<h1>25% Tariff on Trade with Iran and Extraterritorial Secondary Restrictions; Humanitarian Exemptions Unclear, Stakeholders Seek Clarification</h1> The proposed measure institutes a 25% tariff on trade with a designated state (Iran), creating extraterritorial secondary trade restrictions; its operative effect is to subject transactions by third-country traders to added unilateral duties unless exempted. The scope of covered transactions-specifically whether humanitarian categories (foodstuffs, pharmaceuticals) now transacted under explicit OFAC permissions-are excluded remains unspecified; the operative effect is continued legal uncertainty for exporters and banks regarding liability or commercial impact pending an implementing order or guidance. Market participants claim current transactions conform to OFAC authorisations, but seek formal clarification to determine compliance and commercial exposure.