Executive Order Targets Persons Operating in Iron, Steel, Aluminum and Copper Sectors of the Iranian Economy

President Donald J. Trump signed an Executive Order authorizing the imposition of sanctions on persons operating in the iron, steel, aluminum or copper sectors of the Iranian economy.

The Executive Order targets non-U.S. companies and financial institutions (U.S. persons are already prohibited from engaging in most Iran-related dealings), and authorizes secondary sanctions against those who operate in the identified sectors of the Iranian economy, or who engage in or facilitate "significant" transactions related to those sectors. OFAC issued six FAQs in connection with the Executive Order. Individuals and entities engaged in transactions sanctionable under the Executive Order were given a 90-day grace period to wind down those transactions.