OFAC alleged that Key Bank acted without an OFAC license or outside the scope of its license by operating accounts for an entity and a person located in Iran.

Since August 2006, Keshari allegedly procured US-made military aircraft parts for buyers in Iran and illegally shipped the parts to a company in Dubai, UAE for shipment to buyers in Iran.

Conspired to ship U.S. communications technology to Iran.

2002 Funds transfers

Between approximately January 3, 2008 and February 8, 2012, JPMC processed 87 transactions through the U.S. financial system that may have contained interests attributable to a sanctions-targeted party, including Iran.

An apparent violation of the ITR consisting of a May 24, 2006 transfer of 32,000 ounces of gold bullion valued at approximately $20,560,000 to the benefit of a bank in Iran. JPMC did not voluntarily self-disclose this matter to OFAC.

2000-2002 Funds transfers & letter of credit

OFAC alleged that the apparent violations occurred as a result of 69 fund transfers in 2008 and 2009 totaling more than $41 million for or on behalf of Bank Melli Iran ZAO, Moscow, Russia (“BMI Russia”), a Russian affiliate of Iran’s Bank Melli designated as a WMD proliferator under Executive Order 13382.

The Chicago corporation appeared to have violated regulations when goods they sold to a Chinese company were shipped by the Islamic Republic of Iran Shipping Lines (IRISL) aboard a blocked vessel from Spain to China in 2009.

The apparent violations involve, on 44 separate occasions, IPSA’s importation of Iranian-origin services into the United States.