Key Points
On August 16, 2023, OFAC announced a $660,594 settlement with Construction Specialties Inc. (CS) for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). OFAC found that CS’s wholly controlled United Arab Emirates (UAE) subsidiary, Construction Specialties Middle East (CSME), knowingly reexported U.S. goods to Iran. In doing so, CSME’s general manager and another senior manager disregarded CS company policy and falsified trade documents.
OFAC noted that the alleged scheme was uncovered by a U.S. person employed at CSME in Dubai, despite CSME’s senior managers’ efforts to conceal the activities. The U.S. person was suspicious of CSME senior managers’ conduct and confronted CSME’s GM about the issue, only to be terminated by the GM. The same day, the U.S. person employee traveled to the United States and reported their suspicions to CS management. CS initiated an internal review, terminated all Iran related business activity of CSME, and...
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