Litigation

15 ENFORCEMENT ACTIONS On April 19, Oklahoma-based Alliance Steel, Inc. agreed to pay $435,003 to settle its potential civil liability arising from 61 apparent violations of US sanctions against Iran. Alliance designs and manufactures prefabricated steel structures. Although primarily a US-based enterprise, when demand for engineering services for its domestic customers exceeds Alliance's available resources, Alliance outsources work to third-party, non-US subcontractors. Between October 2013 and October 2018, those circumstances led Alliance to knowingly import engineering services from a third party located in Iran. According to OFAC, the company's Vice President of Engineering and twelve other senior managers were aware of these transactions and participated in the approval process, which included approving payments of invoices plainly reflecting the subcontractor's permanent address in Tehran, Iran. OFAC determined that this was a non- egregious case, and that Alliance voluntarily self- disclosed and undertook remedial action. On April 29, OFAC announced a settlement agreement with Texas-based MoneyGram Payment Systems, Inc., in which MoneyGram agreed to pay $34,328.78 to settle its potential civil liability for 359 apparent violations of multiple US sanctions programs. According to OFAC, MoneyGram provided payment services to approximately forty blocked persons, including individuals incarcerated in federal prisons and individuals engaged in commercial transactions relating to Syria. Specifically, between March 2013 and January 2015, the company's deficient screening protocols and software failed to prevent MoneyGram from providing money transfer services to inmates in the Department of Justice's Federal Bureau of Prisons system, as well as other blocked persons. In addition, MoneyGram allegedly processed commercial transactions related to Syria on behalf of two blocked persons under the mistaken belief that those transactions were personal remittances rather than commercial transactions. OFAC noted that MoneyGram's apparent violations were voluntarily self-disclosed and were non- egregious. On April 29, SAP SE agreed to pay combined penalties of approximately $8 million in a global settlement with the US Department of Justice, the Bureau of Industry and Security at the Department of Commerce, and OFAC after the company self-disclosed thousands of exports of its software products and services to prohibited parties in Iran. The majority of violations arose from Iranian users (who were several layers away from direct sales by SAP) accessing cloud—based software subscription services provided by SAP's US subsidiaries. SAP's NPA with the DOJ was the first of its kind under the DOJ's "Export Controls and Sanctions Enforcement Policy for Business Organizations," which provides new guidance on voluntary self-disclosures of export and sanctions violations. On May 3, the State Department entered an administrative settlement with Honeywell International, Inc. to resolve alleged violations of the Arms Export Control Act and the International Traffic in Arms Regulations. According to the State Department, Honeywell made unauthorized exports and retransfers of ITAR-controlled technical data which contained detailed engineering prints for multiple aircraft, gas turbine engines, and military electronics to or within Canada, Ireland, Mexico, China, and Taiwan. Pursuant to the thirty-six-month Consent

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