Behrouz Mokhtari of McLean, Virginia, and Tehran pleaded guilty Jan. 9 to two conspiracies to violate U.S. sanctions on Iran "by engaging in business activities on behalf of Iranian entities" without getting a license from the Treasury Department's Office of Foreign Assets Control, DOJ announced Jan. 9. Mokhtari will forfeit money, property and assets obtained from the schemes, including a Campbell, California, home, and a money judgment of over $2.8 million, DOJ said. The defendant faces a maximum of five years in prison for each of the two conspiracy counts.

Electronics distribution company Broad Tech System and its president and owner, Tao Jiang of Riverside, California, pleaded guilty Jan. 11 to participating in a conspiracy to illegally ship chemicals made or distributed by a Rhode Island-based company to a Chinese firm with ties to the Chinese military, the U.S. Attorney's Office for the District of Rhode Island announced. Jiang and Broad Tech admitted to violating the Export Control Act and conspiring to commit money laundering.

Export Compliance Daily is providing this recap of export control and sanctions enforcement over the past year to assist export compliance professionals, lawyers and others in keeping pace with current enforcement trends. This guide summarizes the most notable enforcement actions by the Commerce Department's Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Treasury Department’s Office of Foreign Assets Control and the Department of Justice since Jan. 1, 2023.

The Office of Foreign Assets Control Dec. 30 fined a multinational Danish-based refrigeration manufacturer more than $4.3 million for violating U.S. sanctions against Iran, Syria and Sudan. Danfoss, which also sells air conditioners and other cooling and heating products, illegally directed customers in all three countries to make payments through a U.S. financial institution, OFAC said in an enforcement notice. The company also made illegal payments to entities in Iran and Syria.

The Bureau of Industry and Security issued a 180-day temporary denial order Dec. 13 against three people and two companies for illegally sending controlled exports to Russia as part of a Moscow-led sanctions evasion scheme. Along with the denial order, DOJ indicted the three individuals, along with others, on charges related to the illegal exports, including money laundering, wire fraud, bank fraud and conspiring to defraud the U.S.

Export Compliance Daily is providing this recap of export control and sanctions enforcement over the past year to assist export compliance professionals, lawyers and others in staying up to date with current enforcement trends. This guide summarizes the most notable enforcement actions by the Commerce Department's Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Treasury Department’s Office of Foreign Assets Control and the Department of Justice since Jan. 1, 2022.

An Iranian businessman was sentenced to 46 months in prison for illegally exporting carbon fiber from the U.S. to Iran, the Justice Department said Nov. 14. Behzad Pourghannad worked with two others between 2008 and 2013 to export the carbon fiber to Iran from third countries using falsified documents and front companies, the agency said.

A Lebanese energy equipment company was fined $368,000 by the Bureau of Industry and Security after it illegally reexported generators to Syria, according to a settlement agreement signed Nov. 27. Ghaddar Machinery allegedly committed 20 violations of the Export Administration Regulations from 2014 to 2016, totaling about $730,000 worth of exports, BIS said. Ghaddar agreed to pay the penalty in five installments through November 2021. Failure to make the payments could result in more penalties, according to the settlement agreement, including a two-year denial of export privileges.

Apple was fined about $465,000 for violations of the Foreign Narcotics Kingpin Sanctions Regulations after it hosted, sold and “facilitated the transfer” of software applications and content belonging to a sanctioned company, the Treasury’s Office of Foreign Assets Control said in a Nov. 25 notice. Apple allegedly dealt in “the property and interests” of SIS d.o.o., a Slovenian software company added to OFAC’s Specially Designated Nationals List in 2015.

Export Compliance Daily is providing this recap of sanctions and export controls enforcement over the past year. Intended to assist export compliance professionals, lawyers and others in the export world stay up to date with current enforcement trends, this guide includes summaries of prominent enforcement actions by the Treasury's Office of Foreign Assets Controls, the Commerce Department's Bureau of Industry and Security, and the Justice Department since Export Compliance Daily began publishing in March 2019.