United States

Between June 2019 and July 2021 a U.S. person provided management consulting to an Iranian software company, received Iranian dividends into U.S. bank accounts and purchased Iranian real property. OFAC found the person provided substantive advice, analysis and information across 19 virtual meetings with Iranian company leadership while knowing sanctions prohibited the conduct.

Rice Lake's Italian subsidiary Dini Argeo S.r.l. exported weighing equipment to Iran through a UAE distributor between June 2019 and November 2021, knowing the goods were destined for an Iranian company. Rice Lake self-disclosed the violations after receiving a tip in late 2021 and ceased the sales while implementing compliance enhancements.

Between April 2019 and May 2021 FTI indirectly dealt in prohibited debt of VTB Bank OAO by issuing invoices with maturity longer than the permissible 14-day term. FTI continued performing services and extending credit to VTB despite unpaid invoices and warning signs that the payment arrangement violated sanctions restrictions.

From November 2023 to June 2025 Adani Enterprises purchased LPG shipments from a Dubai-based trader that in fact originated in Iran, causing U.S. financial institutions to process 32 USD payments totalling approximately $192,104,044. Despite red flags including third-party warnings, suspicious vessel behaviour and commercially implausible pricing, the company failed to conduct adequate due diligence on the cargo's true origin.

From 21 June 2021 to 15 June 2022 TradeStation processed 481 trades through its mobile application totalling $4,442,645 in violation of multiple sanctions programs. The violations resulted from failures in its sanctions compliance systems, including disabled geo-blocking controls and discontinued testing that went unaddressed for nearly a year.

Between January 2018 and December 2021 a U.S. citizen provided managerial services to Syrian real estate companies as an executive and board member. The individual knew Syria was subject to sanctions and only ceased the conduct after receiving an OFAC administrative subpoena.

Between 2018 and 2022 IMG Academy entered into yearly tuition enrolment agreements with two sanctioned individuals and processed payments amounting to 89 violations over five years. The settlement reflects non-egregious violations, substantial cooperation and remedial measures implemented after the company discovered the apparent violations.

Exodus provided customer support services to users in Iran from October 2017 through January 2019, enabling access to digital asset exchanges. On 12 occasions found egregious, staff recommended VPNs to help users circumvent exchange compliance controls after explicitly acknowledging U.S. sanctions restrictions.

A U.S. person settled civil liability for 122 apparent violations occurring between 2018 and 2022 while serving as fiduciary of a sanctioned Russian oligarch's family trust. Following the oligarch's 2018 designation the person continued authorising trust asset transfers, payments and substantive actions despite the oligarch's continued influence through a proxy.

Between April 2018 and May 2020 Gracetown, a New York property management company, received 24 payments on behalf of a company owned by sanctioned oligarch Oleg Deripaska despite prior OFAC notice prohibiting such dealings. Gracetown also failed to report blocked assets in its possession and control for over 45 months.

IPI, a Chicago-based private equity firm, solicited and received $50 million in investments from Russian oligarch Suleiman Kerimov through Definition Services, Inc. between 2017 and 2018. It then continued managing those investments for four years after Kerimov's 6 April 2018 designation, conducting 51 prohibited transactions including capital calls, profit distributions and management fee payments.

Between April 2023 and March 2024 the individual, acting through King Holdings LLC of Atlanta, Georgia, wilfully dealt in residential real property owned by a blocked individual, including by mortgaging, renovating and selling the property. The individual received direct notice from OFAC that the property was blocked, continued to deal in it, and concealed the sale from OFAC in a subpoena response.

Between December 2016 and October 2018 ShapeShift, a digital asset exchange incorporated in Switzerland and operating from Denver, Colorado, processed 17,183 digital asset transactions valued at $12,570,956 with users in Cuba, Iran, Sudan and Syria without sanctions screening. The company lacked a compliance program to screen users or transactions for sanctioned jurisdictions until it received an OFAC administrative subpoena.

Laws Invoked: Venezuela Sanctions Regulations 31 C.F.R. § 591.201; Weapons of Mass Destruction Proliferators Sanctions Regulations 31 C.F.R. § 544.201; Global Terrorism Sanctions Regulations 31 C.F.R. § 594.204; Iranian Transactions and Sanctions Regulations 31 C.F.R. § 560.206; 31 C.F.R. part 501. In May 2022 Fracht, an international freight forwarder based in Houston, Texas, contracted with a blocked Venezuelan airline subsidiary to transport car parts from Mexico to Argentina, paying approximately $995,000 for services involving an aircraft previously designated as blocked property of Iran's Mahan Air. The aircraft was staffed by Iranian nationals and had connections to Iran and Mahan Air, creating apparent violations across multiple sanctions programs.

From July 2016 through January 2024 Interactive Brokers provided brokerage services to customers in Iran, Cuba, Syria and Crimea and processed prohibited transactions involving blocked Russian banks, Chinese military companies and designated individuals. The firm discovered the violations through a self-initiated 2018 compliance review and voluntarily disclosed 12,367 apparent violations to OFAC.

From May 2018 through October 2020 Harman's British-based employees aided its UAE distributor in diverting audio products to Iran, using coded language such as "northern region" to obscure the transactions. The violations involved approximately $148,261 in goods across 11 shipments, with at least one end user being the Government of Iran.

Between January 2022 and July 2023 the Colombian subsidiary of Key Holding, a privately held global logistics company based in Delaware, managed logistics for 36 freight shipments valued at $3,056,264 to Cuba without authorisation. The company voluntarily self-disclosed the violations in January 2024 during due diligence for a pending sale and subsequently implemented compliance reforms.

Between 2016 and 2021 Unicat's former chief executive officer and former employees supplied catalyst products and consulting services to customers in Iran and sold goods to a blocked Venezuelan entity. The settlement reflects OFAC's determination that the conduct was egregious and voluntarily self-disclosed, accounting for cooperation with the investigation and remedial measures undertaken.

GVA Capital, a venture capital firm based in San Francisco, managed a $20 million investment for sanctioned Russian oligarch Suleiman Kerimov from April 2018 through May 2021, working through Kerimov's nephew as proxy despite awareness of his blocked status. The firm also failed to produce approximately 1,300 responsive documents to an OFAC subpoena for over two years, constituting 28 violations of reporting obligations.

Haas, a California manufacturer of machine tools and related parts, indirectly supplied CNC machines, spare parts and authorisation codes to blocked Russian entities between December 2019 and March 2022. The settlement reflects a determination that the violations were not voluntarily disclosed and that eight of 21 violations were egregious, though mitigated by significant remedial efforts and cooperation.

Family International Realty, a Miami, Florida-based real estate company, and its natural-person owner transferred nominal ownership of three luxury condominiums belonging to sanctioned Russian oligarchs to non-sanctioned family members and shell companies between 2018 and 2023. The company earned approximately $182,442 in commissions and reimbursements through rental operations and property sales conducted on behalf of the sanctioned parties, and the owner separately pleaded guilty to criminal charges arising from the same conduct.

Between January and March 2024 SkyGeek, a New York-based supplier of aviation products, made shipments and attempted refunds to two specially designated nationals in the UAE after they were added to the sanctions list. The settlement reflects non-egregious violations with voluntary self-disclosure of four violations and cooperation with OFAC.

Between November 2019 and March 2022 Córdoba, a California manufacturer of musical instruments, shipped instruments valued at $118,831 on nine occasions to a Dubai company that forwarded them to Iran, knowing their Iranian destination. The company's new parent discovered the arrangement in April 2023 following an acquisition and initiated a voluntary self-disclosure to OFAC.

Between January and June 2021 a U.S. person managing legal, financial and administrative affairs for a U.S. equine industry company executed six payments totalling $45,179 on behalf of a sanctioned individual despite knowledge of the designation. Three payments provided indirect compensation to the blocked individual and three facilitated that individual's business operations in the UAE.

Between November 2018 and February 2022 five foreign subsidiaries of C.H. Robinson, a Minnesota-based global transportation and logistics company, provided freight brokerage or transportation services for 82 shipments involving Iran or Cuban-origin goods without adequate sanctions compliance controls. The settlement reflects OFAC's determination that the violations were non-egregious, voluntarily self-disclosed and remediated through enhanced compliance measures including system integration and employee training.

Between 2015 and 2019 Aiotec, a Berlin-headquartered sourcer of industrial equipment for the energy sector, conspired to cause a U.S. company to indirectly sell and supply an Australian polypropylene plant to Iran, concealing this through falsified shipping documents and false statements. The company remitted approximately $9.46 million in payments through U.S. financial institutions while misrepresenting the plant's destination as Turkey and the United Arab Emirates.

Between 2019 and 2022 the individual executed a plan to purchase, renovate and operate a hotel in Iran, using foreign money services businesses to evade sanctions. The individual maintained accounts at blocked Iranian financial institutions and committed 75 violations through unauthorised funds transfers to and from Iran.

ALICO, a Delaware subsidiary of MetLife, Inc., issued group medical and life insurance policies to three entities owned or controlled by the Government of Iran in the UAE from February 2022 to August 2023. The company processed 2,331 premiums and claims totalling $446,077 related to these blocked policyholders before discovery and self-disclosure.

Subsidiaries of Vietnam Beverage Company Limited, a Vietnamese holding company whose subsidiaries produce and sell alcoholic drinks, executed 26 contracts for sales to North Korean entities between January 2016 and September 2018, resulting in 43 wire transfers totalling approximately $1,141,547 processed through U.S. financial institutions. The reduced settlement amount reflects the company's cooperation with OFAC's investigation and significant remedial measures implemented after discovering the violations.

Charles River Systems, a Massachusetts-based non-bank technology company, redated or reissued invoices for customers subject to Directive 1 between 2016 and 2020, involving 38 apparent violations and approximately $1,270,456 in invoices. The violations occurred when staff manipulated invoice dates to prevent payment rejections and accepted late payments outside applicable debt tenor windows.

Between May 2019 and November 2021 Mondo TV, an animation company headquartered in Rome, Italy, remitted approximately $537,939 to a North Korean government-owned studio for animation work through U.S. financial institutions. The company's senior management approved the contracts and payments while knowing it was engaging a DPRK entity through intermediaries with U.S. accounts.

From 2017 to 2018 SCG Plastics, part of a multinational enterprise headquartered in Bangkok, Thailand that sells plastic resins, processed $291 million in wire transfers for Iranian-origin plastic resin sales using deceptive shipping documentation that obscured Iran's involvement. The company caused significant economic benefits to flow to Iran's petrochemical sector by enabling an Iranian joint venture to access international financial systems.

Between 2014 and 2018 EFG, a global private banking group based in Switzerland with approximately 40 global subsidiaries, processed 727 securities transactions totalling $29,939,701 for Cuban clients through U.S. custodians. It also processed 141 transactions worth $468,615 for a Kingpin Act-designated individual and five dividend payments valued at $1,200 for a Russia-designated person.

PURE, an insurance organisation based in White Plains, New York, engaged in transactions related to four insurance policies involving a blocked Panama-based company owned by Viktor Vekselberg between May 2018 and July 2020. The company collected 38 premium payments totalling $308,391 and paid a $7,500 claim related to one policy while the entity remained blocked.

CoinList Markets, a San Francisco-based virtual currency exchange and money services business, processed 989 transactions totalling $1,252,280 on behalf of users in Crimea from April 2020 to May 2022. The violations occurred because its screening procedures failed to identify users who listed Russia as their residence but provided Crimean addresses.

Nasdaq's former Armenian subsidiary processed trades involving a sanctioned subsidiary of Bank Mellat between December 2012 and September 2014, generating 151 violations of the Iranian sanctions regulations. The settlement reflects OFAC's determination that the violations were non-egregious and voluntarily self-disclosed by Nasdaq in 2014.

Laws Invoked: Iranian Transactions and Sanctions Regulations 31 C.F.R. § 560.204; Syrian Sanctions Regulations 31 C.F.R. § 542.207; Executive Order 13722; North Korea Sanctions Regulations 31 C.F.R. §§ 510.206, 510.212; Executive Order 13685; Ukraine-/Russia-Related Sanctions Regulations 31 C.F.R. §§ 589.207, 589.213; Cuban Assets Control Regulations 31 C.F.R. § 515.201; Executive Order 14065; 50 U.S.C. § 1701 et seq.. Binance Holdings, Ltd., a Cayman Islands virtual currency exchange with affiliates around the world, matched and executed virtual currency trades between U.S. users and users in sanctioned jurisdictions from August 2017 through October 2022, processing 1,667,153 violative transactions totalling approximately $706,068,127. Senior management deliberately maintained weak compliance controls while misrepresenting the company's sanctions compliance to third parties and encouraging users to circumvent controls via VPNs.

Between November 2017 and July 2022 Swift Prepaid Solutions, Inc. d/b/a daVinci Payments, a financial services and payments firm, redeemed prepaid cards on 12,391 occasions involving users with IP addresses or email suffixes linked to sanctioned jurisdictions. The company discovered the violations through internal compliance review and subsequently implemented geolocation controls to prevent platform access from sanctioned regions.

Emigrant Bank, a bank located in New York, maintained a certificate of deposit account for two Iranian residents for approximately 26 years and processed 30 transactions totalling $91,051.13 between June 2017 and March 2021. The bank had actual knowledge of the accountholders' Iranian addresses but failed to implement controls to prevent prohibited services to Iranian account holders.

3M's Swiss subsidiary knowingly sold reflective licence plate sheeting via a German reseller to an entity controlled by Iran's Law Enforcement Forces between 2016 and 2018. A U.S. person employed by a 3M foreign subsidiary was closely involved in facilitating these prohibited sales.

The UAE subsidiary of Construction Specialties, a New Jersey company selling specialised building materials, imported U.S. building materials and knowingly re-exported them to Iran between December 2016 and August 2017, with senior managers falsifying documents to conceal the destination. A U.S. employee discovered the conduct and reported it to headquarters, prompting the company to terminate the activity and voluntarily disclose the violations to OFAC.

Between February 2015 and October 2016 Swedbank Latvia AS, a subsidiary of Swedbank AB (publ) headquartered in Stockholm, processed 386 transactions totalling approximately $3.3 million through U.S. correspondent banks, initiated by a Crimea-based customer using the bank's e-banking platform from a Crimea IP address. The bank held customer KYC data indicating the client's Crimea presence but relied on false assurances and rerouted rejected payments through a different correspondent bank.

Murad, LLC, a cosmetics company based in El Segundo, California, conspired with Iran-based and UAE-based distributors to export approximately $11 million in products to Iran over eight years across at least 62 export occasions, and voluntarily self-disclosed following its 2015 acquisition by Unilever US; its settlement was $3,334,286. A former senior executive separately settled for $175,000 for signing distribution agreements in 2009 and 2015 facilitating sales to Iran and overseeing the departments responsible, for violations between June 2016 and September 2017 that were not voluntarily disclosed.

Between January 2014 and November 2019 Poloniex, a Delaware company with its principal place of business in Boston that operated an online trading and settlement platform, processed 65,942 transactions valued at approximately $15,335,349 for customers apparently located in Crimea, Cuba, Iran, Sudan and Syria. OFAC found that Poloniex failed to exercise due caution or care for its sanctions compliance obligations when it operated with no sanctions compliance program for more than a year.

A subsidiary of British American Tobacco, a tobacco and cigarette manufacturer headquartered in London, formed a joint venture in North Korea in 2001 to manufacture and distribute cigarettes, then purported to divest while maintaining control through a complex scheme. Between 2009 and 2016 the North Korea company remitted USD payments through various accounts in China and U.S. banks, involving designated sanctioned entities.

Laws Invoked: Cuban Assets Control Regulations 31 C.F.R. § 515.201(b)(2); Iranian Transactions and Sanctions Regulations 31 C.F.R. §§ 560.204, 560.206(a)(2); Syrian Sanctions Regulations 31 C.F.R. § 542.207; Ukraine-/Russia-Related Sanctions Regulations 31 C.F.R. § 589.207. Between July 2012 and April 2019 Microsoft, including subsidiaries Microsoft Ireland Operations Ltd. and Microsoft Rus LLC, committed 1,339 apparent violations by selling software licences and services to SDNs and blocked persons in sanctioned jurisdictions, totalling $12,105,189.79 in sales value. The violations resulted from failures in restricted-party screening and end-customer identification, including instances where Microsoft Russia employees circumvented internal controls.

Between March 2017 and May 2022 Uphold, a money services business operating a global multi-asset digital trading platform, processed 152 transactions totalling $180,575.80 in apparent violation of sanctions involving Iran, Cuba and Venezuela. Violations included maintaining accounts for customers identifying themselves in sanctioned jurisdictions and processing transactions for employees of state-owned Venezuelan entities.

Wells Fargo and its predecessor Wachovia customised software that enabled a European bank to process trade finance transactions with U.S.-sanctioned jurisdictions from 2008 to 2015 using the bank's technological infrastructure. OFAC found that Wells Fargo did not identify or stop the European bank's use of the software platform for trade-finance transactions involving sanctioned jurisdictions and persons for seven years.

Godfrey Phillips India, a tobacco manufacturer registered in Mumbai, exported tobacco indirectly to North Korea in 2017 using intermediaries in Thailand and Hong Kong to obscure the transaction, causing U.S. financial institutions to process payments for the shipments. The company directed payments in USD through U.S. correspondent banks and a foreign branch of a U.S. bank, thereby causing U.S. persons to facilitate the exportation of tobacco to the DPRK.

Danfoss FZCO, a subsidiary of the Danish manufacturer of refrigeration and cooling products, directed customers in Iran, Syria and Sudan to remit payments to its UAE bank account at a U.S. financial institution and made payments from that account to entities in sanctioned jurisdictions between November 2013 and August 2017. The subsidiary used third-party payers to disguise transaction originators and beneficiaries, causing the U.S. financial institution to facilitate 225 prohibited financial transactions.

Between 14 October 2015 and 29 June 2019 Payward, Inc. d/b/a Kraken, a Delaware-incorporated virtual currency exchange, processed 826 transactions totalling approximately $1,680,577.10 on behalf of individuals appearing to be located in Iran. Kraken failed to implement IP address blocking on transactional activity, allowing account holders to access and trade from sanctioned jurisdictions despite initial account verification controls.

Nodus International Bank, an international financial entity located in Puerto Rico, engaged in three unlicensed transactions totalling $50,271.29 involving blocked property of a designated individual without obtaining an OFAC licence. The bank failed to maintain complete records and submitted inconsistent annual reports regarding blocked accounts to OFAC. OFAC issued a Finding of Violation in lieu of a civil monetary penalty.

Bittrex, a private company based in Bellevue, Washington providing an online virtual currency exchange and hosted wallet services, failed to screen customer information for sanctioned jurisdictions despite holding IP and physical address data indicating users were located in Crimea, Cuba, Iran, Sudan and Syria. The company operated 1,730 such accounts processing 116,421 transactions totalling approximately $263.5 million in apparent violations between March 2014 and December 2017.

Laws Invoked: Cuban Assets Control Regulations 31 C.F.R. § 515.201; Iranian Transactions and Sanctions Regulations 31 C.F.R. § 560.204; Syrian Sanctions Regulations 31 C.F.R. § 542.207; North Korea Sanctions Regulations 31 C.F.R. § 510.206; Executive Order 13685; 31 C.F.R. part 501. Between September 2016 and September 2021 Tango Card, a Seattle-based supplier and distributor of electronic rewards, transmitted 27,720 stored value products to individuals with IP and email addresses associated with sanctioned jurisdictions. Tango Card lacked geolocation controls to identify reward recipients in sanctioned locations although it possessed the technological tools to do so.

From December 2011 to July 2016 CFM, a financial institution based in Monaco specialising in wealth management and corporate and investment banking, processed 426 transactions totalling approximately $1,233,967 for individuals residing in sanctioned jurisdictions despite holding customer address information indicating their location. CFM failed to fully implement its parent company's global sanctions compliance program and initially applied internal restrictions that did not prevent securities-related payments to sanctioned customers.

From April 2013 to April 2016 CA Indosuez (Switzerland) S.A., a financial institution based in Switzerland specialising in wealth management and corporate and investment banking, processed 273 transactions totalling approximately $3,076,180 on behalf of individuals ordinarily resident in sanctioned jurisdictions. CAIS failed to fully implement its parent company's global sanctions compliance program and allowed customers in these jurisdictions to purchase securities and engage in commercial transactions through the U.S. financial system.

MidFirst Bank maintained accounts and processed 34 transactions totalling approximately $10,483 on behalf of two individuals designated as blocked persons, continuing for 14 days after their 21 September 2020 addition to the SDN List. The violations resulted from MidFirst's misunderstanding of its vendor's screening frequency, which reviewed the entire customer base monthly rather than daily as MidFirst had believed. OFAC issued a Finding of Violation in lieu of a civil monetary penalty.

American Express National Bank, a subsidiary of American Express Company providing charge and credit card products and travel-related services, processed 214 transactions totalling $155,189.42 for an account whose supplemental cardholder was designated for illegal drug distribution and money laundering, between 7 May and 6 July 2018. Human error and compliance program deficiencies, including failure to properly review high-confidence sanctions alerts and improper removal of an account suspension, enabled the violations.

Banco Popular de Puerto Rico, a Puerto Rican bank with branches in Puerto Rico and the Virgin Islands, processed 337 transactions totalling $853,126 for two low-level Venezuelan government employees without blocking their accounts, despite holding documentation of their employment status. A 14-month delay between the executive order's issuance and identification of the accounts resulted in the apparent violations.

Laws Invoked: North Korea Sanctions Regulations 31 C.F.R. § 510.212; Syrian Sanctions Regulations 31 C.F.R. § 542.205; Iranian Transactions and Sanctions Regulations 31 C.F.R. § 560.203; Weapons of Mass Destruction Proliferators Sanctions Regulations 31 C.F.R. § 544.201; Global Terrorism Sanctions Regulations 31 C.F.R. § 594.201. Toll, an international freight forwarding and logistics company headquartered in Melbourne, Australia, originated or received 2,958 payments through U.S. financial institutions involving sanctioned jurisdictions and designated entities totalling approximately $48.4 million between January 2013 and February 2019. The company failed to adopt adequate compliance policies and controls to prevent transactions with sanctioned parties despite warnings from its financial institution and its own existing policy.

Between June 2016 and November 2017 Chisu, a Florida-based corporation affiliated with a Suriname-based distributor of explosives and related materials, procured Cuban-origin explosives on four occasions for a mining project in Suriname, knowing the goods originated from Cuba. Upon learning of the sanctions implications in January 2018 Chisu immediately ceased all activities involving Cuba.

Newmont Suriname, a wholly owned subsidiary of Newmont Corporation, a multinational mining firm headquartered in Denver, Colorado, purchased Cuban-origin explosives and explosive accessories from a third-party vendor on at least four occasions between 2014 and 2016. The settlement reflects OFAC's determination that the conduct was non-egregious and voluntarily self-disclosed.

S&P Global, a New York-based provider of business information and financial analytics, reissued and redated multiple invoices to extend credit to Rosneft, a sanctioned Russian oil company, in violation of debt and equity restrictions. The company ultimately accepted past-due payments totalling $82,500 from Rosneft across four reissued invoices spanning August 2016 to October 2017.

From August 2016 through May 2018 Sojitz HK, a Hong Kong-based company engaged in offshore trading and cross-border trade financing, made 60 separate U.S. dollar payments totalling $75,603,411 for approximately 64,000 tons of Iranian-origin HDPE, processing these payments through U.S. financial institutions. Non-compliant employees deliberately omitted Iranian origin information from transactional documents and concealed this from company management and compliance personnel.

Airbnb Payments, a registered money services business incorporated in 2013 under Delaware law, processed payments for approximately 3,464 extrapolated stay transactions in Cuba by guests travelling for unauthorised reasons between September 2015 and March 2020. The company also failed to maintain required records for 3,076 extrapolated experience transactions and processed 44 transactions involving non-U.S. persons prior to receiving an OFAC licence.

TD Bank, N.A., a bank incorporated in Wilmington, Delaware, processed 1,479 transactions totalling $382,685.38 for North Korean mission employees without required OFAC licensing, owing to screening deficiencies and incorrect citizenship recordkeeping. It also maintained accounts for an SDN List designee for four years, incorrectly dismissing multiple sanctions screening alerts before blocking the accounts in February 2020; the settlement comprises $105,238.65 for the North Korea matter and $9,766.39 for the Kingpin matter.

Between February and March 2016 a natural U.S. person accepted four payments totalling $133,860 into a U.S. bank account on behalf of an Iran-based cement company selling Iranian-origin clinker. The individual coordinated logistics and facilitated the sale while knowing that such transactions with Iran were prohibited.

Between January 2005 and February 2009 the London branch of Mashreqbank psc, a commercial bank headquartered in the United Arab Emirates, processed 1,760 payments through U.S. financial institutions for Sudanese banks without identifying the sanctioned parties in the payment messages. The bank's practices prevented U.S. intermediaries from intercepting transactions that violated sanctions requirements.

U.S.-person senior managers of Cameron, a Houston-based supplier of goods and services for the oil and gas industries and a subsidiary of Schlumberger Limited, approved five contracts for its Romanian subsidiary to supply goods to Gazprom-Neft Shelf for an Arctic offshore oil production platform between July 2015 and November 2016. Cameron Romania made 111 shipments of oil production or exploration goods to the sanctioned entity during the violation period.

Between December 2015 and April 2016 three U.S. employees of Schlumberger Rod Lift, a Frisco, Texas-based company then a subsidiary of Schlumberger Lift Solutions LLC, facilitated the sale and shipment of oilfield equipment from a Canadian Schlumberger subsidiary to a Chinese joint venture for delivery to Sudan. The employees were aware Sudan was sanctioned and had received training and internal communications prohibiting such transactions.

NewTek, a San Antonio, Texas company that develops and supplies live production and 3D animation hardware and software, exported goods and technology to third-country distributors between December 2013 and May 2018 knowing the products were intended for companies and individuals in Iran. Three exported products were sold to Islamic Republic of Iran Broadcasting, an entity on OFAC's SDN List, and NewTek provided supporting services on multiple occasions.

First Bank SA, located in Romania, and its U.S. parent company JC Flowers & Co. processed 98 commercial transactions totalling $3,589,189 through U.S. banks on behalf of parties in Iran and Syria between 2016 and 2019. The settlement reflects OFAC's determination that the violations were voluntarily self-disclosed and non-egregious.

Bank of China (UK) Limited, a financial institution located in London, processed 111 commercial transactions totalling $40,599,184 through the U.S. financial system between 4 September 2014 and 24 February 2016 on behalf of parties in Sudan. The settlement reflects OFAC's determination that the violations were voluntarily self-disclosed and constitute a non-egregious case.

Laws Invoked: Executive Order 13685; Zimbabwe Sanctions Regulations 31 C.F.R. § 541.201; Weapons of Mass Destruction Proliferators Sanctions Regulations 31 C.F.R. § 544.201; Iranian Transactions and Sanctions Regulations 31 C.F.R. § 560.204; Sudanese Sanctions Regulations 31 C.F.R. § 538.205; Syrian Sanctions Regulations 31 C.F.R. § 542.207. Between February 2013 and February 2018 Payoneer, a publicly traded New York-based online money transmitter and provider of prepaid access, processed 2,220 transactions totalling $793,950.70 in violation of OFAC sanctions programs. Compliance deficiencies including weak screening algorithms and failure to monitor sanctioned locations enabled sanctioned parties to transact through the platform.

Alfa Laval Tank, Inc., a former subsidiary of Alfa Laval Inc. of Richmond, Virginia that manufactures and sells storage tank cleaning equipment, referred a known Iranian business opportunity to its foreign affiliate in Dubai between May 2015 and March 2016. The company subsequently exported two Gamajet cleaning units worth $18,585 to a Dubai entity that re-exported them to Iran.

Alfa Laval Middle East, a company located in Dubai that sells fluid handling and other equipment for the energy industry, conspired with Dubai- and Iran-based companies to export Gamajet storage tank cleaning units from the United States to Iran between May 2015 and March 2016, falsely listing a Dubai company as the end user. The conspiracy included one completed export worth $18,585, an incomplete transaction worth $5,170 and contemplated transactions worth approximately $181,453.

Laws Invoked: Foreign Narcotics Kingpin Sanctions Regulations 31 C.F.R. § 598.203; Narcotics Trafficking Sanctions Regulations 31 C.F.R. § 536.201; Syrian Sanctions Regulations 31 C.F.R. § 542.207; Democratic Republic of the Congo Sanctions Regulations 31 C.F.R. § 547.201; Central African Republic Sanctions Regulations 31 C.F.R. § 553.201; Weapons of Mass Destruction Proliferators Sanctions Regulations 31 C.F.R. § 544.201. Between March 2013 and June 2020 MoneyGram, a global payments company based in Dallas, Texas, processed 359 transactions totalling $105,627 on behalf of approximately 40 individuals on the SDN List and two individuals initiating commercial transactions involving Syria. MoneyGram failed to screen inmates against the SDN List and suffered screening, technology and human error failures.

SAP SE, a software company headquartered in Walldorf, Germany, exported software and related services to Iran through third-country pass-through entities and cloud-based subsidiaries from June 2013 to January 2018. The settlement reflects OFAC's determination that the violations were non-egregious and voluntarily self-disclosed, with consideration for SAP's remedial response.

Alliance Steel, a designer and manufacturer of prefabricated steel structures based in Oklahoma City, outsourced engineering work to an Iranian company owned by the brother of its VP of Engineering from October 2013 to October 2018, resulting in 61 violations. The settlement reflects non-egregious conduct, voluntary self-disclosure, remedial measures and cooperation with OFAC's investigation.

Nordgas, an Italian company that produces and sells components for gas boiler systems, re-exported 27 shipments of U.S.-origin air pressure switches valued at $2,526,783 to Iranian companies between March 2013 and March 2017 while using code words and misrepresenting end users to conceal its conduct. The misconduct was determined egregious and not voluntarily disclosed, involving wilful violations after the company was explicitly informed such re-exportations would violate U.S. sanctions law.

UniControl, a Cleveland, Ohio-based manufacturer of process controls, airflow pressure switches and boiler controls, exported 21 shipments of air pressure switches valued at $687,189 to European companies that re-exported them to Iran between July 2013 and March 2017. The company failed to respond appropriately to multiple warning signs indicating re-exportation to Iran, including explicit mention of Iran in a sales agreement and a request to remove "Made in USA" labels.

Laws Invoked: Executive Order 13685; Cuban Assets Control Regulations 31 C.F.R. § 515.201; North Korea Sanctions Regulations 31 C.F.R. § 510.206; Iranian Transactions and Sanctions Regulations 31 C.F.R. § 560.204; Sudanese Sanctions Regulations 31 C.F.R. § 538.205; Syrian Sanctions Regulations 31 C.F.R. § 542.207. BitPay, a private company based in Atlanta, Georgia offering a payment processing solution for merchants to accept digital currency, processed 2,102 transactions for buyers located in sanctioned jurisdictions between June 2013 and September 2018 despite having location data available. The company's transaction review process failed to analyse identification and location information, allowing approximately $129,000 in digital currency transactions with sanctioned individuals.

PT Bukit Muria Jaya, a paper products manufacturer located in Indonesia, exported cigarette paper to DPRK entities and directed payments through U.S. banks, causing 28 wire transfers to clear between March 2016 and May 2018. After learning of its sanctions exposure the company ceased DPRK dealings and implemented a formal compliance program.

Between August 2011 and April 2013 UBAF, a bank based in France that facilitates trade finance between Europe and the Middle East, North Africa, sub-Saharan Africa and Asia, operated U.S. dollar accounts on behalf of sanctioned Syrian financial institutions and indirectly conducted USD business through the U.S. financial system. UBAF processed 127 transactions totalling $2,079,339,943.52 in apparent violation of Syria-related sanctions.

Between March 2015 and December 2019 BitGo, a technology company based in Palo Alto, California offering non-custodial secure digital wallet management services, processed 183 digital currency transactions totalling $9,127.79 on behalf of individuals located in sanctioned jurisdictions. BitGo failed to implement controls preventing account access by users in these regions despite holding IP address data identifying their locations.

The National Commercial Bank, headquartered in Jeddah, Saudi Arabia, processed 13 USD transactions totalling $5,918,560 between November 2011 and August 2014 that benefited Sudanese or Syrian counterparties or involved goods from those countries, transiting through the U.S. financial system. The violations were determined non-egregious, with the bank receiving mitigation credit for voluntary disclosure of the Syria-related violations and enhanced compliance measures implemented afterwards.

Berkshire's Turkish subsidiary Iscar Turkey sold cutting tools to distributors knowing the goods would be shipped to Iran for resale to Iranian end users, from December 2012 to January 2016. Iscar Turkey's management concealed these dealings through private emails, false names and fraudulent records while Berkshire enforced compliance policies.

Generali Global Assistance, a New York-incorporated travel assistance services company, processed 2,593 transactions valued at $285,760 in violation of the CACR by intentionally routing Cuba-related reimbursement payments through a Canadian affiliate to avoid direct payments to Cuban parties. The company codified this indirect payment process in its procedures manual between 26 June 2010 and 15 January 2015.

From January 2016 to June 2016 Anite Finland Oy, then a subsidiary of Keysight Technologies of Santa Rosa, California, completed six orders valued at $331,089 containing U.S.-controlled content destined for Iranian end users without OFAC authorisation. After Keysight's August 2015 acquisition of Anite and its directive to cease Iran sales, employees concealed ongoing transactions through obfuscation before Keysight discovered the misconduct and self-disclosed to OFAC.

Comtech Telecommunications Corp. and Comtech EF Data Corp. indirectly exported satellite equipment and facilitated services and training to Sudan's Civil Aviation Authority from June 2014 to October 2015 despite OFAC sanctions prohibiting such transactions. The companies voluntarily self-disclosed and settled the apparent violations of the Sudan sanctions regulations following investigation.

Deutsche Bank Trust Company Americas, a financial institution headquartered in New York, processed a $28.8 million fuel oil transaction on 6 August 2015 involving a designated entity without conducting independent due diligence despite knowing of potential involvement. Between 22 and 30 December 2015 it processed 61 transactions totalling $276,742.90 destined for a designated bank because it failed to include that bank's SWIFT identifier in its screening system; the settlement comprises $157,500 and $425,600 for the two matters.

A natural U.S. person employed as a civilian direct hire of the U.S. Army and stationed at the U.S. embassy in Bogota, Colombia engaged in at least 24 transactions totalling approximately $3,349.33, providing jewellery, meals, clothing, hotel rooms and gifts to a specially designated narcotics trafficker while maintaining a personal relationship. The individual conducted internet research regarding SDN List legality but failed to seek guidance from available government and legal resources at the embassy despite holding a national security position requiring a security clearance.

Foreign subsidiaries of Whitford, a cookware coating manufacturer based in Elverson, Pennsylvania, sold coatings to Iran between November 2012 and December 2015 despite sanctions prohibitions, with U.S.-person employees overseeing the transactions. The company subsequently hired outside counsel, self-disclosed the violations to OFAC and implemented remedial measures including appointing compliance monitors and adopting new compliance policies.

Essentra FZE, a cigarette filter and tear tape manufacturer located in the United Arab Emirates, exported cigarette filters to the DPRK through front companies in China using deceptive practices and received payments via U.S. bank accounts. A senior manager and an employee concealed the DPRK nexus despite company compliance policies prohibiting transactions with sanctioned jurisdictions.

From November 2011 to October 2018 deficient screening processes at Amazon, a Seattle-based provider of retail, ecommerce and digital services, allowed transactions with sanctioned persons and regions including Crimea, Iran and Syria. Amazon also failed to report 362 transactions in a timely manner that were conducted under a general licence carrying mandatory reporting requirements.

From July 2012 to September 2017 BIOMIN America, an animal nutrition company based in Overland Park, Kansas, coordinated 30 sales of agricultural commodities to a Cuban company through its foreign affiliates without OFAC authorisation, resulting in 44 violations. The company developed an incorrect transaction structure to circumvent direct export prohibitions rather than seeking appropriate licences or guidance.

SITA, a provider of commercial telecommunications network and information technology services to the civilian air transportation industry, provided commercial services and software benefiting five airlines designated as specially designated global terrorists between April 2013 and February 2018. The services included messaging, baggage tracking and dispatch software that were subject to U.S. jurisdiction because they were provided from or through the United States.

Eagle Shipping, a Marshall Islands ship management company headquartered in Stamford, Connecticut, settled potential civil liability for 36 apparent violations involving dealings in property interests of a sanctioned entity and the provision of transportation services from Burma to Singapore. The company voluntarily self-disclosed the violations, which occurred between 2011 and 2014, after an internal compliance review following its 2014 emergence from bankruptcy.

Park Strategies, a lobbying firm located in New York, signed a contract with Al-Barakaat, a designated global terrorist entity, to provide lobbying services and received a $10,000 payment between August and November 2017. The firm's executives had actual knowledge of the designation and voluntarily disclosed the violations to OFAC in October 2017.

AGR Canada fronted travel insurance policies providing coverage for Canadian residents travelling to Cuba between August 2010 and January 2015, processing 864 Cuba-related claims totalling approximately $518,092. Despite learning of the activity in 2010, AGR US, a Chicago-based property casualty insurer and wholly owned subsidiary of Allianz SE, failed to implement adequate controls to prevent the prohibited transactions until it began an investigation in 2014.

Between 2010 and 2014 ACE Europe processed at least 20,291 transactions totalling $367,847 in apparent violation of the CACR, comprising premium payments for Cuba-related travel insurance and associated claims payments. The violations resulted from a misunderstanding of U.S. sanctions applicability and a failure to include sanctions exclusionary clauses in global insurance policies; Chubb Limited settled as successor legal entity of the former ACE Limited.

Apple hosted and sold software applications owned by SIS, a designated narcotics trafficker, from February 2015 to May 2017, failing to identify SIS on the SDN List despite possessing matching address information. Apple made 47 payments associated with the blocked apps and collected $1,152,868 from customers downloading SIS applications during the sanctions period.

Apollo Aviation Group, a U.S. company organised and headquartered in Florida, leased aircraft engines that were subleased and installed on aircraft wet-leased to Sudan Airways, an entity on OFAC's SDN List. Although the lease agreements contained sanctions compliance clauses, Apollo failed to monitor engine usage and only discovered the violations after the engines were returned.

Between December 2010 and February 2014 the GE companies — Getsco Technical Services Inc., Bentley Nevada and GE Betz — accepted payments from Cobalt Refinery Company, a specially designated national of Cuba on the SDN List since 1995. The GE companies received 289 cheques totalling approximately $8,018,615 from Cobalt for goods and services provided to a Canadian customer with substantial ties to the Cuban government.

British Arab Commercial Bank, a commercial bank located in London with no offices, business or presence under U.S. jurisdiction, processed 72 bulk funding payments totalling $190,700,000 related to Sudan between September 2010 and August 2014 through U.S. financial institutions. The bank routed USD wire transfers through European banks that passed them via U.S. banks to fund a nostro account used for Sudanese transactions; $4,000,000 was remitted and the remainder of the $228,840,000 proposed penalty suspended.

Atradius Trade Credit Insurance, a trade credit insurer licensed in Maryland and a subsidiary of Atradius N.V., accepted assignment of a debt owed by Grupo Wisa, designated as a narcotics trafficker, and received $4,043,174.25 from the liquidation of that entity's assets. By accepting the assignment and receiving the liquidation payment, ATCI appeared to have dealt in property or interests in property of a specially designated narcotics trafficker; the base penalty amount was $590,282.

DAF, a wholly owned subsidiary of PACCAR Inc of Bellevue, Washington, sold 63 trucks to European customers between October 2013 and February 2015 knowing they were ultimately destined for Iran. The transactions involved three separate incidents where DAF personnel ignored warning signs and failed to conduct adequate inquiries regarding Iranian end users.

Cubasphere Inc. and an individual engaged in unauthorised travel-related transactions to and within Cuba by operating as tour operators and providing travel services to 104 persons on four trips between December 2013 and February 2014. They procured Cuban visas and cover letters for travellers from U.S. religious organisations, but the actual itineraries focused on sightseeing rather than humanitarian activities, and they instructed clients to conceal their travel.

Between 22 April 2011 and 16 October 2014 Expedia Group, a travel service provider headquartered in Bellevue, Washington, assisted 2,221 persons with Cuba-related travel services in violation of the Cuban Assets Control Regulations. After voluntarily self-disclosing the violations Expedia implemented remedial compliance measures throughout its corporate family and cooperated with OFAC's investigation.

Between December 2011 and June 2014 Hotelbeds USA, Inc., a Florida-incorporated subsidiary of Hotelbeds Group, provided unauthorised Cuba-related travel services to 703 non-U.S. persons by selling hotel accommodations and directing payments to accounts in Spain. Personnel possessed knowledge of the violations and operated under a misinterpretation that non-U.S. clients and offshore payments made the transactions permissible.

Western Union Financial Services, a money services business headquartered in Denver, Colorado, processed 4,977 transactions totalling approximately $1.275 million involving a designated entity between December 2010 and March 2015 without proper screening of location data. The company failed to immediately deactivate the sub-agent's network access after discovering the sanctions violation.

Between February 2011 and November 2011 MID-SHIP Group LLC, a global shipping and logistics company, processed five electronic funds transfers totalling approximately $472,861 related to payments for blocked IRISL vessels. The company's deficient compliance culture was evident, including instances where managers knew financial institutions had rejected payments for compliance and security reasons.

From 31 May 2016 to 11 January 2017 Haverly Systems, a New Jersey corporation with offices in Texas and California, transacted in debt of greater than 90 days maturity of Rosneft, an entity on OFAC's Sectoral Sanctions Identification List subject to Directive 2. The company lacked a sanctions compliance program at the time and ignored warning signs from rejected financial transactions before eventually receiving payment on reworked invoices.

Three UniCredit Group entities settled together: UniCredit Bank AG of München processed 2,158 payments totalling $527,467,001 through U.S. financial institutions between January 2007 and December 2011, including managing accounts for IRISL-affiliated companies without disclosing IRISL's involvement and following a formal guide for "OFAC neutral" payment handling ($553,380,759); UniCredit Bank Austria AG of Vienna ($20,326,340) and UniCredit S.p.A. of Milan ($37,316,322) processed transactions involving sanctioned countries and entities through U.S. financial institutions up to 2012 using non-transparent SWIFT MT202 cover messages.

Acteon Group Ltd. and 2H Offshore Engineering Ltd. settled for $227,500 after 2H Offshore's Malaysian affiliates produced analytical reports and sent employees to Cuba for oil exploration projects between 2011 and 2012, with senior managers concealing the Cuban dealings through document alterations and omissions. Acteon Group Ltd. and KKR & Co. Inc. settled for $213,866 after Seatronics subsidiaries rented or sold equipment for Cuban territorial water projects and provided servicing engineers between 2010 and 2012, and Seatronics-AE rented or sold marine equipment to UAE companies that embarked it on vessels operating in Iranian territorial waters.

Laws Invoked: Burmese Sanctions Regulations; Cuban Assets Control Regulations 31 C.F.R. part 515; Iranian Transactions and Sanctions Regulations 31 C.F.R. part 560; Sudanese Sanctions Regulations; Syrian Sanctions Regulations 31 C.F.R. part 542; Zimbabwe Sanctions Regulations 31 C.F.R. part 541; Executive Order 13582; 31 C.F.R. part 501. From June 2009 to June 2014 Standard Chartered Bank, a financial institution headquartered in the United Kingdom, processed 9,335 transactions totalling $437,553,380 involving persons subject to comprehensive sanctions programs, settling for $639,023,750. Separately SCB NY processed 1,795 transactions totalling $76,795,414 for sanctioned entities through its Zimbabwe affiliate, settling for $18,016,283.

Between 29 June 2013 and 30 December 2014 GQ, a Chinese-based subsidiary of Stanley Black & Decker of New Britain, Connecticut, exported and attempted to export 23 shipments of power tools and spare parts valued at $3,201,647.73 to Iran or to third countries for re-exportation to Iran. Stanley Black & Decker voluntarily self-disclosed the apparent violations after discovering the conduct and subsequently hired independent investigators.

Between July 2014 and January 2015 ZAG IP, LLC, a U.S. company with its business address in Newtown, Connecticut, purchased Iranian-origin cement clinker through five separate transactions totalling $14.5 million and resold it to Tanzania. ZAG relied on a supplier's misrepresentation that the goods were not subject to U.S. sanctions despite knowing they originated in Iran.

Between May 2012 and February 2016 AppliChem GmbH, a German manufacturer of chemicals and reagents for the pharmaceutical and chemical industries, violated § 515.201 of the CACR by selling chemical reagents to Cuba on 304 occasions. AppliChem's former owners designed "Caribbean Procedures" to conceal the Cuba sales from parent company ITW through code words and external documentation handlers.

Elsim, the Turkish affiliate of Kollmorgen Corporation of Radford, Virginia, serviced machines in Iran and provided products valued at $14,867 between July 2013 and July 2015 in violation of sanctions prohibitions. After an ethics hotline complaint exposed the conduct in October 2015, Kollmorgen conducted an investigation and voluntarily disclosed its findings to OFAC.

e.l.f. Cosmetics, a cosmetics company headquartered in Oakland, California, imported 156 shipments of false eyelash kits from Chinese suppliers containing materials sourced from North Korea between April 2012 and January 2017, totalling $4,427,019.26 in value. The company's compliance program was inadequate and failed to detect that approximately 80 per cent of the kits from two suppliers contained North Korean materials until January 2017.

Zoltek U.S. approved 26 purchases of acrylonitrile between its Hungarian subsidiary and Naftan, a Belarusian entity on OFAC's SDN List, between January 2012 and October 2015. Despite receiving notice of Naftan's designation in August 2011 and multiple senior managers gaining actual knowledge of the sanctions restrictions by February 2015, the company continued approving the transactions.

From October 2014 to March 2016 Yantai Jereh, an international corporation headquartered in Yantai, China with affiliates and subsidiaries worldwide, exported U.S.-origin goods intended for end users in Iran via intermediary companies in China and the UAE. Nine of the 11 transactions constituting the apparent violations occurred after January 2015, continuing despite a U.S. government investigation.

Aeroflex/Metelics, Inc., a former subsidiary of Cobham Holdings of Arlington, Virginia, sold electronic components including switch limiters and switches through distributors in Canada and Russia to a blocked person between July 2014 and January 2015. The company's denied party screening software failed to identify the blocked entity due to name-matching deficiencies in the search algorithm.

Société Générale S.A., a financial institution headquartered in Paris, processed 1,077 transactions across multiple sanctioned jurisdictions between 2007 and 2012 by removing references to OFAC-sanctioned parties from payment instructions. OFAC found the bank often processed these transactions in a non-transparent manner that removed, omitted, obscured or otherwise failed to include references to OFAC-sanctioned parties; the settlement amount was $53,966,916.05.

JPMorgan Chase Bank, N.A. remitted $5,263,171 to settle potential civil liability for apparent violations involving the processing of 87 net settlement payments, with approximately $1.5 million attributable to sanctions-targeted parties. The bank failed to independently evaluate participating member entities for OFAC sanctions risk between January 2008 and February 2012.

Between August 2011 and April 2014 JPMorgan Chase & Co. processed 85 transactions totalling $46,127.04 and maintained eight accounts on behalf of six customers who were contemporaneously identified on the SDN List. A vendor screening system failed to identify matches due to deficient logic capabilities for names with hyphens, initials or additional middle or last names; OFAC issued a Finding of Violation with no monetary penalty.

Epsilon Electronics, a small business in Montebello, California also doing business as Power Acoustik Electronics, Sound Stream, Kole Audio and Precision Audio, issued 39 invoices for sales to Asra International LLC from August 2008 to May 2012, a company Epsilon knew or had reason to know distributed most if not all of its products to Iran. Following court remand the parties settled, with OFAC weighing aggravating factors including systematic violations and the lack of a prior compliance program against mitigating factors including small business status and cooperation.

Ericsson AB, located in Sweden, signed a letter of intent in September 2011 to provide equipment and services for telecommunications network expansion in Sudan. Between January and April 2012 Ericsson employees structured a multistage transaction to purchase and transship a U.S.-origin satellite hub through Switzerland and Lebanon to Sudan, despite warnings from the company's compliance department.

Between November 2009 and July 2012 subsidiaries of DENTSPLY SIRONA Inc., successor to DENTSPLY International Inc., exported 37 shipments of dental equipment to third-country distributors with knowledge the goods were destined for Iran. Personnel concealed the Iranian destination and continued business with the distributors after receiving confirmation of re-exports to Iran.

Between April 2009 and February 2014 credit cards issued by BCC Corporate SA, owned by Alpha Card Group and ultimately by American Express Company, were used to process 1,818 transactions totalling $583,649.43 for Cuba-related purchases. AMEX voluntarily self-disclosed the violations, and the settlement reflects mitigating factors including swift and appropriate remedial action and no prior penalties.

BD White Birch Investment LLC, headquartered in Greenwich, Connecticut, facilitated the sale and shipment of approximately 544 metric tons of Canadian-origin paper from Canada to Sudan valued at $354,602.26 in April and December 2013. Multiple personnel within the company and its Canadian subsidiary were actively involved in discussing, arranging and executing the export transactions.

Between 5 October 2010 and 21 April 2011 Richemont North America, a luxury goods company headquartered in New York, exported four jewellery shipments to an SDN entity in Hong Kong without identifying sanctions-related issues. The company failed to exercise minimal care despite the recipient's name and address matching those on the SDN List. Note: the enforcement document states a settlement amount of $334,800 while OFAC's year listing records $344,800.

COSL Singapore, an oilfield services company located in Singapore and a subsidiary of China Oilfield Service Limited, exported or attempted to export 55 orders of oil rig supplies from the United States to Singapore and the UAE, then re-exported them to four oil rigs in Iranian territorial waters between October 2011 and February 2013. Although some purchase order quotations included warnings against shipment to sanctioned countries, the company purchased and shipped the goods over several years.

From April 2010 to June 2012 Blue Sky Blue Sea, Inc., doing business as American Export Lines and International Shipping Company (USA), transshipped used and junked cars and parts from the United States via Iran to Afghanistan on 140 occasions. OFAC determined the violations were non-egregious and not voluntarily disclosed, and warranted mitigation based on the company's small business status, first violation eligibility and cooperation with the investigation.

IPSA International Services, a global business investigative and regulatory risk mitigation firm providing due diligence services, imported Iranian-origin background investigation services into the United States on 44 occasions and engaged in transactions related to Iranian-origin services by approving foreign subsidiary payments on 28 occasions. The company settled 72 apparent violations without voluntary disclosure, against a base penalty amount of $720,000.

From June 2012 to March 2013 TransTel, a wholly owned subsidiary of the Singapore-based international technology group CSE Global, originated 104 USD wire transfers totalling over $11 million involving Iran through its bank account, despite having given a written undertaking not to route Iran-related transactions. The funds were processed through the United States to third-party vendors supplying goods for Iranian energy projects, with the transactions deliberately omitting references to Iran or Iranian parties.

Between 14 and 23 May 2014 presidents of ExxonMobil's U.S. subsidiaries ExxonMobil Development Company and ExxonMobil Oil Corp. signed eight legal documents relating to oil and gas projects in Russia with Igor Sechin, an SDN and President of Rosneft OAO. The company violated the sanctions regulations by dealing in services of an individual whose property and interests in property were blocked.

Laws Invoked: Iranian Transactions and Sanctions Regulations 31 C.F.R. part 560; Weapons of Mass Destruction Proliferators Sanctions Regulations 31 C.F.R. part 544; Sudanese Sanctions Regulations 31 C.F.R. part 538; Cuban Assets Control Regulations 31 C.F.R. part 515; 31 C.F.R. part 501. From November 2007 to September 2012 AIG, an international insurance and financial services organisation incorporated in Delaware and headquartered in New York, engaged in 555 transactions totalling approximately $396,530 in premiums and claims for maritime shipment insurance involving Iran, Sudan, Cuba and blocked persons. The violations comprised 455 apparent breaches of the ITSR, 38 of the SSR, 33 of the WMDPSR and 29 of the CACR.

The Canadian subsidiary of American Honda Finance Corporation, a motor vehicle finance company headquartered in California, financed 13 lease agreements with the Cuban Embassy between February 2011 and March 2014, totalling $276,999. AHFC voluntarily disclosed the violations to OFAC and implemented remedial measures including updated OFAC compliance policies.

From January 2010 to March 2016 ZTE, a telecommunications corporation established in the People's Republic of China, engaged in the exportation and re-exportation of U.S.-origin goods to Iran, including items controlled for anti-terrorism and national security purposes. ZTE's highest-level management developed a company-wide plan using third-party entities to conceal the illegal business activities and later surreptitiously resumed Iran operations after publicly claiming to have ceased them.