U.S. and UAE companies agree to settle violations of Iranian sanctions

Companies in U.S. and UAE agree to settle violations of Iranian sanctions

Companies in U.S. and UAE agree to settle violations of Iranian sanctions

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today announced that two companies—one located in Dubai, and another in Richmond, Virginia—have agreed to settle their potential civil liabilities for apparent violations of the Iranian transactions and sanctions regulations (ITSR).

  • According to one OFAC release [PDF 197 KB], the company located in Dubai, United Arab Emirates—that sells fluid handling and other equipment for the energy industry and other sectors—has agreed to pay more than U.S. $415,000 to settle apparent violations (committed between May 2015 and March 2016) when the company conspired with Dubai- and Iran-based companies to export certain storage tank cleaning units from the United States to Iran. As a result, the company caused its U.S.-based affiliate to indirectly export goods from the United States to Iran by falsely listing a Dubai-based company as the end-user on its export documentation. The scope of the conspiracy included additional incomplete and contemplated export transactions with Iran. OFAC determined that the company did not voluntarily self-disclose the apparent violations, and that the apparent violations constitute an egregious case.

  • A separate OFAC release [PDF 191 KB] explains that a company located in Richmond, Virginia, agreed to pay approximately $16,800 for apparent violations of the ITSR on behalf of its former subsidiary (now an operating unit). The apparent violations were committed between May 2015 and March 2016 when the company—that manufactures and sells storage tank cleaning equipment—referred a known Iranian business opportunity to its foreign affiliate in Dubai. The foreign affiliate then orchestrated a scheme to export goods from the United States to Iran and did so by using the former subsidiary to export its cleaning units to Iran. OFAC determined that the company did not voluntarily self-disclose the apparent violations, and that the apparent violations constitute a non-egregious case.


For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
Principal
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
Principal
T: 312-665-3229
E: christopheryoung@kpmg.com

Gisele Belotto
Managing Director
T: 305-913-2779
E: gbelotto@kpmg.com

George Zaharatos
Principal
T: 404-222-3292
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
Managing Director
T: 612-305-5533
E: jlibby@kpmg.com

 

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