On May 10, 2018, the Department of State published in the Federal Register a notice [Public Notice: 10407] that a determination has been made that a number of foreign persons have engaged in activities that warrant the imposition of measures pursuant to Section 3 of the Iran, North Korea, and Syria Nonproliferation Act (the “Act”; Pub. L. 109–353). The Act provides for penalties on foreign entities and individuals for the transfer to or acquisition from Iran since January 1, 1999; the transfer to or acquisition from Syria since January 1, 2005; or the transfer to or acquisition from North Korea since January 1, 2006, of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the potential to make a material contribution to the development of weapons of mass destruction (WMD) or cruise or ballistic missile systems. The latter category includes items of the same kind as those on multilateral lists but falling below the control list parameters when it is determined that such items have the potential of making a material contribution to WMD or cruise or ballistic missile systems, items on U.S. national control lists for WMD/ missile reasons that are not on multilateral lists, and other items with the potential of making such a material contribution when added through case-by- case decisions.

On April 30, 2018 the US Government applied the measures authorized in Section 3 of the Act against the 28 foreign persons listed in the Federal Register notice who were identified in the report submitted pursuant to Section 2(a) of the Act.