US Treasury Publishes List of Countries Requiring Boycott Cooperation

On February 10, 2020 the U.S. Department of the Treasury (“Treasury”) published the current list of countries requiring cooperation with an international boycott.(1) On the basis of the best information currently available to Treasury they listed the following countries as requiring or potentially requiring participation in, or cooperation(2) with an international boycott:

  • Iraq

  • Kuwait

  • Lebanon

  • Libya

  • Qatar

  • Saudi Arabia

  • Syria

  • United Arab Emirates

  • Yemen

References

  1. Department of the Treasury, Office of the Secretary Federal Register publication - 85 FR 7618

  2. Participation and cooperation are defined in section 999(b)(3) of the Internal Revenue Code of 1986. Source: FindLaw - 26 U.S.C. 999

US Imposes Additional Sanctions on Iran's Industry

On January 10, 2020 the U.S. President issued an Executive Order(1) establishing additional sanctions on Iran. The new sanctions target the construction, mining, manufacturing, and textile sectors of the Iranian economy.

We are also designating Iran’s largest metals manufacturers, and imposing sanctions on new sectors of the Iranian economy including construction, manufacturing, and mining”(2), said Secretary Steven T. Mnuchin.

The Executive Order blocks the property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any US person of the following:

  • The 13 largest steel and iron manufacturers and the top aluminum and copper companies in Iran including Mobarakeh Steel Company, Saba Steel, Hormozgan Steel Company, Esfahan Steel Company, Oxin Steel Company, Khorasan Steel Company, South Kaveh Steel Company, Iran Allow Steel Company, Golgohar Mining and Industrial Company, Chadormalu Mining and Industrial Company, Arfa Iron and Steel Company, Khouzestan Steel Company and Iranian Ghadir Iron & Steel Company, Iran Aluminum Company, Al-Mahdi Aluminum Corporation, Khalagh Tadbir Pars Co, and the National Iranian Copper Industries.

  • China entities Pamchel Trading Beijing Co Ltd, Hongyuan Marine Co Ltd and Seychelles-based (Power Anchor Limited a front company for Pamchel Trading Beijing Co, Ltd) entities; and a vessel (Hong Xun) involved with Iranian metals products.

  • Oman-based Reputable Trading Source LLC, which is owned or controlled by Khouzestan Steel Company.

  • Senior Iranian officials involved in recent ballistic missile strikes.

In addition, the Secretary of the Treasury is authorized to sanction foreign financial institutions that knowingly conduct or facilitate any significant financial transaction in contradiction to the Executive Order. See the Executive Order for additional restrictions and details.

Contact the professionals at GCSG for more information on this development.

References

  1. Executive Order on Imposing Sanctions with Respect to Additional Sectors of Iran - January 10, 2020

  2. US Department of the Treasury Press Release: “Treasury Targets Iran’s Billion Dollar Metals Industry and Senior Regime Officials” - January 10, 2020