IFCA Section 1245(e) Periodic Report to Congress - Iran Sanctions Determinations
Summary
The State Department submitted its required 180-day IFCA Section 1245(e) report to Congress, making three determinations regarding Iran sanctions compliance: (1) Iran is not using graphite, metals, coal, or industrial software as barter or balance sheet assets; (2) the construction and defense sectors of Iran's economy are controlled by the IRGC; and (3) no additional materials are used in Iran's nuclear, military, or ballistic missile programs. The report covers the period July 1 to December 31, 2025.
What to do next
- Monitor IRGC sanctions compliance when trading graphite, aluminum, steel, coal, and industrial software with Iran-related parties
- Ensure screening procedures flag IRGC ownership or control in construction and defense sector transactions
- Track any future determinations expanding IRGC-controlled sectors
Archived snapshot
Apr 8, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Content
ACTION:
Notice of report.
SUMMARY:
Section 1245(e) of subtitle D of title XII of the National Defense Authorization Act for Fiscal Year 2013 (also known as the
Iran Freedom and Counter-Proliferation Act of 2012 (IFCA)), as delegated by Presidential Memorandum of June 3, 2013, requires
the Secretary of State, in consultation with the Secretary of the Treasury, every 180 days, to submit to the appropriate congressional
committees and publish in the
Federal Register
a report that contains a determination with respect to: (1) Whether Iran is (A) using any of the materials described in IFCA
as a medium for barter, swap, or any other exchange or transaction, or (B) listing any of such materials as assets of the
Government of Iran for purposes of the national balance sheet of Iran; (2) which sectors of the economy of Iran are controlled
directly or indirectly by Iran's Islamic Revolutionary Guard Corps (IRGC); and (3) which of the materials described in subsection
(d) of section 1245 are used in connection with the nuclear, military, or ballistic missile programs of Iran. Materials described
are graphite, raw or semi-finished metals such as aluminum and steel, coal, and software for integrating industrial processes.
DATES:
The Deputy Secretary of State approved this action on March 25, 2026.
FOR FURTHER INFORMATION CONTACT:
Office of Counterproliferation Initiatives, Department of State, Telephone: (202) 647-5193 or ACN_Sanctions@state.gov.
SUPPLEMENTARY INFORMATION:
For the purpose of implementing the provisions of IFCA delegated to the Secretary of State, including Sections 1245(a)(1)(B),
1245(a)(1)(C), and 1245(e), “raw or semi-finished metals” under IFCA 1245(d) includes, but is not limited to, the following
materials (including all types of such materials and all alloys or compounds containing such materials): Aluminum, Americium,
Antimony, Barium, Beryllium, Bismuth, Boron, Cadmium, Calcium, Cerium, Cesium, Chromium, Cobalt, Copper, Dysprosium, Erbium,
Europium, Gallium, Gadolinium, Germanium, Gold, Hafnium, Hastelloy, Inconel, Indium, Iridium, Iron, Lanthanum, Lithium, Lead,
Lutetium, Manganese, Magnesium, Mercury, Molybdenum, Monel, Neodymium, Neptunium, Nickel, Niobium, Osmium, Palladium, Platinum,
Plutonium, Polonium, Potassium, Praseodymium, Promethium, Radium, Rhenium, Rhodium, Ruthenium, Samarium, Scandium, Silicon,
Silver, Sodium, Steels, Strontium, Tantalum, Technetium, Tellurium, Terbium, Thallium, Thorium, Tin, Titanium, Tungsten, Uranium,
Vanadium, Ytterbium, Yttrium, Zinc, and Zirconium.
This report pursuant to Section 1245(e) of IFCA covers the period July 1, 2025, to December 31, 2025.
Following a review of the available information, and in consultation with the Secretary of the Treasury, the Deputy Secretary
of State has determined that Iran is not using the materials described in Section 1245(d) as a medium for barter, swap, or
any other exchange or transaction. Following a review of the available information, and in consultation with the Secretary
of the Treasury, the Deputy Secretary of State has determined that Iran is not listing any such materials as assets of the
Government of Iran for purposes of the national balance sheet of Iran. Following a review of the available information, and
in consultation with the Secretary of the Treasury, the Deputy Secretary of State has determined that, in addition to the
construction sector, the defense sector of the Iranian economy is controlled directly or indirectly by the IRGC.
Following a review of the available information, and in consultation with the Secretary of the Treasury, the Deputy Secretary
of State has determined that no additional types of materials described in Section 1245(d) are used in connection with the
nuclear, military, or ballistic missile programs of Iran.
Gonzalo O. Suarez, Deputy Assistant Secretary, Bureau of Arms Control and Nonproliferation, Department of State. [FR Doc. 2026-06688 Filed 4-6-26; 8:45 am] BILLING CODE 4710-27-P
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