Alfa Laval

Alfa Laval is a Swedish technology company that provides industrial equipment for the energy, chemical, metal, food, and beverage industries. It has a strong US presence and had over $3.3 billion in revenue in 2009 (Company Annual Report).  (http://local.alfalaval.com/en-us/about-us/alfa-laval-usa/pages/default.aspx) (http://www.alfalaval.com/about-us/investors/Reports/annual-reports/Documents/Annual_report_2009_eng.pdf)

Alfa Laval website lists a head office in Tehran, Iran. (https://www.alfalaval.ae/contact-us/?countryId=818)

Alfa Laval sells its products in Iran through an Iranian website, in addition to maintaing an office in Tehran (Iranian Website). Through this site, Alfa Laval makes available many products that have a known application in the nuclear energy industry. For example, Alfa Laval advertises the benefits of installing its plate heat exchangers in nuclear power plants. (http://www.alfalaval.com/contact-us/iran/Pages/default.aspx) (http://www.alfalaval.com/solution-finder/customer-stories/Pages/china-nuclear.aspx)

Alfa Laval's has deep commercial ties with the U.S. government. Since 2000, Alfa Laval has received over $40.4 million in US government contracts. $35.8 million of these contracts were awarded by the Department of Defense (USA Spending).  (http://www.usaspending.gov/explore?carryfilters=on&fromfiscal=yes&tab=By+Recipient&fiscal_year=2008&contractorid=296116&tab=By+Recipient&fiscal_year=&fromfiscal=yes&carryfilters=on&Submit=Go)

"As part of the settlement [with US Treasury Department], Alfa Laval Middle East agreed to implement sanctions compliance measures for five years and provide annual certification to OFAC that the measures have been implemented." (Compliance Week, "Alfa Laval subsidiaries fined $430K for Iran sanctions violations," 7/20/21) (https://www.complianceweek.com/sanctions/alfa-laval-subsidiaries-fined-430k-for-iran-sanctions-violations/30593.article)

The company discloses in its annual report that it has paid at least $632,911 in salary to employees in Iran since 2007 (Company Annual Report) (http://www.alfalaval.com/about-us/investors/Reports/annual-reports/Documents/Annual_report_2009_eng.pdf)

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[Alfa Laval agreed to] pay or arrange for the payment to the U.S. Department of the Treasury the amount of $415,695."

According to a Settlement Agreement with the US Treasury Department signed April 28, 2021, the "OFAC determined that AL [Alfa Laval] Middle East [a subsidiary of Alfa Laval AB] committed one apparent violation of § 560.203(a) of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (“ITSR”) by causing a U.S. person, Alfa Laval Inc. (“AL U.S.”), to violate § 560.204 of the ITSR by exporting $18,585 worth of U.S.-origin goods indirectly to Iran on or about March 26, 2016.  (https://home.treasury.gov/system/files/126/20210719_al_middle_east_settlement.pdf)

Additionally, AL Middle East committed one apparent violation of § 560.203(b) of the ITSR in forming a conspiracy with two Iran-based firms and one Dubai-based company to cause a U.S. person to violate § 560.204. This conspiracy took place from on or about August 8, 2015 to on or about May 5, 2016 and involved conduct relating to an export worth $18,585 described above, an incomplete export transaction worth $5,170, and future contemplated transactions worth $181,453.