Enforcement Release: September 10, 2026
An Individual Settles with OFAC for $1,427,230
Related to Apparent Violations of Iran-related Sanctions Regulations
A natural U.S. person (“U.S. Person-1”) has agreed to pay $1,427,230 to settle their potential civil liability for 39 apparent violations of OFAC sanctions on Iran. Between June 26, 2019 and July 7, 2021, U.S. Person-1 provided management consulting and advisory services to one of Iran’s leading software solutions companies, received Iranian-origin dividends to their U.S. bank accounts, and acquired real property in Iran. The settlement amount reflects OFAC’s determination that the apparent violations were not voluntarily self-disclosed and were egregious. OFAC’s investigation and resolution of this matter was in cooperation with the Federal Bureau of Investigation, Los Angeles Field Office, Orange County Resident Agency.
Description of the Apparent Violations
In 1987, while living in Iran, U.S. Person-1 co-founded Iranian Company-1, an Iranian...
1) Compare Enforcement Release - An Unnamed Individual (19) (“U.S. Person-1 executed a plan to purchase, renovate, and operate a hotel in Iran. In furtherance of this scheme, U.S. Person-1 used foreign money services businesses in Iran and Canada to evade U.S. sanctions”). This is a similar significant civil penalty against an individual for ITSR violation, though on the basis of different facts.
2) As it relates to the “management consulting and advisory services” (violation of 560.204), this is a rare example of “meetings” being prohibited, albeit in the specific context of the USP having “provided substantive advice, analysis, and information.” Contrast Internal OFAC Correspondence re: Informal Guidance Provided to the State Dep't on Scope of Blocking Prohibitions (meetings not...