Dentsply Sirona Inc, a US company specialising in dental solutions, has agreed to pay OFAC $1,220,400 to settle allegations that it committed 37 violations of the Iranian Transactions and Sanctions Regulations. In particular, that, between November 2009 and July 2012, indirect subsidiaries of Dentsply Sirona Inc had exported 37 shipments of dental equipment and supplies from the US, to distributors in third-countries, with knowledge or reason to know that the goods were ultimately destined for Iran. OFAC determined that the case was not voluntarily disclosed and that the violations had constituted a non-egregious case. Click here for the OFAC enforcement information.
Reza Zarrab, a Turkish-Iranian businessman, has pleaded guilty in a New York court to conspiracy to violating US sanctions against Iran. Mr. Zarrab gave evidence of a money-laundering network between 2010 to 2015, facilitated by a Turkish state bank, which allowed Iran to gain access to international markets, in contravention of US sanctions. He gave evidence against a co-defendant (Mehmet Hakan Atilla, a banker at the Turkish bank), and gave details of bribes paid to Turkish government officials (over $50m) as part of the scheme.
In particular, OFAC determined that on 4 July 2015, DMRI had violated the Regulations by having “[dealt] in the property or interests in property of the National Iranian Tanker Company (NITC), an entity identified by OFAC as meeting the definition of the Government of Iran and whose property and interests in property [were] blocked”. Specifically, DMRI had executed a binding Memorandum of Understanding with NITC, which OFAC determined to have been a contingent contract and, therefore, property in which NITC, a blocked person, had had an interest.
As previously reported, the Court of Appeal held in October 2015 that the principles relating to the disclosure of closed material in the context of control orders, as set out in the House of Lords judgment in AF (No. 3), also applied to disclosure in the context of applications to set aside a financial restrictions decision, see: Bank Mellat v HM Treasury (No 4)  EWCA Civ 1052, and remitted the case to the Administrative Court to consider whether there had been sufficient disclosure by HM Treasury in Bank Mellat’s action to set aside financial restrictions affecting it.
The Administrative Court has just decided, in a closed judgment, that some material may be withheld and other disclosed. The open judgment (Bank Mellat v HM Treasury  EWHC 2931 (Admin)) sets out the relevant principles applied in the closed judgment.
OFAC has added two individuals (Reza Heidari and Mahmoud Seif) and four entities (ForEnt Technik GmbH, Pardazesh Tasvir Raya Co, Printing Trade Center GmbH and Tejarat Almas Mobin Holding) to its SDN list.
The individuals and entities have been designated for being part of a “network… involved in a large-scale scheme to help Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) counterfeit currency to support its destabilizing activities”. In particular, the network is stated to have “employed deceptive measures to circumvent European export control restrictions and [to have] procured advanced equipment and materials to print counterfeit Yemeni bank notes potentially worth hundreds of millions of dollars for the IRGC-QF”.
In light of the recent earthquake in Iran (12 November 2017), the US Office of Foreign Assets Control (OFAC) has published an FAQ highlighting some of the ways in which Americans can provide humanitarian assistance to the Iranian people, consistent with the Iran-related sanctions administered by OFAC.
The Iran Ballistic Missiles and International Sanctions Enforcement Act, which expands sanctions on Iran with respect to ballistic missiles, has been passed in the US House of Representatives by a 423-2 vote. We previously reported here that the House was due to vote on the Bill.
The passing of the Bill comes two weeks after US President Trump announced his decision not to certify the Iran nuclear deal (JCPOA), having criticised Iran for its ballistic missile programme (see previous blog here).
The next stage in the Bill’s legislative process is for the US Senate to vote on it.