Clifford Chance

OFAC's Compliance Focus Stands Out in Latest Enforcement Action

8 February 2019

On February 7, 2019, OFAC announced its second settlement of 2019. The settlement with Kollmorgen Corporation ("Kollmorgen") related to six apparent violations of the Iranian Transactions and Sanctions Regulations, committed by its Turkish affiliate, Elsim Elektroteknik Sistemler Sanayi ve Ticaret Anonim Sirketi ("Elsim"). Kollmorgen acquired Elsim in 2013, knowing that it historically did business with Iran, and took extensive steps to ensure that such business was terminated after its acquisition. Nevertheless, through allegedly deceptive means, Elsim continued to service machines and provide parts in Iran until 2015.

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