A global software company recently agreed to pay combined penalties of more than $8 million as part of a global resolution with the U.S. Department of Justice (DOJ) resulting from its export control violations. Beginning in 2010 and continuing through 2017, the software company, without an export license, either exported or caused the export of its products to Iranian users. Specifically, the software company had inadvertently released thousands of downloads of their products, upgrades and patches to users in Iran. 

The penalties resulting from the export control violations could have been higher had the software company not voluntarily disclosed its violations to the DOJ. In its voluntary disclosures, the software company acknowledged violations of the export administration regulations (EAR) and the Iranian transactions and sanctions regulations. As a result of its voluntary disclosures to the DOJ, the DOJ and the U.S. Attorney’s Office for the District of Massachusetts entered into a nonprosecution agreement with the software company.