A U.S. multinational holding company settled its potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations ("ITSR").
According to OFAC, the U.S. company's "indirectly wholly owned Turkish subsidiary" sold goods through third-party distributors for resale to Iranian end users, including the Government of Iran, in apparent violation of OFAC Rule 560.215 ("Prohibitions on Foreign Entities Owned or Controlled by U.S. Persons"). OFAC determined that the senior managers of the Turkish subsidiary had, among other things, (i) ignored the U.S. company's repeated communications concerning Iranian sanctions, (ii) concealed the subsidiary's activities to establish relationships with Iranian distributors and (iii) used two independent Turkish companies to obfuscate that Iran was the ultimate destination of the goods.
OFAC concluded that the U.S. company voluntarily self-disclosed the apparent violations, but that the conduct constituted an egregious case. To settle the charges, the company agreed to pay $4,144,651.
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