OFAC alleged that Datex-Ohmeda’s former division, Spacelabs Medical, disregarding licensing requirements, exported medical devices from the United States through an entity in Dubai, U.A.E. to Iran or the Government of Iran without authorization between 2000 and 2003.

Between October 2001 and April 2002, DataMirror acted without an OFAC license or outside the scope of its license by exporting software to Iran, Cuba and a territory of Afghanistan controlled by the Taliban.

Between January and June 2004, Data Systems exported consumable office equipment to Iran without an OFAC license, and in June 2006, it attempted to export additional goods to Iran, again without an OFAC license.

Under its prior ownership and management, Dal-Tech, a distributor of microwave radiofrequency devices, made unlicensed sale and export of radio frequency measurement devices (“RF devices”) to Austria with knowledge that the items were intended for transshipment to Iran.

Sold Iran valves that turn gas and oil pipelines on and off without a license.

From on or about June 4, 2012, to on or about March 27, 2013, TransTel caused at least six separate financial institutions to engage in the unauthorized exportation or re-exportation of financial services from the United States to Iran.

Illegal export and attempted illegal export of cryogenic submersible pumps to Iran without a license.

On ten occasions between on or about March 22, 1999, and on or about August 15, 2002, Criticare engaged in conduct prohibited by the Regulations by exporting medical equipment subject to the Regulations and the Iranian Transaction Regulations from the United States through the United Kingdom to Iran without the required U.S. Government authorization.

Credit Suisse had standard procedures for using cover payments to avoid referencing parties subject to U.S. sanctions and omitting information, removing information, or providing incorrect information in payment messages in order to conceal the identities of U.S.

For a number of years, up to and including 2008, CA-CIB and certain of its predecessor banks, and CA-CIB’s subsidiary located in Switzerland, Crédit Agricole (Suisse) S.A. (“CAS”), and its predecessors — including Crédit Lyonnais (Suisse) S.A. (“CLS”) and Crédit Agricole Indosuez (Suisse) S.A. (“CAIS”) — processed thousands of transactions to or through U.S. financial institutions that involved countries and/or persons (individuals and entities) subject to the sanctions regulations administered by OFAC, including Iran.