Between 1996 and 2000, Downey operated 23 accounts for 20 account holders who informed Downey of their permanent residence in Iran.

On or about May 24, 2001, and August 10, 2001, Dosmatic exported or caused the export of four liquid injectors and 120 liquid injectors, respectively, items subject to the Regulations and to the Iranian Transaction Regulations, from the United States to Iran without prior authorization from the Office of Foreign Assets Control.

DMRI executed a binding Memorandum of Understanding with NITC, which OFAC determined was a contingent contract and therefore property in which NITC, a blocked person, had an interest.

2001 Funds transfers

Diversified exported a service in the form of booth space booking arrangements at an annual European seafood exposition to an entity located in Iran.

Between 2001 and 2004, DI U.K.’s Skelmersdale, United Kingdom facility specially ordered from a U.S. company various oil industry related items, which were subject to the Regulations and to the Iranian Transactions Regulations,’ and which were exported by the U.S. company through the United Kingdom to Iran without the required U.S. Government authorization.

2002 - 2003 Exportation of services to Iran.

Specifically, between on or about November 26, 2009, and July 5, 2012, DII subsidiaries UK International (“UKI”) and DS Healthcare Inc. (d.b.a. Sultan Healthcare) (“Sultan”), exported 37 shipments of dental equipment and supplies from the United States, to distributors in third-countries, with knowledge or reason to know that the goods were ultimately destined for Iran.

On three separate occasions from March 1992 through June 1992, Dell shipped U.S. origin computer equipment from the U.S. to Iran without first obtaining the required license.

From June 13, 2010, until October 12, 2011, Baghdasarian served as manager of Delfin Group USA, a Russian-owned producer of synthetic motor oils, located in South Carolina, where he engaged in prohibited transactions with customers in Iran, including Paris Oil. He exported to Iran aviation engine oils and polymers.