World Class Technology OFAC Settlement: $43.2K (2016)

Last updated: July 20, 2026

World Class Technology Corporation settled potential civil liability for alleged violations of the Iranian Transactions and Sanctions Regulations, agreeing to pay $43,200. The alleged violations involve the exportation of seven shipments of orthodontic devices, collectively valued at $59,886, from the United States to Germany, the United Arab Emirates, and/or Lebanon, with knowledge or reason to know that the shipments were intended specifically for supply, transshipment, or reexportation to Iran.

Penalty Amount

$43,200.00

Enforcement Date

September 7, 2016

Rank in Top Penalties

#310

Case Details

Type:: Entity
Name:: World Class Technology Corporation
Country:: 🇺🇸 United States
Industry:: Healthcare
Address:: Portland, Oregon
Penalty amount:: $43,200.00
Base civil monetary penalty:: $80,000.00
Max civil monetary penalty:: $1,750,000.00
Egregious case:: No
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: April 2008 to July 2010
Program:: Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560
Enforcement date:: September 7, 2016

Nature of the Apparent Violations

WCT exported seven shipments of orthodontic devices, collectively valued at $59,886, from the United States to Germany, United Arab Emirates, and/or Lebanon, with knowledge or reason to know that the shipments were intended specifically for supply, transshipment, or reexportation to Iran, in apparent violation of §§ 560.204 and 560.206 of the ITSR. The shipments occurred between April 2008 and July 2010.

How OFAC Determined the Penalty

OFAC determined that WCT did not voluntarily self-disclose the alleged violations, and that the alleged violations constitute a non-egregious case. The maximum statutory civil penalty amount for the alleged violations was $1,750,000, and the base penalty amount was $80,000. The settlement amount of $43,200 reflects OFAC's consideration of the facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Aggravating Factors

WCT willfully violated U.S. sanctions laws
WCT's management had actual knowledge or reason to know that WCT's products were being exported to Iran
WCT had no OFAC compliance program in place until June 2008

Mitigating Factors

The alleged violations did not result in great economic or other benefit conferred on Iran, as the transactions likely would have been licensed by OFAC had WCT applied for a license
WCT has no sanctions history with OFAC for the five years preceding the date of the first transaction giving rise to the alleged violations
WCT cooperated with OFAC by agreeing to toll the statute of limitations
WCT developed an economic sanctions compliance procedure in June 2008 and subsequently drafted a written compliance policy
WCT lacked commercial sophistication in conducting international sales at the time of the alleged violations

Official Source Documents

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Archived on June 13, 2026

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