Freehill Hogan & Mahar LLC which can be found in the attachment on the right.