EXPORT CONTROLCanadian-Based Company Fined by U.S. Commerce Department for Hiding U.S. Exports to Iran
On October 2, 2025, a Canada-headquartered biotechnology company, Luminultra, agreed to pay the Bureau of Industry and Security $685,051 after admitting to illegally exporting water quality testing and analytical instruments to Iran by means of the United Arab Emirates.
Key Takeaways
· Canada-based biotechnology company Luminultra illegally exported from its Maryland-based production facility three Photonmaster luminometers and 25 aqueous test kits valuing $33,438 USD to Iran on October 21, 2022.
· Under instructions from the Iranian buyer, and hopes of future sales to the Iranian market, Luminultra agreed to falsify export declarations and ship the items from the United States via the United Arab Emirates (UAE) to Iran.
· Under further instructions from the Iranian buyer, Luminultra received payment at a Canadian bank in Canadian dollars specifically to avoid payment for the shipment in USD and through a US bank.
· The case shows a lack of awareness of the risks and penalties associated with willful violation of export controls and sanctions and indicates that Canada needs to improve its outreach to the industry, especially now that a wide range of UN sanctions on Iran are re-instated. It also shows the importance of UN sanctions to prevent banks in third countries from processing illicit payments from Iran.
· Luminultra signed a settlement agreement in September 2025 and agreed to pay the $685,051 fine. They also agreed to establish an export compliance system and complete export compliance audits over a three-year probationary period.[1]
Overview
On October 2, 2025, a Canada-headquartered biotechnology company, Luminultra, agreed to pay the Bureau of Industry and Security $685,051 after admitting to illegally exporting water quality testing and analytical instruments to Iran by means of the United Arab Emirates. Luminultra used its Maryland production facility to export 3 Photonmaster luminometers and 25 aqueous test kits to Iran on October 21, 2022. The buyer, Fanavari Pishrafteh Jahan (FPJ), is a Tehran-based distribution company specializing in laboratory equipment and analytical instruments.
Both the luminometers, which measure microbial activity in drinking and wastewater, and the test kits, which are used to test any kind of water system, were classified as EAR99. The exports were prohibited by the Iranian Transactions and Sanctions Regulations administered by the Office of Foreign Assets Control. The company knew they were not authorized under OFAC’s general license for export of medical devices and took several steps to hide the ultimate destination.
