First enforcement action in the 90-day baseline; the egregious-and-not-voluntarily-self-disclosed finding, FBI cooperation, and explicit framing as part of Operation Economic Outcast signal a heightened individual enforcement posture for Iran sanctions.
Treasury settled with an individual for $1,427,230 to resolve apparent Iran sanctions violations involving management consulting and advisory services to an Iranian software company, receipt of Iranian-origin dividends, and acquisition of real property in Iran, classified as egregious and not voluntarily self-disclosed.
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