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 2019 to be used in connection with the nuclear, military, or ballistic missile programs of Iran. 

The 22 specific metals now targeted by the State Department are as follows:

  • ALUMINIUM 1100
  • ALUMINIUM 6061
  • ALUMINIUM 6063
  • ALUMINIUM 6082
  • ALUMINIUM 7075
  • ALUMINIUM BROZE ALLOY UNS C63600 (CDA alloy 636)
  • STEEL 302
  • STEEL 4130
  • A877 STEEL
  • A228 STEEL
  • 100Cr6-52100 STEEL
  • 350 MARAGING STEEL (also known as MARAGING STEEL350)
  • 300 MARAGING STEEL (also known as MARAGING STEEL300)
  • UNS C37000 – CuZn38Pb1
  • ALUMINIUM POWDER with purity above 98 percent

Also under Section 1245 of the IFCA, the State Department announced that it is continuing the determination that the Islamic Revolutionary Guard Corps controls Iran’s construction sector, which means any knowing transfer of certain materials, including graphite or raw or semi-finished metals, to or from Iran to be used in connection with the construction sector of Iran remains sanctionable.

These expanded sanctions continue a trend of the US targeting Iran’s metal industry.  The State Department imposed sanctions on entities within Iran’s metal industry in June 2020, and on Iran’s construction section and metals industry in October 2019 (see our blog the October 2019 sanctions here).

The authors acknowledge the assistance of Ryan Orange.


Mr. Coward focuses on outbound trade compliance matters, including the extraterritorial application of US law, particularly US export control laws, anti-boycott regulations and trade sanctions/embargoes maintained by the US government against various countries. In addition, his practice covers issues of corporate conduct such as the application of the Foreign Corrupt Practices Act and foreign bribery laws. He provides international transactional advice; assistance in the design and implementation of corporate compliance programs, compliance audits, and internal investigations; and representation in enforcement proceedings.


Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws.