A U.S. consultant agreed to pay a settlement to the Office of Foreign Assets Control to settle potential civil liability for providing prohibited software advisory services and receiving dividend payments from Iran over multiple years, despite being fully aware of federal sanctions.
Federal regulators have penalized a U.S. consultant for maintaining commercial ties to Iran and providing strategic software advice to one of the country’s leading software solutions businesses. The enforcement action, announced by the U.S. Department of the Treasury, underscores how federal prohibitions apply directly to American citizens and permanent residents regardless of where they reside or operate. Meanwhile, the Trump administration launched a broader economic onslaught
and “economic D-Day” sanctions offensive against Tehran, as U.S. Treasury Secretary Scott Bessent warned of efforts to isolate the regime and sever commercial ties after nearly six months of conflict.
The Trump administration on Monday delivered its promised threat of sweeping secondary sanctions against countries continuing to trade with Iran, warning of an economic onslaught
designed to isolate Tehran. Yet the measures, billed as an “economic D-Day” for Iran, stopped short of imposing immediate penalties on key trading partners including China, the UAE and Turkey. US Treasury Secretary Scott Bessent said Washington was launching a campaign to persuade governments and companies to sever commercial ties with Iran after nearly six months of conflict between the two countries.
Sanctions List Search Tool
The measures expanded the categories of Iran-related activity that could be subject to secondary sanctions and designated nearly 60 entities, individuals and vessels linked to Iranian oil exports, sanctions evasion, cyber operations and procurement networks. The US Treasury also suspended several general licences covering remittance payments and certain cultural and academic exchanges with Iran, while issuing fresh guidance warning shipping companies of sanctions risks associated with complying with Iranian demands in the Strait of Hormuz. We are launching an economic onslaught against Iran’s financial connections around the globe,
Bessent told reporters. Economic asphyxiation of this regime.
However, despite promises of what Bessent had described in a Financial Times article as the single greatest financial offensive ever marshalled against an adversary
, the package largely consisted of threats of future action rather than immediate penalties against Iran’s largest commercial partners. Bessent said President Donald Trump was personally contacting world leaders with specific requests
to end commercial ties with Tehran and indicated countries would be given time to wind down business before facing unilateral US sanctions.
Ties to Iran’s Leading Software Firm
The case dates back to 1987. According to the agency’s enforcement findings, the consultant originally founded an Iranian software solutions company while living in Iran in 1987, and in 2011 OFAC said they created an Iran-incorporated holding company to maintain their ownership interest in the software firm. The agency said the firm has grown to become one of Iran’s leading software solutions businesses, providing financial, administrative, human resources, logistics and management software for a range of Iranian industries and state-owned entities.
Over time, that enterprise expanded into a prominent domestic operation supplying financial, administrative, human resources, logistics, and management software across various Iranian industries and state-owned entities. Despite expanding federal sanctions, the consultant kept connections to both the software firm and the holding company over many years.
OFAC Fines US Consultant for Iran Advisory Services
Virtual Advisory Calls and Layered Wire Transfers
The regulatory scrutiny focused heavily on a multi-year window between 2019 and 2023, when the agency said the person provided management consulting and advisory services in virtual meetings with the companies’ senior officials. The consultant and others during those calls discussed corporate transactions, asset management, sales, marketing, accounting, human resources, corporate governance and overall company strategy, OFAC said.
“provided substantive advice, analysis, and information.”
U.S. Department of the Treasury, Office of Foreign Assets Control
The agency added that the U.S. consultant drafted the agenda for some of the meetings, and at other times they provided substantive advice, analysis, and information. OFAC also said the consultant, between June 2019 and August 2020, arranged for dividend payments from the two Iranian companies to be deposited into U.S. banks by wire transfers. The wire transfers first transited through banks in third countries, including in Turkey, the United Arab Emirates and Singapore, before being paid into the consultant’s U.S. accounts. OFAC said the person received $713,615 in dividend payments. The consultant also used other dividend payments to buy four real estate properties in Iran for relatives around or after 2021, OFAC said.
US sanctions offensive against Iran stops short of targeting
Ignored Warnings and Aggravating Factors
Federal officials noted that the consultant could not claim ignorance of the rules. The regulatory filing points to an article in a leading newspaper
that the consultant co-authored in 2000 about Iran’s digital revolution and the challenges of the Iran sanctions program to Iran’s information technology sector.
The investigation also faced hurdles regarding cooperation. OFAC said the person gave an initially incomplete
response to an OFAC subpoena in January 2025. After the agency sent the person another subpoena and cited their deficient responses,
the consultant provided a complete response.
The agency said the consultant eventually “abandoned” ownership interest in the two Iranian companies in 2022, but not before violating the Iranian Transactions and Sanctions Regulations from their advisory work, the U.S. bank processing of Iran-origin dividends, and the real estate purchases. OFAC said the consultant committed the violations despite being “aware” of U.S. sanctions on Iran, and the financial penalty was adjusted downward to account for an inability to pay a larger settlement amount alongside a lack of prior enforcement actions over the previous five years.
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