September saw a number of enforcement actions involving Iran. First, the Office of Foreign Assets Control (OFAC) announced separate settlements with 3M and Emigrant Bank for violations of the Iranian Transactions and Sanctions Regulations (ITSR). In addition, a Virginia man was convicted of violating the International Emergency Economic Powers Act (IEEPA) and ITSR when he sent construction equipment to Iran. And the Department of Justice (DOJ) announced its first criminal resolution involving the illicit sale and transport of Iranian oil.
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