In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran Sanctions Program. AL US enlisted its then subsidiary (now operating unit), Alfa Laval Tank, Inc, based in Exton, Pennsylvania (AL Tank), to participate in the scheme. 

The Alfa Laval enforcement action underscores the dangers for global companies in compliance with US-based sanctions programs as part of global operations.  The parent company, Alfa Laval AB is based in Sweden (AL Sweden). AL Middle East agreed to pay OFAC $415,695, and AL US agreed to pay OFAC $16,875. 

In this Episode, MIchael Volkov reviews the OFAC enforcement action and points out interesting aspects and trends.