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Enforcement Release: June 16, 2025
Unicat Catalyst Technologies, LLC Settles with OFAC for $3,882,797 Related to Apparent Violations of Iran and Venezuela Sanctions
Unicat Catalyst Technologies, LLC, as successor to Unicat Catalyst Technologies, Inc., and its subsidiaries, assignees, successors, and affiliates worldwide (collectively, “Unicat” or “the Company”), has agreed to pay $3,882,797 to settle its potential civil liability relating to U.S. sanctions on Iran and Venezuela. Unicat is a Texas-based company that sells and consults on catalyst products used in petrochemical refinery and steel mill operations. Between 2016 and 2021, Unicat’s former chief executive officer and co-founder (the “Former CEO”) and former employees and representatives supplied catalyst products and consulting services to customers in Iran and sold goods to a blocked Venezuelan entity. The settlement amount reflects the Office of Foreign Assets Control’s (OFAC) determination that Unicat’s conduct, through its Former CEO and former employees and...
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1) From a legal basis perspective, the Iran portion of this case is a straightforward example of wilfull indirect exportation of goods and services to Iran (560.204). There are also straightforward "facilitation" violations (560.208) with respect to "the sale of catalyst products through its majority-owned Dutch affiliate to Iran." Note that those Netherlands to Iran sales were, separately, violations of 560.215 for which the parent company woudl be directly liable, but OFAC chose to charge them as direct violations by the parent company, rather than violations by the subsidiary subject to 560.215 that the parent would have been liable for by operation of law (560.701(a)(4)). ...