August 7, 2019
As discussed in our May 8, 2019, Client Alert, President Trump issued Executive Order (“E.O.”) 13871 on May 8, 2019, imposing broad new sanctions against Iran’s metals industries. With the issuance of E.O. 13871, U.S. sanctions targeted virtually the entire metals sector in Iran and those engaged in transactions in support of the sector. The E.O. however contained a 90-day wind-down period. That period ended yesterday on August 6, 2019. E.O. 13871 thus is in full effect. In conjunction with the expiration of the wind-down period yesterday, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued frequently asked questions (“FAQs”) which provide greater clarity on the potential scope of E.O. 13871.
To read the full Client Alert, click HERE.