Indian Multinational Settles OFAC Charges for Iran Sanctions Violations

An Indian multinational company agreed to pay $275 million to settle 32 apparent violations of U.S. sanctions on Iran.

In its enforcement release, OFAC said the company bought 35 LPG ("liquified petroleum gas") cargos from a Dubai supplier during the sanctions period. OFAC said 32 of the cargos, totaling $192,104,044, was paid through U.S. financial institutions. OFAC found apparent violations of the Iranian Transactions and Sanctions Regulations ("ITSR,") and called the case egregious.

OFAC found that the supplier represented the LPG as originating in Oman and Iraq, but the cargos were Iranian-origin. OFAC said the company should have investigated multiple red flags: third-party allegations on at least four occasions that the cargos came from Iran; shadow-fleet vessel behavior, including Automatic Identification System manipulation, uneconomic port calls, and frequent name and flag-state changes; document irregularities, including nonsequential certificates of origin and outdated templates; significantly below-market pricing; and a February 2024 incident in which the supplier's bank halted payment and the supplier redirected the company to a new bank.

OFAC concluded that the conduct resulted in 32 apparent violations of Section 560.203(a) of the ITSR ("Prohibitions") by causing U.S. financial institutions to facilitate trade-related transactions in goods of Iranian origin.

OFAC said the statutory maximum penalty was $384,208,088 under OFAC's Economic Sanctions Enforcement Guidelines. OFAC found aggravating factors: the company acted recklessly given the red flags, helped Iran's sanctioned energy sector, and is a large and sophisticated international company. Mitigating factors brought the settlement to $275 million: no OFAC penalties in the preceding five years; the LPG business representing less than 1.5 percent of the company's 2025 consolidated revenue; substantial cooperation, including an expedited internal investigation by U.S. counsel; and remedial measures, including ceasing LPG imports into India, adopting a risk-based sanctions compliance policy under a dedicated Group Head of Compliance, and deploying maritime-intelligence technology.

OFAC warned non-U.S. companies using the U.S. financial system for energy transactions in high-evasion-risk regions, saying importers should not rely solely on counterparty documentation to confirm cargo origin, should monitor for Iranian shadow-fleet typologies, and should treat significantly below-market pricing as a diligence trigger. OFAC also said the case showed substantial mitigation remains available where a non-self-disclosing company nonetheless cooperates rapidly with an OFAC investigation.