State Department Issues Sanctions Advisory on Exports to Iran's Metals Sector

The State Department issued a Dec. 16 sanctions advisory about exports of graphite electrodes and needle coke to Iran, saying those materials subject exporters to “significant sanctions risk.” Both materials are “essential” to Iran’s steel industry, the State Department said, which is sanctioned by the U.S. Sanctions extend to producers and exporters of the materials along with “port operators, shippers, shipping companies, and vessel operators and owners,” who may be subject to blocking sanctions, even if the intended end-user is not in Iran’s steel sector.

Businesses should “implement effective due diligence policies, procedures, and internal controls to ensure compliance,” the advisory said, regardless of whether Iran’s steel industry is involved in the transaction. Companies should be aware that “the particulars of a transfer or export” of the materials “such as the shipping line used or intended end-user could also cause such activities to be covered by other Iran sanctions-related authorities,” the State Department said.