Construction Specialties Inc. (CS), a company that specializes in selling building materials, has been fined $0.66 million by the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) due to three apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR), specifically 31 C.F.R. part 560.

The settlement pertains to CS’s wholly controlled subsidiary based in the United Arab Emirates (UAE), known as Construction Specialties Middle East L.L.C. (CSME). During the period between 2016 and 2017, CSME, under the guidance of its General Manager, imported goods from both CS and another U.S. supplier into the UAE, and subsequently reexported these goods to Iran, knowingly violating the regulations. Throughout this process, CSME’s General Manager and another senior manager employed deceptive practices, which included altering purchase orders, using false project names, and removing labels to obscure the U.S. origin of the goods. Furthermore, they also blended U.S.-sourced products with items produced in the UAE when conducting sales to Iran, all with the intent of concealing the true origin of the merchandise.

As a consequence of CSME’s actions involving the import and reexport of goods from the U.S. to Iran, the company has been found in violation of § 560.215 of the ITSR on three occasions.