“… Beginning in or about February 2007 and continuing through in or about June 2007, Maghazehe engaged in a transaction or took other action with intent to evade the provisions of the Regulations. Specifically, Maghazehe worked with a U.S. company to arrange for the export without a license from the United States through the United Arab Emirates to Iran of a Varian Ximatron oncology system, which was subject to the Regulations, and the Iranian Transactions Regulations and had a declared value of $5,000. Pursuant to Section 560.204 of the Iranian Transactions Regulations maintained by the Department of the Treasury’s Office of Foreign Assets Control, an export to a third country intended for transshipment to Iran is a transaction that requires OFAC authorization. Pursuant to Section 746.7 of the Regulations, no person may engage in the exportation of an item subject to both the Regulations and the ITR without authorization from OFAC. No OFAC authorization was sought or obtained for the transaction described herein.”

76 FR 60452-54
Published 09-29-2011