The US has broadened the scope of its sanctions on steel, stainless steel, aluminum and copper trade with Iran in a move to stop imports into the country of specialized metals that it says could be used in Iran's nuclear, ballistic missile and military programs, deemed by the US to pose a grave threat to international peace and security.
Most of the products had already been targeted by secondary sanctions against Iran, previously published by the US. The latest list gives more detailed descriptions of some of the products previously included in more general categories.
US Secretary of State Mike Pompeo late July 30 announced the State Department has identified 22 specific materials that it alleges are used in connection with Iran's nuclear, military, or ballistic missile programs. "Those who knowingly transfer such materials to Iran are now sanctionable pursuant to Section 1245 of the Iranian Freedom and Counter-Proliferation Act," Pompeo said in a statement.
The sanctions also cover trade in graphite and raw or semi-finished metals which may be used in Iran's construction sector, which according to the US is controlled by Islamic Revolutionary Guard Corps (IRGC).
"The IRGC's construction firm and many of its subsidiaries remain sanctioned by the United Nations because they were directly involved in the construction of the uranium enrichment site at Fordow," Pompeo said.
No official reaction was available from Iran on July 31 due to a local holiday. However an informed Iranian observer told S&P Global Platts that "the new sanctions are not taken very seriously because all of the metals were previously under the OFAC [Office of Foreign Assets Control] sanctions."
Supply and trade of steel, aluminum, graphite and coal with Iran have been restricted by US secondary sanctions from August 2019 but Iran's metals and minerals export trade has continued since then; in fact its steel exports have increased as they are competitive. Secondary sanctions mean that any third parties involved in that trade are subject to US sanctions.
The 22 products included on the new sanctions list, deemed to be used in connection with Iran's nuclear, military, or ballistic missile programs, are: aluminum 319, 1100, 225, 6061, 6063, 6082 and 7075; aluminium bronze alloy UNS C63600 (CDA alloy 636); aluminium oxide (Al2O3); steel 302, 4130; stainless steel 321 and 316; A877 steel and 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 and aluminum powder with purity above 98%, Pompeo stated.
Suppliers not identified
No information was given on who the current suppliers of these products to Iran are, and the Iranian observer consulted said he was unable to specify origins, as this is classified information within Iran.
Following the previous imposition of secondary metals trade sanctions, the US stepped up its sanctions on Iran in the steel area in January 2020, imposing sanctions on exports from most of Iran's steelmakers and international steel traders which have links to Iran.
Iranian sources said at the time that Iran's steel and metals trade had carried on largely as normal in spite of both of these sets of sanctions, as much of the metals trade with Iran is with Chinese, other Asian and Middle Eastern parties which have not considered the US sanctions to be applicable to their activities. Much international metals trade with Iran is channeled and paid for via traders in offshore locations including Dubai, with those involved reportedly often turning a blind eye to details on suppliers and end-customers, so long as the product is of acceptable quality and price.
