Trade sanctions are put in place by countries hoping to convince the sanctioned bodies to make changes of some sort. We tend to think of sanctions as involving manufactured products or services linked to manufacturing. But it turns out that everything related to trade compliance – sanctions and otherwise – are more than just manufacturing issues.
A recent case first made public by the federal government in September 2021 demonstrates that even scientific research and the materials it utilizes are subject to sanctions. The case involves three individuals who have been charged with violating sanctions against Iran. The complaint against them alleges that the Iranian doctor, his wife, and his sister both laundered foreign money and imported and exported it illegally.
Shipping Equipment to Iran
The first part of the complaint alleges that the three defendants received millions of dollars in payments from China, Malaysia, Singapore, Turkey, and the UAE. Much of the money was used to purchase genetic sequencing equipment here in the States and ship it overseas to Iran. The rest of the money was used to buy property for the American company operated by two of the suspects.
In addition, the doctor was discovered smuggling biological material into the United States on a return trip from Iran. He has also been charged with making false statements by claiming that he did not engage in his profession while in the country. The FBI says documents show otherwise.
Topping it all off are additional charges alleging that the doctor did not report significant electronic fund transfers from overseas while working for the University of Miami. The law requires reporting to either the University or the National Institutes of Health.
On the Sanctions List
It goes without saying that the nation of Iran is on the U.S. sanctions list. Furthermore, principals living and working in Iran may also be sanctioned depending on their associations, work, etc. Pretty much any business with Iran’s public or private sector is not allowed by U.S. residents under the current sanctioning environment.
In all likelihood, the three defendants, in this case, we’re fully aware of the situation. It doesn’t seem reasonable that illegal activity taking place over the course of seven years and totaling millions of dollars could have been accidental or the work of innocent but ignorant people.
That being said, even violating sanctions based on ignorance is not looked on very highly by the U.S. government. Thus, Ohio-based Vigilant Global Trade Services says it is imperative that all importers and exporters are fully versed regarding all sanctioned countries, entities, and persons.
You Don’t Need Trouble
If you own or operate an organization that imports or exports, the lesson in all of this is pretty simple: you don’t need the trouble that comes with violating sanctions. The three defendants in the Iran case likely knew full well what they were doing. If found guilty, they will be punished accordingly. You do not want to follow in their footsteps, even in ignorance.
Note that multiple lists have to be searched to account for all U.S. and international sanctions. Here in the U.S., the U.S. Treasury’s Office of Foreign Assets Control (OFAC) is tasked with enforcing sanctions. Their three most utilized lists are the:
- Specially Designated Nationals List
- Consolidated Sanctions List
- Foreign Sanctions Evaders List.
OFAC maintains six additional lists, and there are also numerous lists kept by international governing bodies. Needless to say, there is a lot of information that has to be accounted for to avoid violations. As the Iranian case demonstrates, sanctions are not just for manufacturers to worry about.
