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.
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Photo of Jeffrey L. Snyder Jeffrey L. Snyder

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of…

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of U.S. extraterritorial regulations. Jeff assists companies in day-to-day compliance with these laws, and with interventions — such as audits and investigations, and civil enforcement proceedings.

Photo of Edward Goetz Edward Goetz

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control…

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control, economic sanctions, anti-money laundering (AML), anti-corruption/anti-bribery, and antiboycott. He has extensive government experience providing information and interpretive guidance on the International Traffic in Arms Regulations (ITAR) concerning the export of defense articles, defense services, and related technical data. He also assists attorneys with matters involving the Export Administration Regulations (EAR), economic sanctions, AML, anti-corruption/anti-bribery, and trade remedies.