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Sanctions — metals-relevant entries

Five official sanctions authorities publish their consolidated lists in machine-readable form. This page mirrors the entries on those lists whose name, designation programme or remarks reference metals-industry activity — refining, smelting, mining, trade in specific metals, metallurgical complexes. TrueSource Metals Hub does not designate, judge or rank — it only consolidates the first-party listings so the metals industry can find them in one place, with a deep link back to every issuing authority.

Primary sources only 5 official lists — loading metals-relevant entries Snapshot:

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Methodology

An entry from a primary list is included here when its name, designation programme or remarks match a metals-industry vocabulary. The match is case-insensitive with word boundaries, and uses two layers:

Word boundaries prevent leadleader, ironenvironment, tinPutin, minerminister. Some industrial vocabulary (notably "refinery") overlaps with oil-and-gas designations; those entries are kept in the snapshot for transparency and labelled by the originating programme so the metals user can see and skip them.

Why not just link to the official lists?

You should — and every entry below does. The official lists are the source of truth. This page only adds two things on top: (1) a metals-industry vocabulary filter so a copper-cathode trader does not have to scroll through 19,000 designations to find the 247 that touch metals, and (2) a five-authority consolidation so the user can compare an entity's status across OFAC, EU, UK and UN in one query. The official source link is always one click away.

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Last updated: 2026-07-09

Russia Metals Sanctions Since February 2022 — From Steel to Gold to the LME Itself

Russia's invasion of Ukraine triggered the most sweeping metals-sector sanctions regime in modern history, moving in successive waves from iron and steel (March 2022), to gold (June 2022), to a direct prohibition on aluminium, copper, and nickel — forcing the London Metal Exchange itself to bar new Russian-origin production from its warrant system in April 2024.

1. The gold ban: OFAC's June 2022 Determination and its narrow scope

On 28 June 2022, in coordination with the G7, the US Treasury's Office of Foreign Assets Control (OFAC) issued a Determination pursuant to Section 1(a)(i)(A) of Executive Order 14068, prohibiting the importation into the United States of gold of Russian Federation origin, effective immediately and re-issued in amended form on 22 December 2023 (OFAC, Determination Pursuant to Section 1(a)(i)(A) of Executive Order 14068 — Prohibitions Related to Imports of Gold of Russian Federation Origin). Crucially, the Determination is not retroactive: it explicitly excludes gold of Russian origin that was located outside of Russia prior to 28 June 2022, meaning bullion already sitting in London, Zurich, or other Western vaults before that date remained legally tradeable (OFAC, Russian Harmful Foreign Activities Sanctions program page). The UK moved in parallel: new regulation 46Z11 of the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 prohibits importing gold that “originated from Russia” and was exported on or after the relevant day, with companion provisions 46Z12–46Z15 separately banning acquisition, supply/delivery, technical assistance, and financial services relating to Russian gold (UK Legislation, The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022). The EU's equivalent prohibition entered into force on 22 July 2022 under Article 3o of Council Regulation (EU) No. 833/2014, banning the direct or indirect import, purchase, or transfer of gold listed in Annexes XXVI and XXVII, alongside related technical and financial assistance and brokering services (European Commission, Consolidated FAQs on Sanctions — Import, Purchase and Transfer of Listed Goods). The UK's National Crime Agency separately issued a Red Alert to financial institutions warning that Russia was using gold specifically as a mechanism to undermine the broader sanctions regime, underscoring why gold received distinct, dedicated restrictions rather than being folded into general trade measures (Ashurst, Russia Sanctions Tracker — UK (2022–23)).

2. Iron, steel, and the base-metals escalation of 2023–2024

Metals sanctions began earlier and more broadly than gold. The EU's fourth sanctions package, adopted 15 March 2022, first banned the import of Russian iron and steel products under Annex XVII of Regulation 833/2014, with the ban progressively widened by the eighth package (October 2022, adding steel semi-finished products and third-country goods incorporating Russian steel inputs) and the ninth package (16 December 2022, extending a new-investment ban to Russia's mining and quarrying sector) (White & Case, EU's 9th Sanctions Package Extends Investment Ban to Mining and Quarrying Sector). On 18 December 2023, the Council imposed a further import ban covering Russian diamonds and raw materials for steel production, processed aluminium products, and other metal goods (EU Sanctions Map, Russia Regime Summary). The UK moved on a parallel but not identical track: the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023 introduced a new Chapter 4CB (regulations 46IF–46II, Schedule 3BA) from 15 December 2023 restricting aluminium, cobalt, copper, lead, magnesium, nickel, tin, and zinc, with a grace period for metal consigned from Russia before that date and imported before 14 January 2024 (Ropes & Gray, The UK's Seventh Package of Sanctions Against Russia). The decisive escalation came on 12–13 April 2024, when OFAC and HM Treasury jointly prohibited the London Metal Exchange and Chicago Mercantile Exchange from accepting new Russian-origin aluminium, copper, and nickel produced on or after that date, issued under OFAC's Metals Import Determination (Executive Order 14068) and Metals Services Determination (Executive Order 14071) (Cassidy Levy Kent, U.S. Imposes Restrictions on Importation, Trading of Russian Metals). Metal produced before 13 April 2024 remained excluded from the prohibition and continued to be deliverable, creating a hard bright-line date that reshaped LME brand eligibility overnight (Reuters, LME Bans Russian-Origin Metal After UK, US Impose New Sanctions).

3. The LME's own Rulebook response: April 2022 suspension and April 2024 delivery ban

The London Metal Exchange initially resisted acting ahead of government sanctions: in March 2022, the LME publicly stated it “does not currently intend to take independent measures outside the framework of existing sanctions” by restricting Russian-produced metal circulating within its system (Reuters, LME Says It Has No Current Plans to Ban Russian Metal From Its System). That posture shifted as UK legislation caught up: the LME's Notice 22/097 in April 2022 detailed new UK Customs (Additional Duty) (Russia and Belarus) Regulations 2022 imposing a 35% additional duty on Russian- and Belarussian-origin copper, aluminium, and lead released into free circulation in the UK from 25 March 2022, directly affecting warranting of Russian brands in LME-approved UK warehouses (LME, Notice 22/097 — Warranting of Russian Lead, Aluminium and Copper Brands in UK Warehouses). The Exchange subsequently published a discussion paper in October 2022 on how to handle Russian metal within its warrant system as market pressure mounted from consumer and industrial members uneasy about continuing to accept Russian-brand metal even where not yet legally required to reject it (LME, Notice 22/240 — Discussion Paper on Russian Metal). The binding rulebook change came only once government sanctions forced it: LME Rulebook amendments effective 13 April 2024 barred any newly produced Russian-origin aluminium, copper, or nickel from entering LME warehouses or being warranted, aligning the Exchange's own brand-approval rules directly with the OFAC/HMT determinations rather than pre-empting them (S&P Global Commodity Insights, LME, CME Block Trade of Russian Aluminum, Copper, Nickel). A partial reversal followed in September 2024, when the LME lifted its suspension specifically on nickel cathodes and briquettes produced before the cutoff, reflecting the LME's practice of distinguishing pre- and post-sanction production dates rather than imposing blanket brand delisting (Interfax, London Metal Exchange Lifts Suspension on Nickel Cathodes).

Current status (July 2026): Russian-origin gold, iron/steel, and base metals (aluminium, copper, nickel) produced after their respective 2022–2024 cutoff dates remain excluded from US, UK, and EU markets and from LME/CME warrant eligibility, while pre-cutoff material continues to trade under grandfathering exceptions. Watch: further EU sanctions packages tightening third-country transformation loopholes, and whether the LME extends similar brand-eligibility relief to other pre-cutoff Russian metals beyond nickel.
Last updated: 2026-07-09

G7 Coordination and the Mechanics of EU, UK, and UN Metals-Sector Listings

No single sanctions list governs metals — OFAC's SDN List, the EU's consolidated financial sanctions regime, the UK's newly unified Sanctions List, and UN Security Council Committee designations each operate on separate legal triggers, and as of January 2026 the UK retired its long-standing OFSI Consolidated List in favor of a single unified list.

1. The G7 gold import ban: four countries, one coordinated announcement

On 26 June 2022, at the G7 summit in Elmau, Germany, the United States, United Kingdom, Japan, and Canada jointly announced a ban on new imports of Russian gold, with the UK government framing the measure as targeting “oligarchs rushing to buy gold bullion in an attempt to avoid the financial impact of western sanctions” (UK Government, UK Sanctions Russian Gold Exports). The rationale was explicitly revenue-denial: gold was described as Russia's second-largest export after energy, and the G7 statement asserted a determination to limit Russia's revenues from the gold trade specifically (Wiley Rein, Biden Administration Adds Economic Measures Against Russia During G7 Meeting). The formal US action followed two days later via the OFAC Determination discussed above, issued alongside nearly 100 new SDN List additions and five new Russia-related General Licenses, including General License 43 authorizing wind-down of pre-existing debt and equity positions in Severstal and Nord Gold PLC through 31 August 2022 (Baker McKenzie, US Government Sanctions More Than 100 Russia-Related Parties and Prohibits the Import of Russian Gold). Market reaction was muted: contemporaneous coverage described the ban as “largely symbolic” given Russian gold's limited direct exposure to formal Western bullion-market channels even before the ban (Bloomberg, Gold Steady as G-7 Russia Import Ban Viewed ‘Largely Symbolic’).

2. The UK's list consolidation: OFSI's closure and the unified UK Sanctions List

For most of the post-2022 period, UK financial sanctions on metals-linked individuals and entities were enforced through the Office of Financial Sanctions Implementation's (OFSI) Consolidated List, which combined UN- and UK-designated asset-freeze targets in one searchable database (GOV.UK, Financial Sanctions Targets: List of All Asset Freeze Targets). That changed on 28 January 2026, when the OFSI Consolidated List formally closed, with the UK Sanctions List becoming the sole authoritative source for all UK sanctions designations going forward, spanning financial, trade, and other measures in a single register (GOV.UK, The UK Sanctions List). UK financial-sanctions guidance for Russia was formally updated to reflect this closure, and the legacy OFSI list remains accessible only for historical reference rather than live compliance screening (GOV.UK, Financial Sanctions Guidance for Russia). Metals-linked designees captured under the unified list include individuals holding leadership positions in Russian and Belarusian mining, construction, and energy companies, sanctioned by OFSI on 29 June 2022 alongside eight individuals and five entities targeting the mining sector specifically (Covington & Burling, UK Introduces Further Sanctions Measures Relating to Russia).

3. UN Security Council Resolution 2321: DPRK's metals export ban

The primary multilateral (UN) metals-sanctions instrument targeting a producer state is UN Security Council Resolution 2321, adopted 30 November 2016 under the Council's DPRK sanctions regime (Committee established pursuant to Resolution 1718), which prohibits North Korea from supplying, selling, or transferring, directly or indirectly, coal, iron, and iron ore, with narrow livelihood and Rajin-port transshipment exceptions, and separately bans DPRK exports of gold, titanium ore, vanadium ore, and rare earth minerals outright, without exception (UN Press, Security Council Imposes Fresh Sanctions on Democratic People's Republic of Korea, Unanimously Adopting Resolution 2321). Resolution 2321 also introduced a first-ever binding annual cap on DPRK coal exports, set at approximately $401 million or 7.5 million metric tons per year, whichever proved lower, and separately prohibited DPRK exports of copper, nickel, silver, and zinc (Permanent Mission of Italy to the UN, Security Council Open Briefing of the 1718 Committee). These metals-specific export bans sit within the broader 1718 Committee sanctions architecture, which by 2017 already restricted DPRK coal and iron-ore procurement under Resolution 2270 and layered further material bans (lead, lead ore, seafood) under Resolution 2371 in 2017 (Arms Control Association, UN Security Council Resolutions on North Korea). Unlike the EU/UK/US Russia sanctions, which target a G20 producer with deep integration into Western commodity exchanges, the DPRK metals regime targets a state largely already isolated from LME/COMEX channels — making enforcement primarily a question of intermediary and shipping-sector due diligence rather than exchange-rulebook changes.

Current status (July 2026): The UK's sanctions-list architecture consolidated into a single UK Sanctions List as of 28 January 2026, replacing the OFSI Consolidated List; G7 gold and metals restrictions on Russia remain in force with pre-cutoff grandfathering; and the UN's DPRK metals export bans (Resolution 2321) remain the primary multilateral instrument, enforced mainly through shipping and trade-finance due diligence rather than exchange rules. Watch: further UK list consolidation guidance, and whether UN Security Council Panel of Experts reporting on DPRK sanctions evasion (last active before Panel mandate lapsed) resumes under a successor mechanism.
Last updated: 2026-07-09

Iran's Sectoral Metals Sanctions and Venezuela's Gold-Sector Designations

Iran and Venezuela illustrate two different sanctions architectures: Iran's metals sanctions operate through a dedicated sector-wide Executive Order targeting an entire industry, while Venezuela's gold sanctions rely on entity-specific SDN designations of its state gold company — a distinction that shapes how each regime has evolved and, in Venezuela's case, partially unwound.

1. Iran: Executive Order 13871 and the iron, steel, aluminum, copper sectors

Executive Order 13871, signed 8 May 2019, authorizes blocking sanctions on any person determined to operate in Iran's iron, steel, aluminum, or copper sectors, to own or control an entity operating in those sectors, or to knowingly engage in a significant transaction for the sale, supply, transfer, purchase, transport, or marketing of those metals and their products to or from Iran (OFAC, FAQ 666 — What Does E.O. 13871 Do?). The order builds on and expands existing metals-related restrictions under Section 1245 of the Iran Freedom and Counter-Proliferation Act (IFCA), which had already restricted trade in raw and semi-finished metals including aluminum and steel, with E.O. 13871 explicitly adding the iron and copper sectors that IFCA had not separately named (OFAC, FAQ 669 — Does E.O. 13871 Expand Upon Existing Sanctions?). Section 2 of the order extends correspondent and payable-through account sanctions to foreign financial institutions that knowingly facilitate significant transactions for Iranian metals trade, giving the sanctions extraterritorial reach over non-US banks that process related payments (Executive Order 13871, Imposing Sanctions With Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran). OFAC has used the order repeatedly: in June 2020 Treasury designated a network of Iranian metals companies and foreign intermediaries, and by April 2024 the order was still being cited — alongside counter-proliferation authority E.O. 13382 — to sanction entities tied to Iran's steel industry and its UAV/ballistic-missile supply chains simultaneously, reflecting how metals sanctions and weapons-proliferation sanctions increasingly overlap in enforcement practice (US Department of the Treasury, Treasury Targets Major Iranian Metals Companies and Foreign Intermediaries; US Department of the Treasury, Treasury Targets Iranian UAV Program, Steel Industry).

2. Venezuela: Minerven's 2019 SDN designation and its 2024–2026 partial reversal

On 19 March 2019, OFAC designated CVG Compania General de Mineria de Venezuela CA (Minerven), Venezuela's state gold-mining and refining company, and its president Adrian Antonio Perdomo Mata, as Specially Designated Nationals under Executive Order 13850 for “operating in the gold sector of the Venezuelan economy,” explicitly targeting gold's role in propping up the Maduro government (US Department of the Treasury, Treasury Sanctions Venezuela's State Gold Mining Company and Its President). OFAC's FAQ 629 clarified that the order's discretion was aimed at those operating corruptly in the gold sector — deceptive, fraudulent, or resource-misappropriating conduct — rather than legitimate gold-sector activity generally (OFAC, FAQ 629). A significant policy reversal began in October 2023 with the suspension of certain Venezuela sanctions, but that opening narrowed again: on 29 January 2024, OFAC revoked General License 43 and issued GL 43A, requiring US persons to wind down all transactions with Minerven by 13 February 2024, reinstating the presumption that Minerven-linked gold trade risked sanctions exposure (Troutman Pepper Locke, OFAC Revokes Venezuela Gold Mining General License). The picture shifted again in 2026: on 27 March 2026, OFAC significantly expanded authorizations for Venezuela's minerals sector, issuing amended General License 51A (broadening authorized trading from gold specifically to Venezuelan-origin minerals generally, while continuing to bar processing or refining in Russia, Iran, North Korea, Cuba, or China) plus new General Licenses 54 and 55 authorizing the provision of goods, technology, and services for mineral exploration and production, and the negotiation of contingent investment contracts, respectively (Baker McKenzie, OFAC Continues Relaxation of Sanctions on Venezuela's Mineral Sector). As of that update, Minerven itself remains listed on OFAC's SDN List, meaning the general licenses provide conditional, reportable carve-outs around a still-designated entity rather than delisting it outright (OFAC Sanctions List Search, Minerven (Entity Record)).

3. Comparing enforcement models: sector-wide order vs. entity-specific designation

The structural contrast between the two regimes has practical compliance consequences. Iran's E.O. 13871 sanctions an entire sector, meaning any company operating in Iranian iron, steel, aluminum, or copper risks designation regardless of individual conduct, and foreign banks face correspondent-account risk for facilitating sector-wide trade (OFAC, FAQ 666). Venezuela's E.O. 13850 instead authorizes case-by-case designation of specific persons determined to operate corruptly in the gold or other named sectors, giving OFAC discretion to license legitimate activity (as it did extensively via GL 51A, 54, and 55 in 2026) while keeping the underlying designation authority available for renewed use (OFAC, FAQ 629). This distinction explains why Venezuela's gold-sector sanctions have oscillated between relaxation and reinstatement multiple times since 2019 — tracking negotiations over electoral conditions — while Iran's sector-wide metals sanctions have remained structurally stable since 2019, with OFAC simply adding new designated entities and intermediaries under the same standing order rather than renegotiating the sanction's scope.

Current status (July 2026): Iran's E.O. 13871 metals-sector sanctions remain in continuous force with periodic new designations targeting steel-industry entities and their proliferation-linked customers; Venezuela's Minerven remains a designated SDN even as OFAC's March 2026 general licenses substantially widened authorized minerals trading around it. Watch: whether Venezuela's 2026 minerals-sector licensing expansion continues or reverses again depending on the state of Maduro-opposition negotiations, and further OFAC designations under E.O. 13871 tied to Iran's UAV and missile supply chains.
Last verified 2026-07-27 · 39/41 sources reachable