Sunrise Technologies OFAC Settlement: $1.7M (2011)

Between 2007 and 2011, Sunrise and its principal owner made unlicensed exports of computer-related goods indirectly from the United States through Dubai, United Arab Emirates, to Iran, in apparent violation of § 560.204 of the ITR. OFAC initiated the inquiry into these matters and referred the case to criminal law enforcement authorities for further investigation.

Sunrise and its principal owner did not voluntarily disclose these matters to OFAC. OFAC considers the apparent violations to be egregious. Sunrise, its principal owner, and OFAC agreed to a settlement in the amount of $1,661,672 with respect to apparent violations of the ITR. OFAC's settlement with Sunrise and its principal owner has been deemed satisfied by their acceptance of criminal responsibility, the criminal forfeiture of assets, and the restrictions imposed by BIS against Sunrise and its principal owner.

Sunrise and its principal owner each pleaded guilty in the U.S. District Court for the District of Columbia to one count of criminal conspiracy to violate IEEPA and the ITR after an indictment arising from the same conduct was filed by the U.S. Department of Justice. In addition to the forfeiture of a money judgment in the amount of $1,250,000, Sunrise and its principal owner also accepted BIS Export Denial Orders which prohibit them from exporting any goods from the United States for a ten-year period. The BIS Export Denial Orders were suspended in their entirety provided Sunrise and its principal owner remain in compliance with the terms of their Settlement Agreements with BIS and with the Export Administration Regulations.

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