US OFAC settlement agreement with Adani Enterprises Limited for purchase of sanctioned gas

20 May 2026

The US Office of Foreign Assets Control (OFAC) has reached a settlement agreement with Adani Enterprises Limited (AEL). AEL has agreed to pay $275,000,000 to settle civil liability for over 32 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR).

Between 2023 and 2025, AEL imported liquified petroleum gas (LPG) from a Dubai supplier and sold it to customers in India. The supplier represented itself as a supplier of LPG from Oman and Iraq. In fact, the supplier or its affiliates sold 32 shipments of LPG originating from Iran to AEL, for a total of $192,104,044. OFAC found that AEL overlooked red flags indicating that LPG was Iranian in origin, that should have been investigated:

• Offers received for LPG were significantly discounted below the market rate;

• The ships carrying LPG routinely engaged in suspicious behaviour: they manipulated their Automatic Identification System (AIS), had unexplained AIS dark periods, and engaged in frequent name and flag changes;

• Payments owed to the Dubai Supplier were stopped due to sanctions concerns at least once.

AEL did not voluntarily self-disclose the apparent violations, and OFAC found them to be egregious breaches of ITSR.

The base statutory maximum penalty was reduced to $275,000,000 because:

• In the 5 years before the earliest illicit transaction AEL had not breached OFAC rules;
• The LPG business was a small percentage of AEL’s overall revenue;
• AEL cooperated with OFAC throughout the investigation;
• AEL has since implemented enhanced sanctions compliance policies.

OFAC’s compliance lessons

Buyers of energy products from regions with a high risk of sanctions evasion activity should conduct deep due diligence to corroborate the origin of energy products, verify the authenticity of certificates of origin, and monitor for behaviour associated with Iran’s “shadow fleet”. It is not sufficient to rely on counterparty documentation when red flags are raised.

OFAC has released guidance on the expected levels of due diligence. See our US Guidance Page for US sanctions guidance and our US enforcement pages for all OFAC enforcement action.