OFAC determined that from on or about 2002 to on or about 2009, NOV engaged in certain conduct in apparent violation of the ITSR. Specifically: (1) between October 2002 and April 2005, National Oilwell Varco, Inc. approved at least four Dreco commission payments to a U.K.- based entity that related to the sale and exportation of goods, directly or indirectly, from Dreco to Iran, in apparent violation of the ITSR (these four commission payments have a combined value of $2,630,091); (2) between September 2006 and January 2008, National Oilwell Varco, Inc.

Between March 2005 and May 2007. OFAC alleged that NMCI outsourced to an Iranian entity inspection services it was contractually bound to perform for a third-party, without an OFAC license.

Occurring between January and March 2000, Suretrade acted without an OFAC license or outside the scope of its license by operating an account for a person located in Iran.

1999 maintenance of Iranian account

In 2011, MGN manager attempted to export protein supplements through the UAE to Iran.

Exported controlled US aircraft parts from the US to Monarch in Singapore and Malaysia and then re-exported those items to companies in Tehran, Iran without obtaining the required US government licenses.

Conspired to obtain and illegally export to Iran U.S.-origin materials used to construct, operate and maintain gas centrifuges to enrich uranium and other nuclear-related goods.

Conspired to export restricted goods and technology to Iran.

Conspired to violate IEEPA and U.S. sanctions against Iran by exporting a gyroscope to Iran

From 2008 through his arrest in 2012, Qiang (Johnson) Hu, a sales manager at MKS Shanghai, conspired with co-workers and others to illegally supply thousands of export-controlled pressure transducers, worth more than $6.5 million, to unauthorized end-users in China, Iran and elsewhere using export licenses fraudulently obtained from the Department of Commerce.