OFAC settled with Rice Lake Weighing Systems, a Wisconsin-based scale manufacturer, to pay $60,764 for potential civil liability for eight apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR). The violations arose from Rice Lake's Italian subsidiary, Dini Argeo S.r.l., which continued indirect sales of weighing equipment to Iran via a UAE-based distributor between June 2019 and November 2021, after General License H authorizing such sales had been revoked in 2018, with total transaction value of approximately $121,527. OFAC deemed the case non-egregious and voluntarily self-disclosed, applying a base penalty of one-half the aggregate transaction value. Key takeaways: 1. Foreign subsidiaries owned or controlled by U.S. persons are subject to ITSR obligations nearly identical to their U.S. parent, and compliance failures at the subsidiary level create direct liability for the U.S. parent. 2. Aggravating factors included reckless disregard for sanctions requirements (Dini should have known indirect sales were prohibited) and Rice Lake's failure to adequately explain or translate compliance guidance sent to non-U.S. personnel. 3. Red flags indicating diversion were present but missed, including repeated inquiries from the sanctioned Iranian counterparty and Iran-referencing email signatures. 4. Mitigating factors included prompt self-initiated investigation upon receiving a tip, voluntary self-disclosure, tolling of the statute of limitations, and post-discovery compliance program enhancements (employee training, distributor vetting, reexport warnings on invoices). 5. OFAC flagged the UAE as a known high-risk jurisdiction for diversion, reinforcing the need for heightened due diligence on indirect sales channels through such intermediary markets.