On 16 December, an Advisory intended to alert persons globally to the sanctions risks for parties involved in transfers or exports to Iran of graphite electrodes and needle coke, which are essential materials for Iran’s steel industry.   It says that the US Government is taking strong action to deny Iran revenue derived from Iran’s steel sector, since such funds may be used to advance the Iranian regime’s malign behavior, including its proliferation programs, campaigns of regional aggression, and support for terrorist groups.  It says that transfers or exports to Iran of graphite electrodes or needle coke create significant sanctions risk for entities and individuals, including but not limited to producers and exporters of graphite electrodes and needle coke, port operators, shippers, shipping companies, and vessel operators and owners.   Sanctions risks may be present even if the intended end-user is not in Iran’s steel sector. It explains that graphite electrodes are mainly used in electric steelmaking, due to their high levels of electrical conductivity and ability to withstand high temperatures; and that needle coke is needle-shaped carbon material characterised by low electrical resistance and strong shock resistance, and is the main input used to create graphite electrodes.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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