Recent news from Treasury’s Office of Foreign Assets Control: September 21

OFAC took two significant enforcement actions, in addition to making additional Iran-related designations:

  • OFAC Announces Settlement Agreements with 3M Company and Emigrant Bank to Settle Potential Civil Liability for Apparent Sanctions Violations on Iran: OFAC on Sept. 21 announced a $9,618,477 settlement with 3M Company to settle 3M’s potential civil liability for 54 apparent violations of OFAC sanctions on Iran by its subsidiary. The apparent violations arose from a 3M subsidiary’s sale of reflective license plate sheeting to an Iranian entity controlled by the Iranian Law Enforcement Forces. Between September 2016 and September 2018, 3M East AG sold 43 orders of this product to a reseller with knowledge that it was destined for a customer in Iran. One U.S.-person employee of another 3M subsidiary was substantively involved in these sales. OFAC determined that these apparent violations were egregious and were voluntarily self-disclosed. Read more.
  • In a separate announcement, OFAC announced a $31,867.90 settlement with Emigrant Bank to settle its potential civil liability for apparent violations of sanctions against Iran. According to OFAC, Emigrant, for 26 years, maintained a Certificate of Deposit account on behalf of two Iranian individuals, for which it processed 30 transactions between June 2017 and March 2021 totaling $91,051.13 before the location of the accountholder was flagged by the bank’s screening filter. The bank had actual knowledge of the Iranian address and apparent location of the accountholders during this period. The settlement amount reflects OFAC’s determination that Emigrant’s conduct was non-egregious and voluntarily self-disclosed. Read more.

Iran-related Sanctions

  • OFAC Sanctions Network Supporting Iran’s UAV and Military Aircraft Production: OFAC on Sept. 19 sanctioned seven individuals and four entities based in Iran, the People’s Republic of China, Russia, and Türkiye in connection with Iran’s unmanned aerial vehicle (UAV) and military aircraft development. This designated network has facilitated shipments and financial transactions in support of the U.S.-designated Iran Aircraft Manufacturing Industrial Company’s (HESA’s) UAV and military aircraft production, procurement, and maintenance activities. Related to this action, OFAC is updating HESA’s entry on the Specially Designated Nationals and Blocked Persons List to include its new alias (Shahin Co.) which it has used to evade sanctions and export control measures. Read more. See identifying information on the designees.

Specially Designated Nationals List Update

  • OFAC Updates Specially Designated Nationals List and Blocked Persons: OFAC on Sept. 25 consolidated and re-listed one entity on its Specially Designated Nationals list, designated pursuant to its Russian Harmful Foreign Activities program, and removed one entity designated pursuant to its Burma programs. For the Russian Harmful Foreign Activities program designated entity, OFAC clarified it was subject to secondary sanctions, included a new website, and linked it to an entity designated under other significant programs. OFAC also changed or corrected identifying information for five entities listed pursuant to the Russian Harmful Foreign Activities program. Read more.
  • In the same announcement, OFAC included a reminder that as of Sept. 25, 2023 OFAC has retired its legacy .PIP, .DEL, and SDALL.ZIP file formats. For more information on this action, please see OFAC’s Aug. 15, 2023 recent actions announcement.