On 15 occasions on or about May 27, 1998, and on or about May 6, 2002, Bio Check exported items subject to the Regulations to Iran without filing a Shipper’s Export Declaration as required by Section 758 of the Regulations.

2002 Trade with Iran

2001 Exportation of goods to Iran.

Exported aircraft parts, mainly seats, from PTC Aerospace to France for installation in Iran Air Aircrafts without obtaining the required license.

OFAC alleged that Barwil engaged in transactions in or related to services of Iranian origin and facilitated trade-related transactions by non-U.S. persons which involved the payment of port expenses for a vessel’s port call in the Iranian port of Bandar Mahshahr, without an OFAC license.

From August 2009 to April 2012, Barracuda U.K. sold Web filtering products including products that could be used to block or censor Internet activity; internet security products; and related software subscriptions to individuals and entities in Iran and Sudan, and to Specially Designated Nationals and Blocked Persons (“SDNs”) under the Syrian Regulations. Also, from August 2009 to May 2012, Barracuda U.S. provided the firmware and software updates for these and other software subscriptions

Barclays’ apparent violations arose out of practices designed to circumvent filters at U.S. banks installed to detect transactions in violation of OFAC regulations, including Iran sanctions.

1998-2000 Operation of Iranian accounts.

2002 Funds transfer.

2002 - 2003 Funds transfers.