Iran Sanctions: Construction Sector, Strategic Materials

The Deputy Secretary of State has issued two new determinations under Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA), expanding U.S. sanctions authority to further restrict Iran’s access to materials supporting its nuclear and military programs.

First, the Department of State, in consultation with the Treasury Department, formally identified Iran’s construction sector as being controlled directly or indirectly by the Islamic Revolutionary Guard Corps (IRGC). As a result, any person knowingly engaging in the sale, supply, or transfer of raw or semi-finished metals, graphite, coal, or industrial software to or from Iran’s construction sector is now subject to mandatory sanctions.

Second, the Department designated ten additional strategic materials as being used in Iran’s nuclear, military, or ballistic missile programs. These include:

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

Entities or individuals knowingly transferring any of these materials to or from Iran—regardless of end-use or end-user—now face mandatory sanctions.

These actions reinforce the Administration’s policy of maximum pressure on Tehran to disrupt its proliferation activities and IRGC-linked operations.

https://www.state.gov/releases/office-of-the-spokesperson/2025/05/u-s-findings-on-iran-pursuant-to-the-iran-freedom-and-counter-proliferation-act-ifca-of-2012/