In November 2019, Mike Pompeo "made two determinations with sanctions implications pursuant to Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA): One identifying the construction sector of Iran as being controlled directly or indirectly by the Islamic Revolutionary Guard Corps (IRGC); and one identifying four strategic materials as being used in connection with Iran’s nuclear, military, or ballistic missile programs." The Trump administration "determined that the following materials are used in connection to Iran's nuclear, military or ballistic missile programs: stainless steel304L tubes; MN40manganesebrazing foil; MN70 manganese brazing foil; and stainless steel CrNi60WTiESR + VAR (chromium, nickel, 60 percent tungsten, titanium, electro-slag remelting, vacuum arc remelting)."[3]