U.S. Findings on Iran Pursuant to the Iran Freedom and Counter-Proliferation Act (IFCA) of 2012 (May 2025)

Date issued: May. 21 2025

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (164 words)

Notes:

1) Compare Increasing Iran Metals Sanctions Targeting Iran’s Nuclear, Military, and Ballistic Missile Programs and the IRGC (IFCA Sec. 1245 Guidance) (the only other IFCA section 1245 metals determination as of the date of this writing). The State Department also determines that “Iran’s construction sector [is] controlled directly or indirectly by the Islamic Revolutionary Guard Corps (IRGC),” such that, per section 1245 of IFCA, a person that “sells, supplies, or transfers, directly or indirectly, to or from Iran [covered materials] to be used in connection with the” construction sector is subject to sanctions. The practical impact of this addition of “construction” sector to the section 1245 secondary sanctions authority does not seem particularly meaningful given that, under EO 13902, it is already...