Background

The Biden administration announced April 18 additional economic sanctions against Iran in the wake of its drone attack on Israel earlier this month and its continued military cooperation with Russia.

The Department of Commerceʼs Bureau of Industry and Security is imposing additional export controls to further restrict Iran’s access to low-level technologies such as basic commercial-grade microelectronics. BIS said this action will cut off a wider range of items from reaching Iran, including items manufactured outside the U.S. that are produced using U.S. technology. BIS already imposes comprehensive export restrictions on Iran, including controls targeting Iran’s involvement in supplying unmanned aerial vehicles in support of Russia’s war against Ukraine.

In addition, Treasury’s Office of Foreign Assets Control is imposing sanctions against (1) 16 individuals and two entities enabling Iran’s UAV production, (2) five companies in the United Arab Emirates, Hong Kong, Turkey, and Europe that provide component materials for steel production to an Iranian steel producer or purchase its finished steel products (because steel exports generate significant revenue for the Iranian government), and (3) three subsidiaries of an Iranian automaker that have continued to materially support entities designated pursuant to counterterrorism authorities.

Under the sanctions, all property and interests in property of the designated persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, all transactions by U.S. persons or within (or transiting) the U.S. that involve any property or interests in property of designated or otherwise blocked persons are generally prohibited.

In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.

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