Enforcement Release: Adani Enterprises Limited

Date issued: May. 18 2026

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TURBOFAC Commentary (294 words)

Notes:

1) From a legal basis standpoint, this is a fairly straightforward enforcement action. Non-U.S. person “causes” violations by originating payments in USD where such payments would be prohibited for U.S. persons to process, here because they related to “Iranian-origin goods” within the meaning of 560.306 of the ITSR, thereby implicating section 560.206(a) of the ITSR. Compare e.g. Enforcement Release: SCG Plastics Co., Ltd.. Two notable things about the enforcement release are (i) the penalty amount vis-à-vis the value of the wires processed (unusually high), and (ii) the due diligence expectations conveyed through the Enforcement Release and Settlement Agreement as it relates to “reason to know” in the context of product origin where many of the ordinary diligence boxes can be checked but a combination of unusually low price and other...