Epsilon Electronics v. TREA: For OFAC, Circumstantial Evidence Could Be Sufficient To Bring Claims for Violations of Iran Sanctions

The saga of California-based wholesaler of electronic equipment for vehicles Epsilon Electronics is one that has been closely observed by OFAC practitioners because of the many issues presented in the case. It has a rather convoluted background which led to the novelty of the question considered in the D.C. Circuit Court of Appeals.