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Hold the Presses: IFCA-related sanctions a-comin’

In June 2020, the State Department sanctioned the Islamic Republic of Iran Shipping Lines (IRISL) pursuant to Executive Order 13382 (WMD Proliferators and Their Supporters).  At that time, we underscored the fact that IRISL is the preferred shipping line for Iranian proliferators and procurement agents.  We have warned industry that those who do business with IRISL, its subsidiaries, and other Iranian shipping entities, risk sanctions.  Today, we are sanctioning seven entities and two individuals for such conduct.

As a part of this action, the State Department is imposing sanctions on IRISL pursuant to Section 1245(a)(1)(C)(i)(II) of the Iran Freedom and Counter-Proliferation Act (IFCA).  IRISL knowingly transferred, directly or indirectly, to Iran grain-oriented electrical steel to at least one Iranian person on the List of Specially Designated Nationals and Blocked Persons maintained by the Office of Foreign Assets Control of the Department of the Treasury (SDN List), namely Hoopad Darya Shipping Agency Company (and thus this grain-oriented electrical steel was transferred to Hoopad Darya Shipping Agency Company).  The State Department is also imposing sanctions on Mohammad Reza Modarres Khiabani, the Chief Executive Officer of IRISL, who has been determined to be a principal executive officer, or person performing similar functions and with similar authorities, of IRISL.

The State Department is also designating the PRC-based Jiangyin Mascot Special Steel Co., LTD pursuant to Section 1245(a)(1)(C)(i)(II) of IFCA.  Jiangyin Mascot Special Steel Co., LTD knowingly transferred grain-oriented electrical steel to Iran via the Islamic Republic of Iran Shipping Lines (IRISL) (and thus this grain-oriented electrical steel was transferred to IRISL); IRISL is an Iranian person on the SDN list.

The State Department is also designating Iran Transfo Company and Zangan Distribution Transformer Company pursuant to IFCA Section 1245(a)(1)(C)(i)(II).  Both of these entities knowingly transferred (imported), directly or indirectly, to Iran grain-oriented electrical steel to at least one Iranian person on the SDN List, namely Hoopad Darya Shipping Agency Company (and thus this grain-oriented electrical steel was transferred to Hoopad Darya Shipping Agency Company).

Separately, the State Department is also designating the UAE-based Accenture Building Materials, Iran’s Mobarakeh Steel Company, and the IRISL subsidiary Sapid Shipping pursuant to IFCA Section 1245(a)(1)(C)(i)(II).  Accenture Building Materials knowingly sold, supplied, or transferred, directly or indirectly, to or from Iran raw or semi-finished steel and the steel was sold, supplied, or transferred to or from an Iranian person (Sapid Shipping) included on the SDN List.  Accenture Building Materials also knowingly sold, supplied, or transferred, directly or indirectly, to or from Iran raw or semi-finished steel and the steel was sold, supplied, or transferred to or from an Iranian person (Mobarakeh Steel Company) included on the SDN List.

Mobarakeh Steel Company knowingly sold, supplied, or transferred, directly or indirectly, to or from Iran, raw or semi-finished steel and the steel was sold, supplied, or transferred to or from an Iranian person (Sapid Shipping and IRISL) included on the SDN List.  The State Department is also imposing sanctions on Hamidreza Azimian, the Chief Executive Officer of Mobarakeh Steel Company, who has been determined to be a principal executive officer, or person performing similar functions and with similar authorities, of Mobarakeh Steel Company.

Sapid Shipping knowingly sold, supplied, or transferred, directly or indirectly, to or from Iran raw or semi-finished steel and the steel was sold, supplied, or transferred to or from an Iranian person (Mobarakeh Steel Company) included on the SDN List.

IFCA-related sanctions involve 5 or more menu-based sanctions, so expect something from OFAC soon (nothing on the Recent Actions page as of 11:41 AM).

Link:

State Department Press Release

Categories: IFCA Iranian Sanctions State Department Updates

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