An electronics testing manufacturer settled an OFAC enforcement matter for violations of the Iranian Transactions and Sanctions Regulations.
According to OFAC, following the firm's acquisition of a subsidiary, the parent company issued a directive to the subsidiary to cease its sales to Iran. OFAC alleged that communications among the subsidiary's personnel indicated that the Vice President and Regional Director were immediately reluctant to comply with the manufacturer's directive, citing their need to preserve their "credibility in local markets." In the year following the parent's directive, the subsidiary completed several orders without OFAC authorization that were destined for end-users in Iran.
OFAC noted that General License H was in effect at the time of these transactions, which permitted foreign subsidiaries of U.S. companies to engage in certain dealings with Iran. However, the General License did not authorize the re-exportation of goods, services, or technology from a third country.
After discovering the misconduct at the subsidiary, the parent firm undertook an internal investigation and terminated the employees involved. OFAC determined that while the parent voluntarily self-disclosed the apparent violations, the conduct constituted an egregious case due, in part, to its employees' effort to circumvent the directive to halt all Iran-related business.
To settle the charges, the company agreed to pay $473,157.
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