The violation was egregious and not voluntarily disclosed.
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) today announced that a Berlin, Germany-headquartered company has agreed to pay over $14.5 million to settle potential civil liability for an apparent violation of the Iranian Transactions and Sanctions Regulations. The company allegedly conspired to facilitate the indirect sale and supply of a polypropylene plant to Iran through a U.S. company between 2015 and 2019, using U.S. financial institutions for payments.
According to today’s OFAC enforcement release, the case involves the company's agreement with a U.S. company to purchase a decommissioned polypropylene plant in Australia, with a stipulation against resale to sanctioned destinations. Despite this, the company allegedly conspired with its Iranian subsidiary and an Iranian company to redirect the plant to Iran, falsifying documents and misrepresenting the plant's destination as Türkiye.
OFAC determined the violation was egregious and not voluntarily disclosed, leading to a settlement that includes a suspended portion contingent on the company's compliance improvements.