On May 8, 2019, exactly one year after President Trump announced that the United States was withdrawing from the Joint Comprehensive Plan of Action ("JCPOA") and would re-impose the U.S. secondary sanctions against Iran, President Trump issued an Executive Order "Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran."  The Executive Order is not yet numbered but is characterized as "further steps" taken under Executive Order 12957 of March 15, 1995.

As explained in the Executive Order, the new sanctions are imposed to deny Iran all paths to both a nuclear weapon and intercontinental ballistic missiles, and to counter the totality of Iran's malign influence in the Middle East.  Specifically, the United States seeks to deny the Iranian government revenue from the export of iron, steel, aluminum, and copper. 

To read more, please refer to the Client Alert from Freehill Hogan & Mahar LLP attached above.