• Andrew Skinner

U.S. Expands Scope of Iran Metals Sanctions.

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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