Enforcement Release - UniControl, Inc

Date issued: Mar. 15 2021

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TURBOFAC Commentary (982 words)

Notes:

1) Notable Application of the “Reason to Know” Standard

560.204(a) of the ITSR prohibits the exportation of goods from the U.S. to non-sanctioned third country persons when the U.S. person knows or has a “reason to know” that “Such goods, technology, or services are intended specifically for supply, transshipment, or reexportation, directly or indirectly, to Iran…”

This enforcement action is notable not so much for the theory of liability, which has been well established, but instead for the “warning signs” that, per OFAC, were sufficient to establish a “reason to know” of the ultimate destination of the items shipped at the time they were shipped from the U.S. This may be the most notable application of the “reason to know” standard since the publication of the 2002