The Trump Administration on January 10, 2020, issued broad new secondary sanctions with respect to Iran’s construction, mining, manufacturing, and textiles sectors in an effort to target additional sources of revenue used by the Iranian regime, as well as with respect to additional members of the Iranian leadership. The expansion of secondary sanctions authority to cover new sectors of the Iranian economy means that non-U.S. companies and financial institutions previously doing business in these sectors now face additional sanctions risk.
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