On April 25, 2012, Sandhill Scientific Inc. (Sandhill), a U.S. manufacturer of medical equipment, agreed to pay $126,000 to settle allegations that it violated the Iranian Transactions Regulations (ITR) and related regulations. The ITR broadly prohibits U.S. companies from entering into, or performing, business transactions with parties in Iran as well as specified Iranian entities. Specifically, the Office of Foreign Assets Control (OFAC) alleged that Sandhill exported medical equipment valued at approximately $6,700 to Dubai with knowledge or reason to know that the goods were intended for transshipment to a company in Iran. OFAC also alleged that Sandhill failed to provide documents responsive to two administrative subpoenas issued by OFAC during its investigation.
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