The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on Monday (19 July) announced settlement agreements totalling USD 432,570 with Alfa Laval Middle East Ltd. (AL Middle East) and Alfa Laval Inc. (AL U.S.) over potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR).
A USD 415,695 settlement was reached with Dubai-located AL Middle East for apparent violations committed between May 2015 and March 2016 when AL Middle East conspired with Dubai- and Iran-based companies to export Gamajet brand storage tank cleaning units from the United States to Iran.
As a result of this conspiracy, AL Middle East 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 that would have employed the same scheme. OFAC determined that AL Middle East did not voluntarily self-disclose the apparent violations, and that the apparent violations constitute an egregious case.
Separately, OFAC announced a $16,875 settlement with Richmond-based AL U.S. for apparent violations of the ITSR on behalf of its former subsidiary (now an operating unit) Alfa Laval Tank, Inc. (AL Tank), located in Exton, Pennsylvania.
Specifically, the apparent violations were committed between May 2015 and March 2016 when AL Tank, which 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 AL Tank to export its Gamajet brand cleaning units to Iran. OFAC determined that AL U.S. did not voluntarily self-disclose the apparent violations, and that the apparent violations constitute a non-egregious case.
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