On 10/20/2020, the Department of the Treasury issued an “enforcement release” explaining that OFAC had settled with Berkshire Hathaway Inc. with respect to potential civil liability for apparent violations of the Iranian Transactions and Sanctions regulations engaged in by one of its foreign subsidiaries, known as “Iscar Turkey.” In their release, the Treasury explained:
“Iscar Turkey sold cutting tools and related inserts to two third-party Turkish distributors knowing that such goods would be shipped to a distributor in Iran for resale to Iranian end-users, including several entities later identified as meeting the definition of the Government of Iran, in violation of Berkshire’s compliance policies. Iscar Turkey took steps to obfuscate its dealings with Iran, including concealing these activities from Berkshire. Iscar Turkey’s conduct in this matter…represents particularly serious apparent violations of the law calling for a strong enforcement action”
As a result of Iscar Turkey’s actions, Berkshire Hathaway has agreed to pay a $4,144,651 payment to settle its potential civil liability for trade-related transactions and exports to Iran.
The full Treasury enforcement release can be found here.