Liu “Willow” Yang, a Chinese national located in China, began procuring electronic components for an Iranian she met while she was employed as a sales representative of a Chinese digital audio player company. The Iranian approached Yang while at a meeting in China, and requested if she could obtain electronic components for him from the U.S. as a side business. Yang agreed to obtain the products for a small commission. Yang registered her business in Hong Kong in 2009 to avoid scrutiny from U.S. suppliers, and began

On March 11, 2020, Nordic Maritime Pte. Ltd. (Nordic), and its Chairman, Morten Innhaug (Innhaug), were found to have committed four violations of the EAR for their respective roles in the illegal reexport of controlled undersea surveying equipment to Iran for use in surveying an Iranian oil field.

On November 1, 2019, Beng Sun Koh, also known as Michael Koh, pled guilty in U.S. District Court for the District of Columbia in connection with the illegal transshipment of U.S.-origin commodities to Iran via Singapore. Koh, Owner and Director of Anh Minh Cuong Co. Ltd. in Singapore, was directed to use his company to acquire U.S.-origin as chromatograph mass spectrometers and electron capture detectors classified under ECCN 3A999 on behalf of an Iranian national and his Tehran, Iran based company. Koh purchased the requested items from a U.S.

SAP SE (“SAP”), a software company headquartered in Walldorf, Germany that provides enterprise application software, cloud-based services, and associated maintenance and support, has agreed to pay $2,132,174 to settle its potential civil liability for 190 apparent violations involving the export of software and related services from the United States to Iran.

Alliance Steel, Inc. has agreed to pay $435,003 to settle its potential civil liability for 61 apparent violations of OFAC regulations related to its importation of engineering services from an Iranian engineering company.

From on or about July 16, 2013 to on or about March 25, 2017, UniControl appears to have exported to two European companies 21 shipments of air pressure switches, valued at $687,189, that were subsequently reexported to Iran. UniControl, Inc. (“UniControl”), a Cleveland, Ohio-based entity that manufactures process controls, airflow pressure switches, boiler controls, and other instrumentation, has agreed to pay $216,464 to settle its potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR).

Colin Fisher, 45, was sentenced in Pensacola federal court. He pleaded guilty in September to violating the International Emergency Economic Powers Act and to attempted smuggling in relation to exporting power generating equipment to Iran, according to court records. Fisher, a U.K. citizen was sentenced to two years and six months in federal prison for violating am embargo and attempting to smuggle industrial equipment to Iran.

In April 2023, DES International Co., Ltd., a business organization based in Taiwan, and Soltech Industry Co., Ltd., based in Brunei, pleaded guilty in the U.S. District Court for the District of Columbia to participating in a criminal conspiracy to violate U.S. export laws and sanctions by sending U.S.-origin goods to Iran. The companies were involved in procuring goods for Iranian government entities, including a power amplifier and cybersecurity software, without the required licenses from the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC).

"Whitford Worldwide Company, LLC (“Whitford”), a cookware coating manufacturer based in Elverson, Pennsylvania, has agreed to pay $824,314 to settle its potential civil liability for its foreign subsidiaries’ sales to Iran. Whitford’s foreign subsidiaries continued to sell coatings to Iran despite changes to OFAC’s Iran sanctions program that prohibited such transactions. Additionally, U.S.-person employees of Whitford oversaw and provided instructions relating to some of these sales.

"Keysight Technologies, Inc. (“Keysight”), a company based in Santa Rosa, California, on behalf of its former Finnish subsidiary, Anite Finland Oy (“Anite”), has agreed to pay $473,157 to settle its potential civil liability for reexports of U.S. export-controlled test measurement equipment to Iran. Anite had business with Iran prior to its acquisition by Keysight in August 2015. After Keysight’s acquisition of Anite, and after Keysight implemented its policy to restrict sales to Iran, Anite employees nonetheless continued sales to Iran and obfuscated such sales from Keysight.