OFAC announced a $1,427,230 settlement with a natural U.S. person for 39 apparent egregious, non-voluntarily-disclosed violations of the ITSR arising from management consulting and advisory services rendered to an Iranian software company and its holding vehicle across 19 virtual meetings (2019–2020), receipt of $713,615 in Iranian-origin dividends via wire transfers routed through Türkiye, the UAE, and Singapore into U.S. accounts (16 occasions), and the purchase of four Iranian real estate properties with dividend proceeds.