Adhesive manufacturing company H.B. Fuller said in a regulatory filing last week that it received a “cautionary letter” from the Department of the Treasury’s Office of Foreign Assets Control (OFAC) concerning possible economic sanctions dealings in Iran.
OFAC will not be pursuing a civil monetary penalty and does not intend to take any other enforcement action, the company said.
In its Jan. 26 filing, H.B. Fuller said it retained legal counsel in 2018 to conduct an internal investigation concerning “the possible resale of our hygiene products into Iran by certain customers of our subsidiaries in Turkey, beginning in 2011, and India, beginning in 2014, in possible violation of the economic sanctions against Iran administered by OFAC and our compliance policy.” H.B. Fuller added the sales to these customers “ceased during fiscal year 2018” and that it does not currently conduct any business in Iran.
In January 2018, the company voluntarily contacted OFAC regarding its internal investigation “and our intention to cooperate fully with OFAC.” In September 2018, it further submitted the results and findings of its investigation to the regulator, according to the filing.
“While OFAC has indicated that future enforcement action is not precluded if additional information warrants renewed attention, the cautionary letter represents OFAC’s final enforcement response to our investigation and voluntary disclosure, so we now consider this matter closed,” H.B. Fuller stated.
Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal, enforcement, technology, and more.
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