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Iran Freedom and Counter-Proliferation Act of 2012 (“IFCA”)

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On July 30, 2020, the US Department of State (“State Department”) expanded secondary sanctions targeting Iran’s nuclear, military, and ballistic missile programs under the Section 1245 of the Iranian Freedom and Counter-Proliferation Act of 2012 (“IFCA”) by including 22 specific metals used in connections with such programs in Iran.  Sanctions may be imposed on persons who knowingly transfer these 22 materials, in addition to the 4 materials already determined by the State Department in October…

On October 31, 2019, the US State Department strengthened US secondary sanctions targeting Iran under the Iran Freedom and Counter-Proliferation Act of 2012 (“IFCA”) (codified at 22 U.S.C. § 8801 et seq.), which dates back to 2013.  These new IFCA sanctions target the construction sector in Iran and make sanctionable the export to Iran of certain strategic metals.

On August 6, 2018, President Trump issued Executive Order 13846, “Reimposing Certain Sanctions with Respect to Iran” (the “New Iran EO”), which formally reimposes certain sanctions on Iran that had been suspended or revoked as part of the United States’ commitments under the Joint Comprehensive Plan of Action (“JCPOA”). The New Iran EO, which was issued to coincide with the end of the 90-day wind-down period announced on May 8, 2018 and detailed in our previous blog post, reimposes a wide range of sanctions on Iran that were in effect prior to the implementation of the JCPOA pursuant to pre-existing legal authorities, and also expands the scope of those sanctions, as described below.