Yantai Jereh Oilfield Services Group Co., Ltd. and its affiliated companies and subsidiaries has reached a settlement with the Office of Foreign Assets Control for potential violations of Iran sanctions. OFAC alleges that between October 2014 and March 2016, Jereh Group companies may have violated Sections 560.203 and 560.204 of the Iranian Transactions and Sanctions Regulations (31 C.F.R. part 560). In a report submitted to OFAC, Jereh admitted that a Chinese company, Jinan Tongbaolai Oilfield Equipment Co., Ltd. executed purchase orders and contracts with Jereh and then resold the merchandise, some of which originated in the US, directly and indirectly to entities in Iran. The settlement agreement states that Jereh directed sales through several other intermediaries as well, despite a June 2011 policy directive disseminated within the company that forbade business with Iran. Through the settlement agreement, OFAC agrees to release Jereh from civil liability for the apparent violations, without any finding of fault, and Jereh agrees to pay $2,774,972, terminate the conduct described in the settlement agreement, take personnel action dictated by the agreement, engage outside trade counsel to conduct an internal review and develop a trade and sanctions compliance program, create a permanent compliance department, and prepare and circulate an export compliance manual, among other requirements.