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.

A notice (please see here) updating the HM Treasury’s Consolidated List regarding three entities listed under Council Regulation (EU) 267/2012, which imposes financial sanctions against Iran, was published yesterday. This notice removes the asset freeze against the below three Iranian entities, following Judgments of the General Court of the European Union (please see here and here for the relevant judgments): IRISL Club IRISL Multimodal Transport Company Leading Maritime Pte Ltd These three entities were initially listed…