In 2007, pursuant to this delegated authority, GIM UK purchased approximately $3 million of shares for GEMF in the First Persian Equity Fund (“FPEF”), a Cayman Islands company that invests exclusively in Iranian securities.

The apparent violations consist of two reinsurance claim payments to the Steamship Mutual Underwriting Association Limited (“Steamship Mutual”) for losses arising from vessel operations of the National Iranian Tanker Company in July and August 2005.

On or about January 16, 1999, Gebruder shipped thyroglobulin testing kits from Austria to Iran. These testing kits had been shipped from the United States to Austria on or about January 6, 1999 and were destined for Iran.

On 13 occasions, between on or about May 20, 1998, and on or about March 22, 2000, Lunar Europe N.V. caused the export from the United States to Iran of bone densitometer equipment, without prior authorization from the Office of Foreign Assets Control. GE Medical is the successor to Lunar Europe N.V.

The purpose of the conspiracy was to bring about the export from the United States to Iran, via the United Arab Emirates ("UAE"), of approximately 2,300 computer motherboards, items subject to the Regulations and valued at approximately $130,000, without the required U.S. Government authorization.

On 30 separate occasions, Gateway 2000 exported US-origin computer systems to 16 countries, including Iran, without the valid licenses required.

Between January 2001 and December 2002, GasTech willfully exported its engineering and procurement services to the National Iranian Gas Company for the development of a gas processing plant to be constructed in Iran.

Conspired to illegally export military aircraft components from the US to Iran.

GAC supplied bunker fuel in Paranagua, Brazil for an Iranian vessel carrying an agricultural commodity, which OFAC alleged was a violation of the ITSR.

2002 Exportation of services to Iran.