Treasury Targets Iranian UAV Program, Steel Industry, and Automobile Companies in Response to Unprecedented Attack on Israel (Press Release)

Date issued: Apr. 18 2024

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TURBOFAC Commentary (524 words)

Notes:

1) This designation notice is notable for the portion pertaining to OFAC “designating five companies in multiple jurisdictions providing component materials for steel production to Iran’s Khuzestan Steel Company (KSC), one of Iran’s largest steel producers, or purchasing KSC’s finished steel products”.

As noted in the notice, “KSC was designated pursuant to E.O. 13871 on January 10, 2020 for operating in the iron, steel, aluminum, or copper sectors of Iran.” In addition to the “operating in” provision, EO 13871 includes a secondary sanction provisions aimed at persons that have “to have knowingly engaged...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”. In addition to that, the EO includes the standard quasi-secondary sanctions targeting provision aimed at persons that “materially...