Whitford Worldwide OFAC Settlement: $824.3K (2020)

Last updated: July 20, 2026

Whitford Worldwide Company, LLC, a cookware coating manufacturer, settled its potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations, agreeing to pay $824,314. The apparent violations arose from Whitford's foreign subsidiaries' sales to Iran and from U.S.-person employees of Whitford who oversaw and provided instructions relating to some of these sales.

Penalty Amount

$824,314.00

Enforcement Date

July 28, 2020

Rank in Top Penalties

#116

Case Details

Type:: Entity
Name:: Whitford Worldwide Company, LLC
Country:: 🇺🇸 United States
Industry:: Materials & Components
Address:: Elverson, Pennsylvania
Penalty amount:: $824,314.00
Base civil monetary penalty:: $1,526,508.00
Max civil monetary penalty:: $19,953,513.00
Egregious case:: No
Apparent violations:: 74
Voluntary self disclosure:: Yes
Case:: Settlement
Violation period:: November 2012 to December 2015
Program:: Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR)
Enforcement date:: July 28, 2020

Nature of the Apparent Violations

Between November 2012 and December 2015, Whitford and its owned or controlled foreign subsidiaries appear to have violated the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), 74 times. The apparent violations fell into two categories: (1) Whitford's foreign subsidiaries exported goods to Iran and engaged in trade-related transactions with Iran, in apparent violation of § 560.215 of the ITSR, by engaging in conduct that would have been prohibited if engaged in by a U.S. person under §§ 560.204 or 560.206; and (2) U.S.-person employees of Whitford facilitated the Iran-related business, in apparent violation of § 560.208 of the ITSR.

Whitford's foreign subsidiaries, Whitford S.r.l. in Italy ("Whitford-Italy") and Whitford Yuzey Kaplamalari Sanayi ve Ticaret Limited Sirketi in Turkey ("Whitford-Turkey"), historically sold coatings to Iran. After changes to OFAC's Iran sanctions program in 2012 that prohibited U.S.-owned or -controlled foreign entities from knowingly engaging in transactions with Iran, both subsidiaries continued to sell coatings to Iran. Whitford failed to comply with the new prohibitions arising from these changes.

When Whitford realized in 2013 that Whitford-Turkey's sales to Iran may be problematic, its Regulatory Affairs Manager (who did not specialize in sanctions compliance) incorrectly advised that Whitford's foreign subsidiaries could legally continue selling to Iran so long as there were no direct connections between a Whitford subsidiary and Iran. After receiving this advice, Whitford's Managing Director for Europe (a U.S. person who oversaw both Whitford-Italy and Whitford-Turkey), along with managers from both entities, developed a plan to continue selling to Iran by instructing that sales go indirectly through third-party distributors and that documents related to those sales avoid referencing Iran. By adopting this plan, from approximately February 2014 through December 2015, Whitford, Whitford-Turkey, and Whitford-Italy engaged in additional apparent violations by selling to Iran, making payments to and receiving payments from their Iranian sales agent, and engaging in prohibited facilitation of transactions with Iran.

How OFAC Determined the Penalty

The statutory maximum civil monetary penalty applicable in this matter is $19,953,513. OFAC determined that Whitford voluntarily self-disclosed the apparent violations and that the apparent violations constitute a non-egregious case. Accordingly, under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A, the base civil monetary penalty amount applicable in this matter is $1,526,508. The settlement amount of $824,314 reflects OFAC's consideration of the General Factors under the Enforcement Guidelines.

Aggravating Factors

With a lengthy history of foreign subsidiary sales to Iran, Whitford acted recklessly by failing to implement compliance policies commensurate with selling to a high-risk jurisdiction such as Iran and taking affirmative steps to help its foreign subsidiaries to continue selling to Iran, using indirect channels, after being warned that foreign subsidiary sales to Iran were problematic.
Whitford, including its Managing Director for Europe (a U.S. person) and other senior managers, had actual knowledge of the conduct associated with the Apparent Violations and also facilitated transactions with Iran by developing a plan to continue its Iran-related business through indirect channels.
Whitford conferred an economic benefit to Iran of $3.05 million through 74 transactions over the course of approximately three years.

Mitigating Factors

Whitford substantially cooperated with OFAC's investigation by providing data analysis of the Apparent Violations, submitting detailed information in a well-organized manner, and entering into multiple tolling agreements to extend the statute of limitations. Additionally, Whitford, through outside counsel, conducted an internal investigation without receiving an administrative subpoena and identified and disclosed the transactions that led to the Apparent Violations.
Whitford has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest transaction giving rise to the Apparent Violations.
Whitford undertook significant remedial measures, including: hiring outside counsel to investigate and advise the company on sanctions matters; appointing an independent external compliance monitor responsible for auditing Whitford's compliance with U.S. sanctions and export controls, who reports directly to the Board of Directors; appointing an internal compliance monitor with responsibility for executing implementation of the recommendations made by the external compliance monitor; making changes to Whitford's leadership, including requesting and receiving the resignation of the Chief Executive Officer (formerly the Managing Director for Europe who was part of the plan to continue selling goods to Iran) from the Board of Directors, and appointing a new, independent member to the Board of Directors; establishing annual and quarterly reporting requirements related to U.S. sanctions compliance, including certification requirements for Managing Directors at each of the company's subsidiaries, the Chief Executive Officer, the internal and external compliance monitors, and the General Counsel; adopting a Code of Conduct that applies to Whitford and all its subsidiaries; adopting a new, global sanctions and export controls compliance policy utilizing an export compliance program manual; and providing export controls and sanctions compliance training and establishing a central repository for compliance and training materials.

Compliance Takeaways

This case demonstrates the importance of companies dedicating sufficient resources to U.S. sanctions compliance, staying abreast of changes to sanctions regulations, and understanding the full scope of sanctions prohibitions, especially when operating in higher risk jurisdictions. U.S. companies with foreign operations -- particularly those with a history of trading with Iran -- may face a myriad of sanctions risks. Sanctions compliance personnel at U.S. companies should have the appropriate technical knowledge and expertise, based on the company's risk exposure.

Failing to develop, implement, and routinely update a sanctions compliance program can result in apparent violations. Sanctions programs and the corresponding regulations, like the ITSR, may change based on U.S. national security objectives. Failure to dedicate sufficient resources to monitor, apply, and ensure ongoing compliance with new sanctions laws may result in potential exposure to civil monetary penalties, including for activities related to foreign subsidiaries.

Official Source Documents

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Archived on June 13, 2026

SHA-256: e20617dfb7a6da7a143c6f20fe7db7f9032b9b0ab7f16421de6d2932b7a579ee