The State Department determined that “the construction sector of Iran is controlled directly or indirectly by the IRGC”, adding that “as a result of this determination, the sale, supply or transfer to or from Iran of raw and semi-finished metals, graphite, coal, and software for integrating industrial purposes will be sanctionable if those materials are to be used in connection with the Iranian construction sector.” It also found “four strategic materials as ones that are being used in connection with the nuclear, military or ballistic missile programs of Iran”, as a consequence of which “the sale, supply or transfer to or from Iran of those materials will be sanctionable (regardless of end-use or end-user)”. Iranian Foreign Minister Javad Zarif responded by maintaining that “subjecting construction workers to economic terrorism only manifests maximum failure of ‘maximum pressure’. The U.S. can sanction every man, woman and child, but Iranians will never submit to bullying”. He went to call on Washington to “abandon failed policies and return to the JCPOA”.
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