DENTSPLY SIRONA INC. OFAC Settlement: $1.2M (2017)

Between on or about November 26, 2009 and July 5, 2012, DII subsidiaries UK International ("UKI") and DS Healthcare Inc. (d.b.a. Sultan Healthcare) ("Sultan") exported 37 shipments of dental equipment and supplies from the United States to distributors in third countries, with knowledge or reason to know that the goods were ultimately destined for Iran, in apparent violation of § 560.204 of the ITSR. Personnel from these subsidiaries and/or divisions concealed the fact that the goods were destined for Iran, and in multiple cases continued to conduct business with these distributors after receiving confirmation that the distributors had re-exported DII products to Iran in apparent violation of the ITSR. Several supervisory and managerial personnel within UKI and Sultan had actual knowledge of, and actively participated in, the conduct that led to the apparent violations and appear to have deliberately concealed their awareness from DII.

OFAC determined that DII did not voluntarily disclose the apparent violations and that the apparent violations constitute a non-egregious case. The statutory maximum penalty amount is $9,551,082 and the base penalty amount is $1,695,500. OFAC thoroughly considered the arguments DENTSPLY set forth in its submissions, and the settlement amount of $1,220,400 reflects OFAC's consideration of facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

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