Building Materials Company Penalized for Exporting Material to Iran

A building materials company settled potential civil liability for violations of the Iranian Transactions and Sanctions Regulations.

In an Enforcement Release, OFAC stated that the company provided "specific written instructions" to its subsidiary in the U.A.E. that U.S. persons were not allowed to engage in, facilitate, or support business in Iran. OFAC found that the subsidiary imported goods from the U.S. to the U.A.E. and then knowingly re-exported the goods to Iran. OFAC charged that the subsidiary’s management "engaged in a pattern of behavior," including by falsifying information on purchase orders and using false project names to conceal the destination of the goods.

OFAC said that a U.S. employee of the U.A.E. subsidiary became aware of the conduct and reported his suspicions to the company’s headquarters in the United States. OFAC said that the employee's report prompted the company to (i) initiate an internal investigation, (ii) terminate all Iran-related business activity and (iii) voluntarily disclose the matter to OFAC.

After determining that the apparent violations were egregious but voluntarily self-disclosed, OFAC agreed to a settlement amount of $660,594.