US Imposes Additional Sanctions Against Iran in Response to Missile Attack | Practical Law

US Imposes Additional Sanctions Against Iran in Response to Missile Attack | Practical Law

On January 10, 2020, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) imposed additional sanctions against Iran, including the designation of Iranian government officials and metal manufacturers. In addition, President Trump issued Executive Order 13876 imposing sanctions on the construction, mining, manufacturing, and textiles sectors of the Iranian economy.

US Imposes Additional Sanctions Against Iran in Response to Missile Attack

Practical Law Legal Update w-023-5808 (Approx. 4 pages)

US Imposes Additional Sanctions Against Iran in Response to Missile Attack

by Practical Law Commercial Transactions
Published on 13 Jan 2020USA (National/Federal)
On January 10, 2020, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) imposed additional sanctions against Iran, including the designation of Iranian government officials and metal manufacturers. In addition, President Trump issued Executive Order 13876 imposing sanctions on the construction, mining, manufacturing, and textiles sectors of the Iranian economy.
On January 10, 2020, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) imposed additional economic sanctions against Iran, including the designation of certain Iranian government officials and the largest steel, iron, aluminum, and copper manufacturers in Iran. Concurrently, President Trump issued a new Executive Order authorizing the imposition of sanctions targeting additional sectors of the Iranian economy including the construction, mining, manufacturing, and textiles sectors. The restrictions are a response to Iran's January 8, 2020 missile attack on Ain al-Assad air base in Iraq, where US and coalition service members are stationed. Iran fired the missiles after the US killed Iranian military commander Qassem Soleimani in a drone strike on January 3, 2020.

Background

US sanctions against Iran began in 1979 when a group of Iranians took more than 60 US citizens hostage at the American Embassy in Tehran. Tensions between the two countries have persisted since that time. They began to subside in 2015 when President Barack Obama reached a deal with Iran that that lifted some sanctions in exchange for Iran ending its nuclear program. Also known as the Joint Comprehensive Plan of Action (JCPOA), the agreement allowed Iran to sell oil on the international market. Other signatories to the JCPOA were the United Kingdom, France, Russia, China, and Germany.
On August 6, 2018, President Trump issued an Executive Order Reimposing Certain Sanctions with Respect to Iran, citing defects in the JCPOA as the basis for his decision. US withdrawal from the JCPOA meant that that it could reimpose sanctions against Iran's oil sector, which would have put the US in violation of its obligations under the deal. For more information about the JCPOA, US withdrawal from this agreement, and reimposition of sanctions on Iran, see Legal Updates, Updated: President Trump Signs Executive Order Reimposing US Sanctions on Iran and US Reimposes Second Set of Sanctions on Iran, Targeting Oil, Shipping, and Banking Sectors.

January 10, 2020 Sanctions Against Iran

OFAC's action on January 10, 2020 targets:
  • The 13 largest steel and iron manufacturers in Iran, who collectively generate billions in sales annually.
  • The top four companies operating in the Iranian aluminum and copper sectors.
  • Eight senior Iranian regime officials who, according to OFAC, were involved in and complicit with the January 8, 2020 missile attack on the airbase in Iraq, thereby advancing the regime’s destabilizing objectives.
  • A network of three China- and Seychelles-based entities involved in the purchase, sale, and transfer of Iranian metals products, as well as in the provision of critical metals production components to Iranian metal producers and a vessel owned by one of these entities.
Concurrent with these designations, President Trump Issued a new Executive Order Imposing Sanctions With Respect to Additional Sectors of Iran. This Executive Order authorized the Secretary of the Treasury, in consultation with the Secretary of State, to impose sanctions against persons operating in or transacting with additional sectors of the Iranian economy, including:
  • Construction.
  • Mining.
  • Manufacturing.
  • Textiles.
These sanctions are intended to cut off revenue used by the Iranian regime to fund and support its nuclear program, missile development, terrorism and terrorist proxy networks, and malign regional influence.

Sanctions Implications

All property and property interests of the designated persons that are in the US or in the possession or control of US persons must be blocked and reported to OFAC and US persons are generally prohibited from dealing with the designated persons. Additionally, persons that participate in certain transactions with the designated persons or in the specified sectors may themselves be sanctioned. Finally, any foreign financial institution that knowingly facilitates or conducts a significant transaction for or on behalf of the designated persons or in connection with the specified sectors of the Iranian economy could be subject to certain sanctions.
For an overview of economic and trade sanctions administered by OFAC, see Practice Note, Export Regulation: OFAC Economic and Trade Sanctions.