Between the approximate dates of October 7, 2011, and February 20, 2013, when COSL Singapore, through its subsidiary companies COSL Drilling Pan-Pacific (Labuan) Ltd and COSL Drilling Pan-Pacific Ltd, exported or attempted to export 55 orders of oil rig supplies from the United States to Singapore and the United Arab Emirates, and then re-exported or attempted to re-export these supplies to four separate oil rigs located in Iranian territorial waters.

Between June 2007 and February 2008, Nam and Seng fraudulently purchased and caused 6,000 modules to be illegally exported from a Minnesota company through Singapore, and later to Iran.

Between June 2007 and February 2008, Nam and Seng fraudulently purchased and caused 6,000 modules to be illegally exported from a Minnesota company through Singapore, and later to Iran.

Illegally exported auto parts to Iran.

1999-2000 Facilitation of Trade with Iran

1999-2000 Facilitation of Trade with Iran

OFAC alleged that Confi-Dental acted without an OFAC license when it entered into contract with, and attempted to make shipments to, an Iranian company.

Occurring on or about March 31, 2006, to on or about October 22, 2010. The Switzerland branch office of CPI’s U.S. subsidiary, Communications and Power Industries International Inc., sold, on 30 occasions, x-ray generators to an entity in Tehran, Iran; attempted to sell, on two occasions, x-ray generators and a medical digital imaging workstation to an entity in Tehran, Iran; at the request of an entity in Tehran, Iran, directed its affiliate in Canada, Communications & Power Industries Canada Inc.

As early as 2002, bank employees deleted or omitted references to Iranian financial institutions, replaced the originating bank information with Commerzbank’s name, and later created a process to route payments involving Iranian counterparties to a payment queue requiring manual processing by bank employees rather than routine, automated processing.

2000 & 2001 Funds transfer