The apparent violations involve, on 44 separate occasions, IPSA’s importation of Iranian-origin services into the United States.

1995 - 2000 Exportation of services to Iran and Cuba

OFAC alleged that IGF attempted to import goods of Iranian origin on or about October 10, 2003, without an OFAC license.

Attempted to ship computer goods through Germany to Iran.

2001 - 2003 Exportation of services to Iran.

Intensa had conducted business with an Italian firm, Irasco, that was found to be Iranian owned. The fine was particularly harsh because Intesa was found to have failed to maintain a sufficiently robust compliance program over the time the apparent violations took place.

Exported $2.3 million in parts for petrochemical products to oil companies owned on behalf of the Government of Iran.

Conspired to violate U.S. sanctions on Iran and Cuba by processing several thousand wire transfers, travelers' checks, and trade finance transactions involving Iran, Sudan, Cuba, Burma and Libya.

On or about June 2, 1998, ISC transferred the goods referred to in Charge 1 from the United States to the United Arab Emirates with knowledge that a violation of the Regulations would occur - that the goods which were subject to both the Regulations and the Iranian Transactions Regulations would be transferred to Iran.

Between November 2009 and February 2012, Kaiga, managing director of Industrial Metals and Commodities, used as an intermediary to export 7075 Aluminum tubing from a company in northern Illinois to Belgium, then to Malaysia on behalf of Saeed Valadbaigi of Iran.