Sanctions 12 Aug, 2019 Iran sanctions - wind-down period for sanctions against metals sector ends Tony Paulson Head of Asia & Corporate Director Members are asked to note that the 90-day wind-down period to allow any contracts entered into prior to 8 May 2019 to be concluded ended on 6 August 2019, and the sanctions are now fully in place, irrespective of the date of the contract.  Download PDF As noted in our News Item of 9 May 2019 , President Trump issued Executive Order 13871 on 8 May extended Iran secondary sanctions to encompass the iron, steel, aluminium and copper sectors of the Iranian economy, thereby prohibiting any “significant” transaction involving: The sale, supply, or transfer to Iran of significant goods or services used in connection with the iron, steel, aluminium, or copper sectors of Iran, and The purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminium, aluminium products, steel, steel products, copper, or copper products from Iran. There was however a 90-day wind-down period to allow any contracts entered into prior to 8 May 2019 to be concluded. Members are asked to note that this wind-period ended on 6 August 2019 and the sanctions are now fully in place irrespective of the date of the contract. Coinciding with the ending of the wind-down period OFAC have issued some further FAQs (available here ). These confirm that the scope of the sanctions includes iron ore and also set out the factors which OFAC will take into consideration when deciding whether any transaction is significant. Like previous such explanations however this does not provide any firm guidance on exactly what is significant or not and each case will continue to be judged on its own merits by taking a number of factors into account. The Club’s U.S. attorneys Freehill Hogan & Mahar have produced a helpful Client Guide which is available below . Client Alert - Sanctions Against Iran PDF (718.8 KB) Finally, Members are reminded that tra