Whitford's Breach of US Iran Sanctions

Within the scope of US sanctions regime against Iran, Whitford Worldwide Company, LLC (“Whitford”) reached a settlement with US Office of Foreign Assets Control (“OFAC”) amounting to USD 824.314 for engaging in commercial transactions with Iranian correspondences by itself and its subsidiaries in both Turkey and Italy.

As it is known, under the economic US sanctions regime against Iran, US companies and foreign subsidiaries controlled by the US companies are forbidden from trading with Iran. However, the employees of Whitford were instructed to continue on the commercial transactions with Iran through third party intermediaries, since the compliance director of Whitford suggested that indirect sales by the foreign subsidiaries to Iran could carry on.

Whitford, later on realized the referred transactions could be breaching the sanctions regime, thus voluntarily disclosed the past transactions, cooperated with OFAC throughout the investigation and took significant corrective sanctions immediately. Those steps caused a material decrease in the projected amount of civil liability of Whitford, the almost by half.