U.S. Sanctions Iran’s Metals

May 8, 2019

On May 8, President Donald Trump signed an executive order to impose sanctions on Iran’s iron, steel, aluminum, and copper sectors. The White House statement noted that those metals are “the regime’s largest non-petroleum-related sources of export revenue,” some 10 percent. The metals and mining industry has historically been an important source of employment as well. As of January 2018, some 620,000 people were working in the sector, according to the Boston-based consultancy Arthur D. Little. In May 2019, the Associated Press published a breakdown of the industry: steel mills employ some 50,000 workers, steel exports have been on the rise for more than five years, and metal-related industries employ about 2.2 million workers or 10 percent of the workforce, according to a report by Iran’s parliament. Trump warned that “Tehran can expect further actions unless it fundamentally alters its conduct.”

In May 2018, the United States withdrew from the 2015 nuclear deal, known formally as the Joint Comprehensive Plan of Action. It also specified 12 conditions as the basis for a new, more comprehensive agreement with Iran that would also address its ballistic missile program, support for terror, and human rights abuses. The new sanctions are the latest part of the Trump administration’s “maximum pressure campaign” to push Iran to change its policies and come to the negotiating table.

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The White House statement and press release, as well as Trump’s letter to Congress and a Treasury Department FAQ regarding the executive order are below. 
 

Statement from President Donald J. Trump Regarding Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran

TrumpOne year ago, I dramatically strengthened our national security by ceasing America’s participation in the horrible, one-sided Iran nuclear deal. Today, I am signing an executive order to impose sanctions with respect to Iran’s iron, steel, aluminum, and copper sectors, the regime’s largest non-petroleum-related sources of export revenue. 

Under the Iran nuclear deal, Iran was free to engage in and sponsor terrorist networks, develop its missile force, foment regional conflicts, unjustly detain United States citizens, and brutalize its own people, all while maintaining a robust nuclear infrastructure—not to mention, as we now know, its extensive nuclear weapons archive.

A lot can change in a year when we make bold decisions to defend America’s national security. Because of our action, the Iranian regime is struggling to fund its campaign of violent terror, as its economy heads into an unprecedented depression, government revenue dries up, and inflation spirals out of control. We are successfully imposing the most powerful maximum pressure campaign ever witnessed, which today’s action will further strengthen.

Over the last month, the United States has taken several steps to increase the effectiveness of our campaign. We designated the Islamic Revolutionary Guard Corps as a Foreign Terrorist Organization and increased the pressure on Iran ten-fold through full application of United States sanctions on Iranian oil exports. Today’s action targets Iran’s revenue from the export of industrial metals—10 percent of its export economy—and puts other nations on notice that allowing Iranian steel and other metals into your ports will no longer be tolerated.

Tehran can expect further actions unless it fundamentally alters its conduct. Since our exit from the Iran deal, which is broken beyond repair, the United States has put forward 12 conditions that offer the basis of a comprehensive agreement with Iran. I look forward to someday meeting with the leaders of Iran in order to work out an agreement and, very importantly, taking steps to give Iran the future it deserves.

 

PRESIDENT DONALD J. TRUMP IS CUTTING OFF FUNDS THE IRANIAN REGIME USES TO SUPPORT ITS DESTRUCTIVE ACTIVITIES AROUND THE WORLD

“We call on the regime to abandon its nuclear ambitions, change its destructive behavior, respect the rights of its people, and return in good faith to the negotiating table.” – President Donald J. Trump

ONE YEAR LATER: One year after withdrawing from the Iran nuclear deal, President Donald J. Trump continues to hold the Iranian regime accountable for its malign activity.

  • One year ago, President Trump withdrew from the fatally flawed, one-sided Iran deal and began the process of reimposing sanctions on the terror-sponsoring regime.
  • Today, President Trump is imposing additional sanctions on Iran’s metal sectors.
    • These sanctions are being imposed on Iran’s iron, steel, aluminum, and copper sectors.   
    • With this action, the United States has now imposed sanctions on Iran’s top three exports – oil, petrochemicals, and metals.
  • The Administration is imposing tougher sanctions on Iran than ever before because the regime continues to engage in destructive and destabilizing activities.
    • The regime has maintained its nuclear ambitions and continues to develop its ballistic missile capabilities and support terrorism.
  • The United States will aggressively enforce its sanctions, and those who continue to engage in sanctionable activity involving Iran will face severe consequences.  

WORST DEAL EVER NEGOTIATED: The Iran deal was a disastrous one-sided deal that failed to end Iran’s nuclear program and the full range of the regime’s malign activity.

  • President Trump withdrew from the Iran deal because it failed to protect American national security interests and enabled Tehran’s malign behavior.
  • The Iran deal left Iran with future pathways to pursue nuclear weapons.
    • The regime was allowed to preserve its nuclear infrastructure, keep enriching uranium, and continue research and development.
    • The deal included incomplete mechanisms for inspections and verification.
    • The extensive nuclear archive exposed by Israel proves Tehran pursued nuclear weapons and secretly preserved its blueprints and database to do so.
  • The deal failed to address Iran’s wide range of malign activities, including its global terrorist campaign, unjust detention of Americans, ballistic missile development, and more.
  • The regime received an influx of cash because of sanctions relief that it has used to engage in and support terrorism and to destabilize the Middle East.

MAXIMUM PRESSURE CAMPAIGN: President Trump launched a strategy to address the totality of Iran’s malign activities and ensure Iran is never allowed to develop nuclear weapons.

  • President Trump reimposed the nuclear-related sanctions that were lifted under the deal.
  • The President reimposed sanctions on Iran’s energy, shipping, and financial sectors.
  • President Trump ended prior significant reduction exceptions to oil sanctions on Iran, aiming to bring Iran’s oil exports to zero and deny the regime its principal revenue source. 
  • The Administration designated Iran’s Islamic Revolutionary Guard Corps as a Foreign Terrorist Organization, further targeting resources it uses for its global terror campaign. 
  • This maximum pressure campaign is working, having already denied the regime direct access to more than $10 billion in oil revenue since May 2018.
  • The Trump Administration will continue to apply maximum pressure on the Iranian regime until its leaders change their destructive behavior and return to the negotiating table.

 

TO THE CONGRESS OF THE UNITED STATES:

Pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), I hereby report that I have issued an Executive Order (the "order") with respect to Iran that takes additional steps with respect to the national emergency declared in Executive Order 12957 of March 15, 1995, and to supplement the authorities provided in the Iran Freedom and Counter-Proliferation Act of 2012 (subtitle D of title XII of Public Law 112-239).

The order takes steps to deny Iran revenue, including revenue derived from the export of products from Iran's iron, steel, aluminum, and copper sectors, that may be used to provide funding and support for the proliferation of weapons of mass destruction, terrorist groups and networks, campaigns of regional aggression, and military expansion.

The order blocks the property and interests in property of persons determined by the Secretary of the Treasury, in consultation with the Secretary of State:

  • to be operating in the iron, steel, aluminum, or copper sector of Iran, or to be a person that owns, controls, or operates an entity that is part of the iron, steel, aluminum, or copper sector of Iran;
  • to have knowingly engaged, on or after the date of the order, in a significant transaction for the sale, supply, or transfer to Iran of significant goods or services used in connection with the iron, steel, aluminum, or copper sectors of Iran;
  • to have knowingly engaged, on or after the date of the order, in a significant transaction for the purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminum, aluminum products, steel, steel products, copper, or copper products from Iran;
  • to have materially assisted, sponsored, or provided 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 the order; or
  • to be 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 the order.

The order also authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to impose correspondent and payable-through account-related sanctions on a foreign financial institution upon determining the foreign financial institution has, on or after the date of the order, knowingly conducted or facilitated a significant financial transaction:

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

I have delegated to the Secretary of the Treasury, in consultation with the Secretary of State, the authority to take such actions, including adopting rules and regulations, to employ all powers granted to the President by IEEPA as may be necessary to implement the order.

I am enclosing a copy of the order I have issued.

DONALD J. TRUMP

 

THE WHITE HOUSE,

May 8, 2019.

 

U.S. Department of the Treasury

Frequently Asked Questions Regarding Executive Order (E.O.) “Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran” of May 8, 2019


666. What does the Executive Order Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran of May 8, 2019 do?

The Executive Order of May 8, 2019 authorizes sanctions with respect to the iron, steel, aluminum, and copper sectors of Iran.

Section 1 of the E.O. of May 8, 2019 authorizes blocking sanctions on any person determined by the Secretary of the Treasury, in consultation with the Secretary of State:

(i) to be operating in the iron, steel, aluminum, or copper sector of Iran, or to be a person that owns, controls, or operates an entity that is part of the iron, steel, aluminum, or copper sector of Iran;

(ii) to have knowingly engaged, on or after the effective date of the order, in a significant transaction for the sale, supply, or transfer to Iran of significant goods or services used in connection with the iron, steel, aluminum, or copper sectors of Iran;

(iii) to have knowingly engaged, on or after the effective date of the order, in a significant transaction for the purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminum, aluminum products, steel, steel products, copper, or copper products from Iran;

(iv) to have materially assisted, sponsored, or provided 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 section 1; or

(v) to be 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 section 1.

Section 2 of the E.O. of May 8, 2019 authorizes correspondent and payable-through account sanctions on foreign financial institutions (FFIs) determined to have knowingly conducted or facilitated any significant financial transaction:

(i) for the sale, supply, or transfer to Iran of significant goods or services used in connection with the iron, steel, aluminum, or copper sectors of Iran;

(ii) for the purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminum, aluminum products, steel, steel products, copper, or copper products from Iran; or

(iii) for or on behalf of any person whose property and interests in property are blocked pursuant to the order.

Sections 3-13 of the E.O. of May 8, 2019 contain exceptions, definitions, and other implementing provisions related to the sanctions. [05-08-2019]

 


667. When does Executive Order Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran become effective?

The E.O. of May 8, 2019 became effective upon signing. [05-08-2019] 


668. Is there a wind-down period?

Yes. Persons engaged in transactions that could be sanctioned under the Executive Order Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran of May 8, 2019 will have a 90-day period to wind down those transactions without exposure to sanctions under the E.O. of May 8, 2019. Those persons should take the necessary steps to wind down transactions by the end of the 90-day wind-down period to avoid exposure to sanctions. Entering into new business that would be sanctionable under the E.O. of May 8, 2019 (the effective date of the E.O.) will not be considered wind-down activity and could be sanctioned even during the wind-down period. [05-08-2019] 


669. Does the Executive Order Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran expand upon existing sanctions relating to trade with Iran in certain raw and semi-finished metals, such as aluminum and steel?
 
Yes. the E.O. of May 8, 2019 expands upon existing sanctions under section 1245 of IFCA on the sale, supply, or transfer, directly or indirectly, to or from Iran of certain materials, including raw and semi-finished metals such as aluminum and steel, as described in subsections 1245(a)(l)(B) or (C) of IFCA.
 
In addition, the E.O. of May 8, 2019 explicitly targets the iron and copper sectors of Iran. [05-08-2019] 

670. Are there exceptions to the sanctions imposed under E.O. of May 8, 2019?
 
Yes. The sanctions authorized under the E.O. of May 8, 2019​ do not apply to transactions for the conduct of the official business of the United States Government or the United Nations (including its specialized agencies, programmes, funds, and related organizations) by employees, grantees, or contractors thereof. [05-08-2019] 

671. What is the definition of significant?
 
The Department of the Treasury anticipates adopting the interpretation of “significant” set out in 31 C.F.R § 561.404. See existing OFAC Iran FAQ 289. [05-08-2019]