On May 18, 2026, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a massive $275 million settlement with Adani Enterprises Limited (“AEL”) arising from alleged imports of Iranian-origin liquified petroleum gas (“LPG”) disguised as Omani and Iraqi product.

The enforcement action is significant for several reasons.

First, it underscores OFAC’s continuing emphasis on disrupting Iranian energy exports and the “shadow fleet” infrastructure used to evade sanctions.

Second, it demonstrates OFAC’s willingness to pursue large non-U.S. companies whose only meaningful U.S. nexus may be the use of U.S. dollar payments routed through U.S. financial institutions.

Third, the case illustrates OFAC’s increasingly expansive view of sanctions compliance obligations, especially in high-risk commodity and maritime transactions.

The Conduct at Issue

According to OFAC, between November 2023 and June 2025, AEL purchased 35 shipments of LPG from a Dubai-based trader that purported to source LPG from Oman and Iraq. OFAC alleged that numerous red flags should have alerted AEL that the LPG actually originated from Iran. During the relevant period, AEL allegedly caused U.S. financial institutions to process 32 U.S. dollar-denominated payments totaling approximately $192 million connected to the transactions.

The facts described by OFAC read like a sanctions evasion case study. OFAC cited numerous indicators that the shipments were tied to Iran, including:

• suspicious vessel activity and AIS manipulation;
• uneconomic shipping routes and illogical port calls;
• frequent vessel name and ownership changes;
• questionable certificates of origin;
• delayed or inconsistent shipping documentation;
• pricing significantly below market value; and
• third-party warnings regarding potential Iranian origin.

Particularly damaging was OFAC’s allegation that AEL continued transactions despite repeated warnings and despite circumstances suggesting that the transactions were commercially implausible if the LPG truly originated from Oman or Iraq. OFAC repeatedly emphasized that AEL relied too heavily on facially valid documentation and failed to undertake deeper, risk-based due diligence.

OFAC’s Expansive Jurisdictional Reach

The enforcement action is another reminder of the broad jurisdictional scope of U.S. sanctions laws. AEL is an Indian company, the supplier was Dubai-based, and the cargoes were allegedly sourced from Iran and delivered to India. Yet OFAC asserted jurisdiction because U.S. dollar transactions passed through U.S. correspondent banks.

This theory of jurisdiction has become increasingly important in sanctions enforcement. Any company using U.S. dollars in international trade transactions potentially exposes itself to OFAC jurisdiction because dollar-clearing transactions typically transit the U.S. financial system.

OFAC specifically alleged violations of the Iranian Transactions and Sanctions Regulations (“ITSR”) by “causing” U.S. financial institutions to facilitate prohibited Iran-related transactions.

OFAC’s “Egregious” Determination

OFAC classified the matter as “egregious” and non-voluntarily self-disclosed, resulting in a base statutory maximum penalty exceeding $384 million.

The agency identified several aggravating factors:

1. AEL allegedly acted recklessly by ignoring clear red flags;
2. the conduct undermined core U.S. sanctions objectives targeting Iran’s energy sector; and
3. AEL was deemed a sophisticated multinational enterprise operating in high-risk sectors.

Notably, OFAC did not allege that AEL knowingly purchased Iranian LPG. Instead, OFAC focused heavily on recklessness, inadequate due diligence, and failure to investigate obvious warning signs.

This reflects an important evolution in sanctions enforcement. OFAC increasingly expects companies operating in high-risk industries to proactively investigate suspicious facts rather than merely avoid actual knowledge.

Cooperation and Remediation Reduced Exposure

Despite the “egregious” classification, OFAC credited AEL for substantial cooperation and remediation efforts. After media reports surfaced in 2025, AEL suspended LPG imports, retained U.S. counsel, conducted an extensive internal investigation, and cooperated extensively with OFAC.

OFAC also credited AEL for implementing significant compliance enhancements, including:

• adoption of a centralized sanctions compliance program;
• appointment of a dedicated compliance leader;
• enhanced maritime and sanctions risk assessments; and
• deployment of maritime intelligence technology solutions.

The settlement therefore reflects OFAC’s continued emphasis on rewarding post-discovery cooperation and remediation, even where voluntary self-disclosure credit is unavailable.

wIncreasing Focus on Maritime and Energy Sanctions Enforcement

The settlement fits within OFAC’s broader enforcement strategy targeting Iran’s shadow shipping network and illicit energy exports. OFAC expressly referenced prior guidance concerning maritime sanctions evasion, vessel tracking manipulation, and the use of deceptive shipping practices.

The case also highlights OFAC’s expectation that companies engaged in energy trading and maritime commerce deploy sophisticated compliance tools capable of identifying deceptive shipping patterns and sanctions evasion typologies.

This is no longer a “check-the-box” environment. OFAC made clear that companies cannot rely solely on certificates of origin, counterparty representations, or SDN screening when dealing in high-risk jurisdictions or commodities.

The message from OFAC is unmistakable: companies operating in global energy markets are expected to employ dynamic, intelligence-driven compliance controls designed to identify increasingly sophisticated sanctions evasion schemes.