Unicat Board's Sanctions faux-pas

Hi ,

I’m putting the finishing touches to my deep-dive on OFAC’s latest Enforcement Action against Unicat Catalyst Technologies - a Texas company that sells catalysts: https://ofac.treasury.gov/recent-actions/20250616.

In advance of sending you the full piece on Monday, here’s two key points you might want to copy and past for your next Board Meeting:

1. Unicat had a culture of concealment - from the top down. As my title highlights there was active collaboration across the company on calling Iranian clients “I” clients.

2. Unicat’s Board spoke openly about “ongoing business in Iran” without doing anything to rectify that point. Any board awareness creates a duty to act immediately.

As you can see from the timeline this was exacerbated by the fact that the previous CEO had shown his understanding and appreciation of sanctions requirements in 2015.

I look forward to sharing with you on Monday and hope you have a great weekend.

Cheers

Paul