OFAC settles apparent Iran sanctions violations with raw materials marketing company

ZAG IP, LLC , a Connecticut-based global sourcing and marketing company for cement products, has agreed to pay $506,250 to settle potential civil liability for apparently violating  § 560.206 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), on five occasions in 2014 and 2015.  The company allegedly purchased cement clinker from a company in the United Arab Emirates for resale in Tanzania, knowing that the product originated in Iran.  In announcing the settlement, the Office of Foreign Assets Control of the US Department of the Treasury noted that the settlement amount reflects aggravating factors such as ZAG’s reckless disregard for sanctions requirements in the exercise of its due diligence; awareness by a senior manager of the source of the cement; and the economic benefit conferred on Iran by the transactions.  OFAC also considered mitigating factors, including remedial measures undertaken by ZAG; the company’s voluntary self-disclosure of the apparent violations; its timely and efficient cooperation with OFAC’s investigation; and ZAG’s five year record without OFAC penalty notices or findings of violations.

OFAC press release | OFAC Enforcement Information