Brassler USA

OFAC alleged that on or about February 24, 2006, January 21, 2009, and March 20, 2009, Brasseler exported goods or services to a person in a third country with knowledge or reason to know that such goods or services were intended specifically for transshipment to Iran, without authorization from OFAC.

BNP Paribas SA (BNPP)

For a number of years, up to and including 2012, BNPP processed thousands of transactions to or through U.S. financial institutions that involved countries, entities, and/or individuals subject to the sanctions programs listed above, including Iran.

BMO Harris Bank NA

Between February 3, 2011, and March 10, 2011, M&I Bank originated six funds transfers totaling $67,357 on behalf of its customer, a company specializing in carpets that included the word “Persian” in its name (the “Company”), for the purpose of paying an outstanding balance owed to an Iranian entity located in Iran for the purchase of Iranian-origin carpets.

Blue Robin, Inc.

From on or about January 14, 2009, to on or about July 19, 2010, Blue Robin violated the ITSR when it conducted 33 transactions in which it imported Web development services valued at $205,650 from an Iranian company called PersiaBME. PersiaBME worked collaboratively with Blue Robin’s computer engineers via a private Internet portal provided by Blue Robin to develop Web-based systems and applications that were used to automate online business processes and operations for Blue Robin’s customers.