On August 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had reached a $415,350 settlement with a Singaporean oilfield services company for an alleged 55 violations of Iran sanctions regulations. OFAC asserted that the company “exported or attempted to export 55 orders of oil rig supplies from the [U.S.] to Singapore and the United Arab Emirates, and then re-exported or attempted to re-export these supplies to four separate oil rigs located in Iranian territorial waters” from approximately October 2011 through February 2013. OFAC alleged that each instance of this conduct, which the company did not voluntarily self-disclose, violated OFAC’s Iranian Transactions and Sanctions Regulations. Had the company not settled, OFAC determined that civil monetary penalties ranged from approximately $923,000 to $13.75 million. In establishing the penalty, OFAC considered that the company: (i) failed to act with an appropriate level of caution by exporting goods to oil rigs located in Iranian territorial waters; (ii) aided the development of Iran's energy resources; (iii) “is a large, sophisticated company with 14 offshore drilling rigs doing business throughout the world;” and (iv) “did not have an OFAC compliance program in place at the time of the transactions.” As for mitigating factors, OFAC determined that: (i) the company has no prior sanctions history with OFAC; (ii) the company took remedial action by implementing an OFAC compliance program; and (iii) the company cooperated with the investigation and entered into a tolling agreement with OFAC.