United Medical Instruments OFAC Settlement: $515.4K

Last updated: July 20, 2026

United Medical Instruments, Inc. (UMI), a company incorporated in California, settled its potential civil liability with OFAC in the amount of $515,400 for 56 alleged violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560. OFAC alleged that UMI made sales of medical imaging equipment with knowledge or reason to know that the goods were intended specifically for supply or re-exportation to buyers located in Iran, and facilitated the sales of medical imaging equipment from a company located in the United Arab Emirates to Iran.

Penalty Amount

$515,400.00

Enforcement Date

February 28, 2017

Rank in Top Penalties

#135

Case Details

Type:: Entity
Name:: United Medical Instruments, Inc.
Country:: 🇺🇸 United States
Industry:: Healthcare
Address:: California
Penalty amount:: $515,400.00
Egregious case:: Unknown
Apparent violations:: 56
Voluntary self disclosure:: Unknown
Case:: Settlement
Violation period:: December 5, 2007 to April 30, 2009
Program:: Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR)
Enforcement date:: February 28, 2017

Nature of the Apparent Violations

From on or about December 5, 2007 to on or about April 30, 2009, UMI violated §§ 560.204 and 560.208 of the ITSR on at least 56 occasions. UMI made sales of medical imaging equipment with knowledge or reason to know that the goods were intended specifically for supply or re-exportation to buyers located in Iran, and it facilitated the sales of medical imaging equipment from a company located in the United Arab Emirates to Iran. The total value of the goods associated with these transactions was approximately $2,493,597.

How OFAC Determined the Penalty

The $515,400 settlement amount reflects OFAC's consideration of the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A. UMI's obligation to pay is satisfied by: (a) its compliance with the terms of its September 24, 2013 Settlement Agreement with the U.S. Department of Commerce's Bureau of Industry and Security; and (b) its payment of $15,400 to the U.S. Department of the Treasury. The remainder of the settlement amount is thus deemed satisfied by compliance with the BIS agreement rather than by direct payment to OFAC.

Aggravating Factors

UMI willfully exported goods from the United States to Iran with actual knowledge and prior notice that such shipments constituted or likely constituted a violation of U.S. law
UMI had actual knowledge that it required a license to send and/or export its products to Iran, as demonstrated by a November 2003 license application the company submitted to OFAC
UMI failed to effectively manage and enforce its compliance program

Mitigating Factors

The alleged violations occurred due to the actions of a single UMI employee rather than a systemic pattern of company-wide conduct
UMI took remedial action in response to the alleged violations, including by voluntarily ceasing transactions involving Iran and by implementing new procedures and updating its compliance program to prevent the recurrence of similar sanctions violations
UMI has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the alleged violations
UMI cooperated with OFAC's investigation by providing timely responses to OFAC's correspondence and by entering into multiple statute of limitations tolling agreements
UMI is a small business, as determined by the size standards set forth by the Small Business Administration
Based on the financial condition of UMI, including significant financial difficulties experienced by the company in recent years, additional mitigation is warranted

Official Source Documents

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View archived version View on ofac.treasury.gov

Archived on June 13, 2026

SHA-256: 98579f45a43294193087a3565e201fe7bfdcd3cf7ccd2782f5d7277772411aa2