Info:
Kayakiran is being sanctioned as a foreign sanctions evader pursuant to Executive Order 13608, which targets efforts by foreign persons to engage in activities intended to evade U.S. economic and financial sanctions with respect to Iran and Syria;
OFAC sanctioned Kayakiran, a Turkish national, for causing six violations of U.S. sanctions against Iran. Between July 2013 and July 2015, Kayakiran was the managing director of a Turkish company that imports, distributes, and installs motion control products (Elsim Elektroteknik Sistemler Sanayi ve Ticaret Anonim Sirketi). In March 2013, a Kollmorgen Corporation acquired the Turkish Company, thereby making the latter subject to the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Specifically, section 560.215 of the ITSR prohibits foreign entities that are owned or controlled by a U.S. person (including entities) and established or maintained outside the United States from knowingly engaging in any transaction with the Government of Iran or any person subject to the jurisdiction of that government that would be prohibited by the ITSR if engaged in by a U.S. person or in the United States;
Before and after the acquisition, the Kollmorgen Corporation undertook a wide range of proactive compliance measures designed to ensure that the newly acquired Turkish Company complied with U.S. sanctions, including those against Iran;
Despite the U.S. Company’s extensive efforts, for two years after the acquisition, Kayakiran — in his role as the managing director of the Elsim — directed employees to service machinery located in Iran. Employees were threatened with termination if they refused to travel to Iran to provide the services, and upon returning from the trips, employees were directed to falsify corporate records by listing the travel as vacation rather than business. Kayakiran also regularly and fraudulently certified to the Kollmorgen Corporation that no products or services were being sent to Iran. It was only after an employee filed an internal complaint with the Kollmorgen Corporation via the company’s ethics hotline in late October 2015 that the violations and associated conduct came to light. Kollmorgen Corporation subsequently investigated the matter;
Upon being notified of the Kollmorgen Corporation’s internal investigation, Kayakiran attempted to obstruct the investigation by instructing the Elsim’s employees to delete references to Iran in company records and misled the U.S. Company’s attorneys. Finally, Kayakiran attempted to delete emails related to Iran;
Kollmorgen Corporation completed its internal investigation despite Kayakiran’s efforts and fully cooperated with OFAC’s investigation, including by filing a thorough voluntary self-disclosure with OFAC;
Date of Birth:
08 Feb 1980
Country:
Turkey
Passport:
U00242309 (Turkey)