The Company self-initiated an internal investigation for potential breaches of sanctions and export controls in both the United States and the United Kingdom, as a result of the discovery that there had been indirect supplies of its products to Iran, Syria and Sudan. The Company’s predecessors had undergone a number of significant corporate changes, resulting in the sale of assets (and the product line in question) to the newly formed Company.

The Company subsequently discovered that it had inherited a serious problem relating to indirect supplies to Iran and possibly other embargoed countries from its predecessors.

Peters & Peters were instructed as part of a transnational legal team to advise on (i) the Company’s corporate liability taking into account its various corporate guises, (ii) any potential breaches of export controls and sanctions and (iii) disclosure to the authorities. A coordinated and joined up strategy was devised to ensure that no further action was taken by either the UK or US authorities.