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A natural U.S. person (“U.S. Person-1”) has agreed to pay $1,427,230 to settle their potential civil liability for 39 apparent violations of OFAC sanctions on Iran. Between June 26, 2019 and July 7, 2021, U.S. Person-1 provided management consulting and advisory services to one of Iran’s leading software solutions companies, received Iranian-origin dividends to their U.S. bank accounts, and acquired real property in Iran. The settlement amount reflects OFAC’s determination that the apparent violations were not voluntarily self-disclosed and were egregious. OFAC’s investigation and resolution of this matter was in cooperation with the Federal Bureau of Investigation, Los Angeles Field Office, Orange County Resident Agency.
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