On 31 October 2019 the U.S. Secretary of State announced (“in consultation with the Secretary of the Treasury”) two further determinations pursuant to Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA). First, the construction sector of Iran was identified as being indirectly or directly controlled by the Islamic Revolutionary Guard Corps (IRGC). As a result, “the sale, supply, or transfer to or from Iran of raw and semi-finished metals, graphite, coal, and software for integrating industrial purposes” are sanctionable offenses if those materials are used within the Iranian construction sector. Second, four materials have been identified as being used in connection with Iranian missile programs. As a result, selling, supplying or transferring these materials to or from Iran is a sanctionable offense. For further details please read the press release from the U.S. Department of State.