The Office of Foreign Assets Control of the US Department of the Treasury has designated, pursuant to Executive Order 13871, twelve Iranian steel and metals producers, three non-Iran based sales agents of a major Iranian mining holding company, and a supplier of graphite electrodes to the Iranian steel industry.
According to OFAC, in the first six months of 2020 the Chinese graphite supplier, Kaifeng Pingmei New Carbon Materials Technology Co., Ltd. sent thousands of metric tons of material to several Iranian steel companies, including the Pasargard Steel Complex, the Gilan Steel Complex, and several metals and mining holding companies, which together produce millions of tons of steel billets and other metal products annually.
In a parallel action, the US Department of State has also sanctioned Kaifeng Pingmei, the Islamic Republic of Iran Shipping Lines, and Majid Sajdeh pursuant to Section 1245(a)(1)(C)(II) of the Iran Freedom and Counter-Proliferation Act of 2012, for having knowingly supplied graphite to or from Iran and ultimately to or from a person on the list of Specially Designated Nationals.
As a result of these sanctions, US property owned by the sanctioned entities is blocked, and OFAC regulations generally prohibit US persons from transacting with such property. In addition, persons who engage in certain transactions with designated persons may themselves be exposed to sanctions, and foreign financial institutions that knowingly facilitate transactions on behalf of designated persons could be subject to US correspondent or payable through account sanctions.