A U.S.-based building materials company agreed to settle with the U.S. Treasury Department ("Treasury") Office of Foreign Assets Control ("OFAC") charges stemming from five alleged transactions that violated the Iranian Transactions and Sanctions Regulations.
According to OFAC, between July 2014 and January 2015, ZAG IP, LLC ("ZAG") knowingly purchased a total of 263,563 metric tons of "Iranian-origin clinker" from a company in the United Arab Emirates. OFAC said that ZAG then resold and transported the clinker to a company located in Tanzania. The total value of the transactions was over $14 million.
ZAG voluntarily disclosed the apparent violations to OFAC, and OFAC determined that the case was "non-egregious." To settle the charges, ZAG agreed to pay $506,250. In its settlement notice, OFAC highlighted that the enforcement action demonstrates the importance of risk-based compliance measures, especially for companies in high-risk industries that are exposed to "jurisdictions or persons implicated by U.S. sanctions."
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