This Week in Iran Policy, January 6-10 (Excerpts)

January 10, 2020



The Iranian regime exploits revenue from its metals industry to fund its destabilizing activities.  Accordingly, the Department of State is sanctioning Pamchel Trading (Beijing) Co., Ltd. pursuant to section 1245 the Iran Freedom and Counter-Proliferation Act (IFCA) for transferring 29,000 metric tons of steel from an Iranian firm that is a Specially Designated Global Terrorist.

We are also making a second announcement with regard to IFCA.  IFCA Section 1245, requires sanctions on persons (entities and individuals) who knowingly sell, supply, or transfer, directly or indirectly, to or from Iran, raw or semi-finished metals, when such metals are (1) to be used in connection with the energy, shipping, or shipbuilding sectors of Iran or any sector of the economy of Iran determined to be controlled directly or indirectly by Iran’s Revolutionary Guard Corps, such as the construction sector; (2) are sold, supplied or transferred to or from an Iranian person included on the SDN List; or (3) are determined to be used in connection with the nuclear, military, or ballistic missile programs of Iran.  Today, we are announcing that the Secretary of State has decided that “raw or semi-finished metals” under IFCA 1245 section (d) includes, but is not limited to, 74 metals (including all types of such materials and all alloys or compounds containing such materials).  This decision clarifies for foreign stakeholders that supplying, selling, or transferring raw or semi-finished forms of these 74 metals is sanctionable if certain other conditions are met.   We are making this announcement to send a clear signal to foreign counterparts about the importance of avoiding selling, suppling, or transferring metals to or from Iran, and thus the Department is clarifying that the IFCA 1245 provision “raw or semi-finished metals” includes but is not limited to 74 metals including all types of such materials and all alloys or compounds containing such materials.‎

The 74 metals are: Aluminum, Americium, Antimony, Barium, Beryllium, Bismuth, Boron, Cadmium, Calcium, Cerium, Cesium, Chromium, Cobalt, Copper, Dysprosium, Erbium, Europium, Gallium, Gadolinium, Germanium, Gold, Hafnium, Hastelloy, Inconel, Indium, Iridium, Iron, Lanthanum, Lithium, Lead, Lutetium, Manganese, Magnesium, Mercury, Molybdenum, Monel, Neodymium, Neptunium, Nickel, Niobium, Osmium, Palladium, Platinum, Plutonium, Polonium, Potassium, Praseodymium, Promethium, Radium, Rhenium, Rhodium, Ruthenium, Samarium, Scandium, Silicon, Silver, Sodium, Steels, Strontium, Tantalum, Technetium, Tellurium, Terbium, Thallium, Thorium, Tin, Titanium, Tungsten, Uranium, Vanadium, Ytterbium, Yttrium, Zinc, and Zirconium.