Microsoft Corporation has agreed to pay $2,980,265.86 to settle potential civil liability for 30 apparent violations of U.S. sanctions on Iran between July 2012 and April 2019. These violations involved the sale, activation, and provision of software and related services from Microsoft’s U.S.-based systems to Iranian entities. Microsoft failed to screen and identify Iranian end users, allowing them to access software through third-party distributors and resellers.

Uphold HQ Inc., a California-based money services business, has agreed to pay $72,230.32 to settle its potential civil liability for 152 apparent violations of U.S. sanctions against Iran, Cuba, and Venezuela between March 2017 and May 2022. The violations included processing transactions for customers who self-identified as being located in Iran or Cuba and for employees of the Venezuelan government. Uphold failed to screen customer-provided free-text address fields and identification documents, allowing users from sanctioned jurisdictions to access financial services.

American Life Insurance Company (ALICO), a Delaware-based subsidiary of MetLife, Inc., has agreed to pay $178,421 to settle its potential civil liability for violating U.S. sanctions on Iran. Between February 2022 and August 2023, ALICO issued group medical and life insurance policies and processed 2,331 premiums and claims totaling $446,077 for UAE-based schools and entities owned or controlled by the Government of Iran (GOI).

Aiotec GmbH, a Berlin-based industrial equipment sourcing company, has agreed to pay $14.55 million to settle its potential civil liability for violating U.S. sanctions on Iran. Between 2015 and 2019, Aiotec conspired to purchase a decommissioned polypropylene plant in Australia from a U.S. company and then illegally reexport it to Iran through false documentation and deception. Aiotec misrepresented to the U.S.

C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle potential civil liability for 82 apparent violations of U.S. sanctions on Iran and Cuba. Between November 2018 and February 2022, five of CHR’s non-U.S.

Córdoba Music Group LLC, a California-based musical instrument manufacturer, has agreed to pay $41,591 to settle its potential civil liability for apparent violations of U.S. sanctions on Iran. Between November 2019 and March 2022, Córdoba knowingly shipped musical instruments and accessories valued at $118,831 to an Iranian distributor via a Dubai-based intermediary, in violation of the Iranian Transactions and Sanctions Regulations (ITSR). The company failed to recognize that indirect exports to Iran were prohibited under U.S.

Michael Sheehan, operating as Real-Time Industrial Solutions in Ohio, was charged in 2018 for submitting false or misleading information to the Automated Export System (AES) and providing false information to an Office of Export Enforcement (OEE) Special Agent. Sheehan played a key role in a conspiracy to illegally export U.S.-origin industrial goods to Iran by procuring items for IC Link Industries Ltd., a front company established by Iranian national Mohammad Khazrai Shaneivar. To evade U.S.

A federal jury convicted Jalal Hajavi of Sterling, Virginia in September 2023 of conspiring to violate the IEEPA and the ITSR, smuggling goods from the United States, unlawfully exporting and reexporting goods from the U.S. to Iran without a license. Hajavi, through his company JSH Heavy Equipment, LLC, conspired with an individual in Iran to export U.S. heavy machinery indirectly to Iran without first obtaining the required licenses from OFAC.