Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million.  Murad was acquired by Unilever United States (“Unilever”) in 2015.  Once discovered, Unilever voluntarily disclosed the conduct to OFAC.

The fallout from Murad’s long-running conspiracy: Unilever paid $3.3 million to OFAC for its Iran Sanctions violations.  Interestingly, OFAC prosecuted a former senior executive (“Executive-1”) from Murad and settled with Executive-1 for $175k.  Executive-1 committed three separate violations as the manager of Murad during the period between June 2016 and September 2017.  Executive-1 did not voluntarily disclose his/her conduct.

In this Episode, Michael Volkov reviews the Murad OFAC settlement and important lessons learned for sanctions compliance programs.