Sanctions Evasion Reference

Unicat: Iran written as "I" in the emails

A Texas catalyst company paid OFAC $3.9 million in 2025 after its former CEO directed sales to Iran through a UAE distributor, a Dutch affiliate and a China office. New owners found it on a site visit.

period

2016–2021

outcome

Settlement

parties

Unicat Catalyst Technologies, LLC; Its former chief executive officer; Unicat's Dutch affiliate; Orinoco Iron S.C.S.

programmes

Islamic Republic of Iran, Bolivarian Republic of Venezuela

reviewed

2026-10-01

Cite this page
APA 7
Sanctions Evasion Reference. (2026, October 1). Unicat: Iran written as "I" in the emails. https://sanctionsevasion.org/cases/unicat-catalysts-iran-venezuela-2025/
Chicago
Sanctions Evasion Reference. “Unicat: Iran written as "I" in the emails.” Last reviewed October 1, 2026. https://sanctionsevasion.org/cases/unicat-catalysts-iran-venezuela-2025/.
BibTeX
@misc{ser-cases-unicat-catalysts-iran-venezuela-2025,
  author = {{Sanctions Evasion Reference}},
  title  = {Unicat: Iran written as "I" in the emails},
  year   = {2026},
  note   = {Last reviewed 2026-10-01},
  url    = {https://sanctionsevasion.org/cases/unicat-catalysts-iran-venezuela-2025/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2025-06-16 $3,882,797 14 apparent violations worth about $2.58 million; egregious, voluntarily self-disclosed. Base penalty $4,017,813; statutory maximum $8,035,626. Deemed satisfied up to an equal amount by payments to the Department of Justice; the Commerce Department's Bureau of Industry and Security settled separately.

A case where the concealment is visible in the email subject lines.

How the supply chain worked

Unicat, based in Alvin, Texas, sells catalysts used in refineries and steel mills. From 2016 it bought most of them from manufacturers in China through one supplier who worked in both countries, and the supplier usually shipped directly from China to the customer. In 2018 the supplier set up a Unicat-branded company in Dalian. Orders arrived at the Texas headquarters or at a majority-owned Dutch affiliate.

Iran

OFAC says the former CEO had known since at least 2015 that US law prohibited trading with Iran. At his direction, Unicat signed distribution agreements in 2016 and again in 2020 with a regional distributor operating in the UAE and Iran to sell to end users in Iran. When a supply chain manager wrote in July 2018 that “sending from the US [sic] will not be an option”, the CEO replied that the Dutch affiliate could handle the order and the goods could ship from China. They did.

Unicat also sent technical staff to Iran three times to supervise loading catalysts into refinery reactors. Payment for those services was in cash. The distributor explained that cash would “avoid from transfering [sic] money” since “it is not possible to transfer money through US [sic] to Iran.”

The board knew by late 2018 — a December meeting agenda listed “ongoing business in Iran” — and did not stop it. In 2019 employees began writing Iran as “I” in emails, discussed who should not see shipping documents because “sanctions have been tougher now”, and in May 2019 a sales manager wrote: “I suggest you don’t put the country name on any communication, especially not on email title or subject.” Sales continued until February 2021.

Venezuela

In May 2020 Unicat sold catalysts to Orinoco Iron, then owned by the Government of Venezuela. The CEO, the China office and a person acting for Orinoco used unrelated third-party entities for the sale, and the CEO arranged to receive $517,337 of Orinoco’s $1,370,231 payment as a credit from the China office, which OFAC describes as an apparent attempt to obscure the payment.

How it ended

In April 2021 Unicat merged with a UK company whose founder became its CEO. On his first visit to the Texas headquarters in July 2021 he found the sales to sanctioned countries and stopped them. The former CEO was terminated, and Unicat filed disclosures with OFAC, the Justice Department and the Commerce Department a month later.

The penalty

Egregious but voluntarily self-disclosed, at $3.9 million against a $4.0 million base. The release lists the CEO’s knowledge, the board’s inaction, the instruction to keep Iran out of emails and the Dutch-affiliate redirect as aggravating, and credits the self-disclosure, a full internal investigation, and a new compliance programme with periodic audits and sanctions clauses in agent contracts.

What the record shows

  • Routing through a majority-owned foreign affiliate does not remove US liability. The Dutch affiliate’s role is the basis for a separate facilitation violation. See third-country transshipment and the pages on the UAE, the Netherlands and China.
  • Third-party entities and a credit note obscure a payer. See front companies.
  • A change of owner surfaced it. Like Murad, the conduct was concealed internally and found by new management, not by a control.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Iran sanctions — A layered set of US, EU and UN measures dating from 1979 and substantially rebuilt after 2018, covering energy, finance, shipping, and proliferation-related procurement.
  • Venezuela sanctions — US measures targeting the Venezuelan government, the state oil company and designated individuals, with restrictions on debt, equity and petroleum dealings.
  • United Arab Emirates — A major re-export hub and financial centre that appears in enforcement records across almost every technique on this site, principally because of the volume of trade that passes through it.
  • Netherlands — A major European trading and logistics hub whose port and trading companies appear in enforcement records the way any high-volume gateway does, from a criminal prosecution to an investigation still at the arrest stage.
  • China — A very large manufacturing exporter, named as a transshipment point in US export-control alerts on Russia and described in Multilateral Sanctions Monitoring Team reporting as the place North Korea's stolen cryptocurrency is cashed out.

Enforcement documents and sources

  1. Unicat Catalyst Technologies, LLC Settles with OFAC for $3,882,797. U.S. Department of the Treasury, Office of Foreign Assets Control, 2025. Enforcement release, 2025-06-16, US$3,882,797.
  2. A Framework for OFAC Compliance Commitments. U.S. Department of the Treasury, Office of Foreign Assets Control, 2019. Risk Assessment, Mergers and Acquisitions (M&A); Root Causes, item III; General Aspects of an SCP, Testing and Auditing.

All enforcement cases