OFAC has fined HyperBranch Medical Technology Inc., a US medical goods company, $107,691.30 for apparent violations of US sanctions on Iran. HyperBranch is said to have exported thousands of units of medical goods to its distributor in the UAE, with knowledge or reason to know that the goods were ultimately destined for Iran.
In its enforcement notice, OFAC said that HyperBranch voluntarily disclosed the violations and that they did not constitute an egregious case. OFAC found the conduct to have been aggravated by the fact that HyperBranch’s former CEO and International Sales Manager knew the ultimate destination of the exports, and that it did not have a sanctions compliance program in place. In mitigation, OFAC noted that the harm caused to US sanctions objectives by the violations was limited because the exports involved medical end-use products that were likely eligible for a specific licence.