U.S. Findings on Iran Pursuant to the Iran Freedom and Counter-Proliferation Act (IFCA) of 2012

Pursuant to Section 1245 of the Iran Freedom and Counter-Proliferation Act (IFCA) of 2012, the Department of State has made two findings with sanctions implications:

• identifying 10 strategic materials as being used in connection with the nuclear, military, or ballistic missile programs of Iran
• identifying Iran’s construction sector as being controlled directly or indirectly by the Islamic Revolutionary Guard Corps (IRGC)

Specifically, the Department of State in consultation with the Department of the Treasury, has determined that the following certain types of additional materials are used in connection with the nuclear, military, or ballistic missile programs of Iran:

• Austenitic nickel-chromium alloy
• Magnesium ingots
• Sodium perchlorate
• EDM-11
• EDM-14A
• EDM-15
• Tungsten copper
• AA2024-T351 aluminum sheets and/or tubes
• ISO-68
• ISO-69

Any person that knowingly sells, supplies, or transfers, directly or indirectly, these materials to or from Iran (regardless of end-use or end-user) will now be subject to mandatory sanctions.

In addition, the Department of State, in consultation with the Department of the Treasury, has determined that the construction sector of Iran is controlled directly or indirectly by the IRGC.

Any person that knowingly sells, supplies, or transfers, directly or indirectly, to or from Iran, raw and semi-finished metals, graphite, coal, and software for integrating industrial purposes will be subject to mandatory sanctions if those materials are to be used in connection with the Iranian construction sector.

The United States will continue to impose maximize economic pressure on the Iranian regime to end Iran’s nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups.