H.B. Fuller Company, an industrial sealants and adhesives manufacturer based in St. Paul, Minnesota, confirmed in its 2020 annual report that the Office of Foreign Asset Controls of the US Department of the Treasury had issued a cautionary letter to the company, but had elected not to pursue a civil monetary penalty or further enforcement action based on the information provided by Fuller at the close of the company’s internal investigation into potential Iran sanctions violations.
In earlier regulatory filings, the company had disclosed that it had retained outside counsel to conduct an investigation into the possible resale of Fuller products to Iran through customers in Turkey and India between 2011 and 2018. According to Fuller, the company voluntarily disclosed the internal investigation to OFAC in January 2018, along with its intention to cooperate fully with OFAC. In September 2018, Fuller submitted the results of the investigation to OFAC, which issued the cautionary letter in December 2020.