Construction Specialties Inc. (“CS”), a company headquartered in New Jersey that sells specialized building materials, has agreed to pay $660,594 to settle its subsidiary’s potential civil liability for three apparent violations of OFAC sanctions on Iran. The conduct at issue occurred when CS’s wholly controlled United Arab Emirates (UAE) subsidiary, Construction Specialties Middle East L.L.C. (“CSME”), imported building materials from the United States to the UAE and then knowingly reexported them to Iran. In doing so, CSME’s general manager and another senior manager disregarded CS company policy and falsified trade documents. The settlement amount reflects OFAC’s determination that CSME’s apparent violations were egregious and voluntarily self-disclosed.

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