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Turkish Man Designated By OFAC For Directing Subsidiary Of U.S. Firm To Do Business With Iran


The United States government announced sanctions last week against a Turkish national it says helped an American firm evade sanctions against Iran.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) levied sanctions on the man for aiding the subsidiary on six different occasions between July 2013 and July 2015, beginning shortly after the firm for which he would soon become the managing director was acquired by an American company. As a result, the Turkish subsidiary then became subject to longstanding American prohibitions on dealings with Iran.

Although the U.S. company was acknowledged by OFAC as taking extensive precautions against allowing the newly-purchased subsidiary to do business with Iran, OFAC says the new managing director repeatedly ordered his subordinates to carry out services for customers in Iran. In order to obtain compliance, OFAC says the managing director threatened hesitant employees with termination should they refuse, and he ordered them to falsify records upon their return hiding the fact of their illicit dealings in Iran.

A whistleblower finally came forward in late 2015, prompting the U.S. firm to conduct an investigation. Tipped off to the investigation, the Turkish managing director allegedly ramped up efforts at concealing his actions relative to Iran by ordering relevant documents destroyed, including emails. He also allegedly gave false information to the firm’s American attorneys.

OFAC noted that the U.S. firm was cooperative and fully compliant with government investigators. No sanctions have been announced against the firm to date.

As with all OFAC sanctions, the designated individual is now legally barred from exercising rights to any property within the jurisdiction of the United States, and Americans are forbidden from conducting business with him.

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