Keysight Technologies, Inc. (“Keysight”), a company based in Santa Rosa, California, on behalf of its former Finnish subsidiary, Anite Finland Oy (“Anite”), has agreed to pay $473,157 to settle its potential civil liability for reexports of U.S. export-controlled test measurement equipment to Iran. Anite had business with Iran prior to its acquisition by Keysight in August 2015. After Keysight’s acquisition of Anite, and after Keysight implemented its policy to restrict sales to Iran, Anite employees nonetheless continued sales to Iran and obfuscated such sales from Keysight. Keysight and Anite subsequently implemented remedial measures intended to prevent future unauthorized sales.
Description of the Apparent Violations and the Conduct Leading to the Apparent Violations
From on or about January 2016 to on or about June 2016, Anite appears to have violated § 560.205 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), when it completed six orders, without OFAC authorization, valued at $331,089, of goods that incorporated 10 percent or more of U.S.-export controlled content exported from the United States that was subject to U.S. licensing requirements for export or reexport to Iran under the Export Administration Regulations, 15 C.F.R. §§ 730-774, with knowledge that such goods were destined for end-users in Iran (collectively referred to hereafter as the “Apparent Violations”). Although foreign entities owned or controlled by U.S. persons were authorized to engage in certain transactions with Iran pursuant to General License H of the ITSR between January 16, 2016, and June 27, 2018, the general license did not authorize reexportation from a third country of any goods, technology, or services prohibited by § 560.205 of the ITSR.