OFAC’s $4.1 Million Penalty on Berkshire Hathaway Subsidiary: Why it Matters

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced on October 20 that it was imposing a $4.1 million penalty against Omaha, Nebraska-based Berkshire Hathaway Inc., its subsidiary MC International Metalworking Companies B.V. (“IMC”) and IMC’s wholly owned Turkish subsidiary, Iscar Kesici Takim Ticareti ve Imalati Limited Sirket (“Iscar Turkey”) for illicit transactions by Iscar Turkey with Iran. Iscar Turkey is in the business of manufacturing machinery, specifically cutting tools and inserts. The violations took place between 2012 and 2016, with Iscar Turkey entering into 144 transactions with Iran over that period. While announcements of OFAC penalties for sanctions violations are not rare, this one has a few notable points.
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced on October 20 that it was imposing a $4.1 million penalty against Omaha, Nebraska-based Berkshire Hathaway Inc., its subsidiary MC International Metalworking Companies B.V. (“IMC”) and IMC’s wholly owned Turkish subsidiary, Iscar Kesici Takim Ticareti ve Imalati Limited Sirket (“Iscar Turkey”) for illicit transactions by Iscar Turkey with Iran. Iscar Turkey is in the business of manufacturing machinery, specifically cutting tools and inserts. The violations took place between 2012 and 2016, with Iscar Turkey entering into 144 transactions with Iran over that period. While announcements of OFAC penalties for sanctions violations are not rare, this one has a few notable points.

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