Today OFAC announced a $506,250 settlement with ZAG IP, LLC (formerly known as ZAG International, LLC) (“ZAG”), a U.S. company with its business address in Newtown, Connecticut, for five apparent violations of § 560.206 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Specifically, between on or about July 11, 2014 and on or about January 15, 2015, through five separate transactions, ZAG purchased a total of 263,563 metric tons of Iranian-origin clinker from a company located in the United Arab Emirates, with knowledge that the cement clinker was sourced from Iran, and then resold and transported it to a company in Tanzania. OFAC determined that ZAG voluntarily self-disclosed the apparent violations to OFAC, and that the apparent violations constitute a non-egregious case.
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