Enforcement Release: Unicat Catalyst Technologies, LLC

Date issued: Jun. 16 2025

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TURBOFAC Commentary (472 words)

Notes Common to Enforcement Release: Unicat Catalyst Technologies, LLC, Settlement Agreement (OFAC) - Unicat Catalyst Technologies, Inc and Plea Agreement Statement of Facts (DOJ) - Unicat Catalyst Technologies, Inc

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)). ...