Imposing Sanctions With Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran

This executive order imposes blocking sanctions on persons operating in or transacting with Iran's iron, steel, aluminum, and copper sectors, and authorizes secondary sanctions on foreign financial institutions facilitating such trade. It also suspends U.S. entry for designated persons, building on the national emergency first declared in 1995.

Federal Register Open PDF 84 FR 20761

Impact dates

May 8, 2019
Sanctions effective for transactions on or after this date

Key directives

Block all property of persons operating in Iran's iron, steel, aluminum, or copper sectors
Block property of persons engaging in significant transactions for sale/supply/transfer of goods/services to Iran's metals sectors on or after May 8, 2019
Block property of persons engaging in significant transactions for purchase/transport/marketing of Iranian metals products on or after May 8, 2019
Authorize secondary sanctions on foreign financial institutions facilitating prohibited transactions
Prohibit opening or restrict maintenance of correspondent/payable-through accounts for sanctioned foreign financial institutions
Suspend entry into U.S. of aliens meeting section 1(a) criteria
Prohibit donations to blocked persons under IEEPA section 203(b)(2)
Prohibit evasion, avoidance, and conspiracy to violate order

Who is ordered

Timeline

Immediate

Blocking sanctions effective upon signing (May 8, 2019) for designated persons
Visa suspension effective immediately for covered aliens

Near term (90d)

Treasury/State designations of specific persons and entities expected
Foreign financial institutions must assess exposure to avoid correspondent account restrictions

Long term

Ongoing enforcement and potential expansion of sanctions designations
Structural shift in Iran's metals export markets away from U.S.-linked financial system

Risks & tensions

No prior notice required for designations (Section 9), raising due process concerns
Secondary sanctions risk forcing foreign banks to choose between Iran metals trade and U.S. market access
Broad 'should have known' knowledge standard (Section 8(e)) creates compliance uncertainty for businesses
Explicit disavowal of Algiers Accords relevance (Section 12) signals hardened bilateral posture
Metals sectors represent significant non-oil revenue for Iran; escalation risk if Iran retaliates in region