U.S. Skincare Company Settles OFAC Charges for Iranian Sanctions Violations

A U.S. skincare and dietary supplements company settled OFAC charges regarding apparent violations of the Iranian Transactions and Sanctions Regulations after the Company supplied products and services to Iran.

In a Settlement Agreement, OFAC stated that the Company conspired with two distributors (one in Iran and one in the United Arab Emirates) to re-export or supply its products to Iran. OFAC stated that the Company had applied multiple times for a specific license to export its products to Iran. The Company did not, however, receive such a license and the Company's senior management nonetheless went ahead with a plan to export products to Iran without a license. OFAC said that the total value of the Company’s transactions with the co-conspirators amount to $11,114,287. As a result of its actions, OFAC found that the Company violated Iranian Transactions and Sanctions Regulations.

To settle its potential civil liability, the Company agreed to (i) pay $3,334,286, (ii) waive any possible legal objection against the Settlement Agreement at a later date and (iii) undertake the compliance commitment outlined by OFAC.