Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure

In June 2025, the U.S. Treasury's Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability relating to U.S. sanctions on Iran and Venezuela. OFAC is the primary U.S. government agency that administers and enforces U.S. sanctions.

Notably, this followed from a December 2024 announcement by the National Security Division (NSD) of the U.S. Department of Justice (DOJ) that the government was declining to prosecute private equity firm White Deer Management, LLC (White Deer), the owner of Unicat. The declination was the result of White Deer's voluntary self-disclosure of sanctions and export control violations committed by Unicat prior to White Deer's acquisition of the company.