Microsoft Corporation

Microsoft Corporation has agreed to pay $2,980,265.86 to settle potential civil liability for 30 apparent violations of U.S. sanctions on Iran between July 2012 and April 2019. These violations involved the sale, activation, and provision of software and related services from Microsoft’s U.S.-based systems to Iranian entities. Microsoft failed to screen and identify Iranian end users, allowing them to access software through third-party distributors and resellers. Some Iranian customers were able to circumvent Microsoft’s compliance measures by providing incomplete or misleading information during account setup. While Microsoft voluntarily self-disclosed the violations and took extensive remedial measures, including improving sanctions screening, disabling software licenses for blocked users, and enhancing compliance training, OFAC found that Microsoft had demonstrated a reckless disregard for U.S. sanctions over seven years. The case highlights the importance of robust compliance controls in global technology firms, especially when dealing with indirect sales channels and foreign subsidiaries that may obscure sanctioned parties.