Justice Department Declines Prosecution of Private Equity Firm Following Voluntary Disclosure of Sanctions Violations and Related Offenses Committed by Acquired Company (06/16/25)

The Justice Department’s National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas declined to prosecute private equity firm White Deer Management LLC and its affiliates after the firm discovered and voluntarily self-disclosed criminal violations of U.S. sanctions and export laws committed by a company it acquired, Texas-based Unicat Catalyst Technologies LLC. After acquiring a company with a hidden history of sanctions violations, this private equity firm uncovered the misconduct, stopped it, and quickly reported it to the government, leading to the successful prosecution of a senior executive. Unicat agreed to pay $3,882,797 to OFAC for its apparent violations of U.S. sanctions laws and agreed with OEE to pay a penalty of $391,183 for its violation of U.S. export control laws. The former CEO and co-founder of Unicat, Mani Erfan, pleaded guilty to conspiring to violate U.S. sanctions against Iran and other countries and foreign governments, as well as concealment and international promotional money laundering. As part of his plea, Erfan also agreed to pay a money judgment in the amount of $1,600,000.