Internal investigation reveals dealings with sanctioned entities

In a regulatory filing on May 7, 2020, Iron Mountain Incorporated, an information storage and records management company headquartered in Boston, Massachusetts, reported that it had determined that one of its non-US subsidiaries had provided storage and handling services to an entity belonging to the government of Iran and to an entity designated pursuant to Executive Order 13382.  The company noted that the relationships with the entities began before US sanctions would have prohibited them, and continued “automatically” from year to year.  Iron Mountain disclosed the transactions to OFAC as required by Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Exchange Act, and is in the process of terminating its relationships with the sanctioned entities.

The company further noted in its report that during the course of the internal investigation spawned by the initial discovery, it had identified two additional customer relationships with entities designated pursuant to Executive Orders 13382 and 13224. The company added that it is in the process of reviewing, and enhancing as necessary, its policies and processes designed to identify transactions associated with restricted parties.

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