Firm Agrees To Pay OFAC Six-Figure Settlement of Iran Sanctions Violations
HyperBranch Medical Technology agreed to pay $107,691 as part of a settlement with the Office of Foreign Assets Control, after HyperBranch allegedly exported thousands of units of sealant to a United Arab Emirates distributor, either knowing or having “reason to…
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know” the goods were headed to Iran, which would violate Iran Sanctions Regulations, OFAC said (here). HyperBranch in 2011 allegedly sent 4,000 units of sealant and 80 samples to its UAE distributor, OFAC said. The company, however, voluntarily self-disclosed the apparent violations, which constitute a “non-egregious” case, OFAC determined. HyperBranch is paying $51,851 less than the statutory minimum for the alleged penalties. Among other things, OFAC considered as mitigating factors the high likelihood the medical end-use products were eligible for a specific license, translating to minimal harm to U.S. sanctions program objectives; and the lack of prior HyperBranch OFAC sanctions history.