Zurigo Trading, Inc

In September 2006, Zurigo attempted to export goods valued at $7,168 to Iran on behalf of its foreign customer. OFAC determined that Zurigo did not voluntarily self-disclose the violation to OFAC and that the violation constituted a non-egregious case.

Zulutrade, Inc.

Over a number of years beginning in 2009, Zulutrade maintained accounts for over 400 persons in Iran, Sudan, and Syria, and exported services to these customers by placing FX trades via its platform. Zulutrade also originated eight funds transfers totaling $10,264.36 destined for two individuals located in Iran.

Zimmer Dental, Inc.

The alleged violations occurred between March 2002 and May 2004 and primarily prior to the October 2003 acquisition of Centerpulse Dental Inc. by Zimmer Dental’s parent company. OFAC alleged that goods and services were exported to Iran without an OFAC license.