According to a settlement with the US Treasury signed August 21, 2020, "From approximately December 2012 to Janumy 2016, Iscm Turkey [a Turkish subsidiary] appears to have violated§ 560.215 of the ITSR when it engaged in al least 144 transactions involving Iran valued at $383,443 that would have been prohibited by§§ 560.203, 560.204, 560.206, and 560.208 of the ITSR if engaged in by a U.S. person (the "Apparent Violations"). The Apprent Violations constitute an egregious case and were voluntarily self-disclosed.
[Berkshire Hathaway aggreed to] pay or arrange for the payment to the U.S. Department of the Treasury the amount of $4,144,651."
"Berkshire Hathaway Inc. has agreed to pay roughly $4.1 million to settle allegations that a Turkish subsidiary violated U.S. sanctions on Iran. The U.S. Treasury Department on Tuesday alleged that Berkshire’s indirect subsidiary—Iscar Kesici Takim Ticareti ve Imalati Limited Sirket—sold cutting tools and related inserts to two third-party Turkish distributors between 2012 and 2016, knowing that the goods would be shipped to a distributor in Iran for resale to end-users there." (Wall Street Journal, "Berkshire To Pay $4.1 Million To Settle Allegations Of Violating U.S. Sanctions On Iran," 10/21/2020).
According to its Quarterly report filed with the SEC for fiscal year 2016: "We are making the following disclosures under Section 13(r) of the Exchange Act because our management recently became aware that one of our foreign subsidiaries made sales through a third-party distributor to customers in Iran that include or may include parties (the "Iran Parties") that meet the definition of the "Government of Iran" under Section 560.304 of 31 C.F.R. Part 560. Based upon currently known information, total revenues to our subsidiary from sales to the Iran Parties, which took place from June 2013 through November 2015, were approximately $45,000, and the total net income attributable to those sales was approximately $2,500.
Our subsidiary has stopped all shipments to the Iran Parties, and the subsidiary does not intend to continue sales to, or engage in other dealings with, the Iran Parties. On May 6, 2016, we submitted initial notifications of voluntary self-disclosures to the U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC"), and the U.S. Department of Commerce, Bureau of Industry and Security ("BIS"). We will submit further information to OFAC and BIS after completing an internal investigation, which we are conducting with the assistance of outside counsel, and we intend to cooperate fully with both agencies."
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