- Many medical products can be exported to Iran – so long as a license is obtained
- Imposition of successor liability underscores importance of pre-transaction due diligence
- OFAC enforcement, as in the past, continues to take a long time
In December 2017, the U.S. Office of Foreign Assets Control (OFAC) announced a penalty of $1.2 million against DENTSPLY SIRONA Inc. (DSI), one of the world’s largest manufacturers of dental products, for violating U.S. sanctions on Iran. DSI, which is publicly traded in the United States, is based in York, Pennsylvania, and maintains operations around the world.