Enforcement Actions for December 2017 By Jeffrey L. Snyder & Edward Goetz on January 15, 2018 Posted in Iran Sanctions, Office of Foreign Assets Control (OFAC), Sanctions Office of Foreign Assets Control (OFAC) On December 6, OFAC announced that DENTSPLY SIRONA Inc. (DSI), a U.S. company incorporated in Delaware, the successor in interest to DENTSPLY International Inc. (DII), agreed to pay $1.2 million to settle its potential civil liability for 37 apparent violations of the Iranian Transactions and Sanctions Regulations. Between 2009 and 2012, DII subsidiaries exported 37 shipments of dental equipment and supplies from the U.S. to third countries, with knowledge or reason to know the goods were ultimately destined for Iran. OFAC determined this was a non-egregious case and that DII did not voluntarily disclose the apparent violations. Aggravating factors included: The subsidiaries acted willfully and had knowledge or reason to know the goods were destined for Iran; Management knew of the apparent violations; and DENTSPLY is a large and commercially sophisticated company with knowledge of U.S. sanctions requirements. Mitigating factors included: DENTSPLY had not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the first transaction, although DENTSPLY was previously the subject of a settlement involving substantially similar apparent violations in 2001; The harm to the ITSR program objectives was limited because the exports were likely eligible for a specific license; DENTSPLY took remedial steps, including voluntarily expanding the scope of the review to include a full, company-wide inquiry following a subpoena to one of its subsidiaries that led to the subsequent revelations involving the other subsidiary; and DENTSPLY cooperated with OFAC’s investigation, including by providing detailed and well-organized information for its review, and by agreeing to toll the statute of limitations for a total of 1,104 days.