The violation is not serious because the United States’ sanctions are very broad, covering “goods, services, technology, information, or support” that could in any way help the nation to develop its petroleum resources. Forget doing anything that could help Iran go nuclear, too.
As The Register discovered when we spoke to an Iranian resident for The eXpat Files back in 2015, Iran manages to get American tech in through resellers in gulf countries.
Dell’s violations occurred outside Iran: the 10Q reports that in the first half of 2016 the company sold “desktop computers, computer stands, and a server, and associated warranty support” to the Iranian embassies in Germany and France. The transactions secured “net revenue of approximately 4,998 Euros and realized net profits of approximately 1,231 Euros from the three sales.”
The company has also provided support to Iranian embassies in the Netherlands and Italy.
Dell’s since dissolved those deals and won’t provide further support.
The company’s also stopped support for the Paris, France, branch of Iranian concern the Bank of Saderat.
Not long after the new sanctions-violation reporting regime was introduced in 2012, The Washington Post reported that businesses had disclosed transactions yielding as little as US$4 profit, in order to show how seriously they take complying with sanctions and reporting requirements. The Register has also found that IRANNOTICEs appear every few days.
Dell’s almost certainly disclosed for the same reasons and will therefore almost certainly escape domestic sanctions and any stain on the company’s reputation.
The Register imagines Dell staff around the world have been sent a memo reminding them the US-based company has certain responsibilities.
But there is one new thing to consider, in the form of president-elect Donald Trump’s vehement opposition to recently relaxed sanctions on Iran. Trump made criticism of the Obama administration’s Iran deal a centrepiece of his foreign policy. Dell will likely escape this time, but before long even a trivial breach may be viewed less kindly. Even if it earns an American company a profit of €1,231