On 21 February 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with U.S. company ZAG IP, LLC (formerly known as ZAG International, LLC) (“ZAG”). ZAG’s $506,250 settlement with OFAC is for five apparent violations of § 560.206 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Apparently, between the approximate dates of 11 July 2014 and 15 January 2015, ZAG purchased cement clinker from a company in the United Arab Emirates and resold and transported it to a company in Tanzania, knowing that the clinker was sourced in Iran. ZAG voluntarily disclosed these apparent violations to OFAC and OFAC determined that this constitutes a non-egregious case.
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