HyperBranch Medical Technology OFAC Settlement: $107.7K

Last updated: July 20, 2026

HyperBranch Medical Technology, Inc. agreed to pay $107,691.30 to settle potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560, arising from exports to its United Arab Emirates distributor with knowledge or reason to know that the goods were ultimately destined for Iran. OFAC determined that HyperBranch voluntarily self-disclosed the apparent violations, and that the apparent violations constitute a non-egregious case.

Penalty Amount

$107,691.30

Enforcement Date

June 23, 2016

Rank in Top Penalties

#238

Case Details

Type:: Entity
Name:: HyperBranch Medical Technology, Inc.
Country:: 🇺🇸 United States
Industry:: Healthcare
Address:: Durham, North Carolina
Penalty amount:: $107,691.30
Base civil monetary penalty:: $159,542.00
Max civil monetary penalty:: $1,129,912.00
Egregious case:: No
Voluntary self disclosure:: Yes
Case:: Settlement
Violation period:: April 15, 2011 to May 27, 2011
Program:: Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560
Enforcement date:: June 23, 2016

Nature of the Apparent Violations

HyperBranch made two exports of medical sealant products to its United Arab Emirates distributor with knowledge or reason to know that the goods were ultimately destined for Iran, in apparent violation of § 560.204 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560. On or about April 15, 2011, HyperBranch exported 1,600 units of Adherus Dural Sealant, 2,000 units of Adherus Spinal Sealant, 20 units of Adherus Dural Sealant samples, and approximately 60 units of Adherus Spinal Sealant samples to its UAE distributor. On or about May 27, 2011, HyperBranch exported an additional 400 units of Adherus Dural Sealant to the same UAE distributor, again with knowledge or reason to know the goods were destined for Iran.

How OFAC Determined the Penalty

OFAC determined that HyperBranch voluntarily self-disclosed the apparent violations, and that the apparent violations constitute a non-egregious case. The statutory maximum civil monetary penalty amount for the apparent violations was $1,129,912 and the base civil monetary penalty was $159,542. The final settlement amount of $107,691.30 reflects OFAC's consideration of aggravating and mitigating factors pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Aggravating Factors

HyperBranch acted willfully by exporting products to its foreign distributor with knowledge or reason to know that the exports were ultimately destined for Iran in apparent violation of U.S. law, editing its destination control statement at the request of its distributor, and continuing to conduct business with its distributor after receiving confirmation that the distributor had reexported HyperBranch products to Iran in apparent violation of U.S. law
HyperBranch's former CEO and former International Sales Manager knew that the exports at issue were ultimately destined for Iran
HyperBranch did not have a sanctions compliance program in place at the time of the apparent violations

Mitigating Factors

Harm to U.S. sanctions program objectives was limited because the exports involved medical end-use products that were likely eligible for a specific license
HyperBranch has no prior OFAC sanctions history, including no penalty notice or Finding of Violation in the five years preceding the date of the earliest transaction giving rise to the apparent violations, making it eligible for "first violation" mitigation of up to 25 percent
HyperBranch took remedial steps, including the implementation of an OFAC compliance program
HyperBranch cooperated with OFAC's investigation and agreed to toll the statute of limitations for a total of 513 days

Official Source Documents

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Archived on June 13, 2026

SHA-256: 2a4bd13adca2381dc2ee842f44bf7f5b82c5202f1ca8c1ff453d2bb730d483d0