How a shopping mall project in Tehran ended up costing a US
construction company $660,594
Sanctions on Iran have been around, and on more than off, for
many years. Thanks to geopolitical tensions in the Middle East and
the memory of the 1979 hostage crisis, most Americans recognize
that doing business with Iran is fraught with compliance and
reputational risk. However, this is not always the case with
overseas subsidiaries. Take, for instance, the recent settlement
agreement between the Treasury Department Office of Foreign Assets
Control (OFAC) and New Jersey-based construction firm Construction
Specialties, Inc. (CS).
CS agreed to a $660,594 fine to settle three apparent violations
of the Iranian Transactions Sanctions Regulations (ITSR), which
arose from the activities of their United Arab Emirates subsidiary,
Construction Specialties, Middle East LLC (CSME). According to the
OFAC press release: "Between December 4,
2016, and August 3, 2017, CSME senior
