3M Imtec Corporation entered into a US$125,000 joint settlement with OFAC and BIS for violations of the Iranian Transactions Regulations and EAR. Between 2004 and 2007, Imtec Corporation, the predecessor to 3M Imtec, made multiple unlicensed sales of dental implants and related equipment, valued at more than US$81,000, to Iran via the United Arab Emirates. Imtec had previously obtained licenses from OFAC for the sale of dental equipment to Iran. However, these licenses lapsed due to Imtec’s failure to implement a trade compliance program and resulted in Imtec’s unlicensed sales to Iran. These unlicensed transactions were discovered and disclosed to BIS and OFAC during a due diligence review conducted prior to the acquisition of Imtec by 3M.