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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On June 25, 2020, the U.S. Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) <a href="https://home.treasury.gov/news/press-releases/sm1044" target="_blank" rel="noopener noreferrer">announced</a> that its <a href="https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200625.aspx" target="_blank" rel="noopener noreferrer">recent designations</a> to the Specially Designated Nationals and Blocked Entities (SDN) List targeted Iran&rsquo;s steel, aluminum, copper, and iron sectors. OFAC designated eight entities operating in the Iranian metals sector including companies from Iran, the United Arab Emirates (UAE), Hong Kong, and Germany. OFAC designated these entities pursuant to President Trump&rsquo;s May 2019 <a href="https://www.treasury.gov/resource-center/sanctions/Programs/Documents/13871.pdf" target="_blank" rel="noopener noreferrer">Executive Order (E.O.) 13871</a>, which authorizes OFAC to impose sanctions with respect to the metals sectors of Iran.
Five of the designated companies are linked to Esfahan&rsquo;s Mobarakeh Steel Company (&ldquo;Mobarakeh&rdquo;), Iran&rsquo;s largest steel manufacturer. Mobarakeh was <a href="https://home.treasury.gov/news/press-releases/sm524" target="_blank" rel="noopener noreferrer">designated</a> in 2018 due to its link to the Islamic Revolutionary Guard Corps (IRGC), and was <a href="https://home.treasury.gov/news/press-releases/sm813" target="_blank" rel="noopener noreferrer">sanctioned</a> by the seven member nations of the Terrorist Financing Targeting Center in October 2019 for being part of Iran&rsquo;s terror support network. OFAC designated one Germany-based and three UAE-based sales agents for being owned or controlled by Mobarakeh. The other three entities designated to the SDN List are Iran metals producers. All property and interest in property of these SDNs and any entities in which they own a 50% or greater interest are blocked and may not be dealt with by U.S. persons. Foreign persons dealing with these entities may also expose themselves to U.S. sanctions.
Treasury Secretary Steven T. Mnuchin stated the following with respect to this recent action: &ldquo;The Iranian regime continues to use profits from metals manufacturers and foreign sales agents to fund destabilizing behavior. The United States remains committed to isolating key sectors of the Iranian economy until the revenues from such sectors are refocused toward the welfare of the Iranian people.&rdquo;

OFAC Sanctions Target Iran’s Metals Sectors