The Justice Department announced it has declined to prosecute White Deer Management LLC, a private equity firm, after the firm voluntarily self-disclosed criminal violations of U.S. sanctions and export control laws committed by an acquired company, Unicat Catalyst Technologies LLC (Unicat).
After Justice's announcement, the Department of Commerce released details of a parallel settlement reached in December 2024 related to the same activities.
Justice entered into a non-prosecution agreement with Unicat, and announced the guilty plea of former Unicat CEO Mani Erfan for conspiracy to violate sanctions laws and related offenses.
Assistant Attorney General for National Security John A. Eisenberg stated, “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.”
From 2014 to 2021, Erfan and others engaged in prohibited sales of chemical catalysts to sanctioned jurisdictions including Iran, Venezuela, and Cuba. The scheme included false export documentation and misrepresentations to Unicat employees. Unlawful sales generated $3.33 million in revenue. The firm also falsified import invoices from China, resulting in $1.66 million in lost duties.
Following the acquisition, White Deer’s newly appointed CEO discovered a pending transaction with an Iranian customer. The firm canceled the deal, launched an internal investigation, and disclosed the violations to DOJ before the investigation concluded.
Pursuant to the resolution:
• Unicat will forfeit $3.3 million under the DOJ agreement.
• OFAC imposed a penalty of $3.88 million, partially offset by the DOJ forfeiture.
• BIS levied a penalty of $391,183, crediting amounts paid to OFAC.
• CBP settled for $1.65 million in unpaid tariffs.
• Erfan pleaded guilty and agreed to a $1.6 million money judgment.
The resolution marks the first DOJ declination under the National Security Division’s 2024 Mergers and Acquisitions Policy, which incentivizes voluntary self-disclosure of national security-related offenses by acquirors. DOJ, SDTX, and national security agencies credited White Deer for timely disclosure, full cooperation, and remediation efforts.
BIS charged Unicat with three violations of the EAR for knowingly exporting catalysts (classified as EAR99) to Iran via a UAE intermediary without the required U.S. government authorization.
While the Proposed Charging letter, settlement and order were finalized in December 2024, BIS made the docments available in June, 2025.
Under the settlement agreement, Unicat Catalyst Technologies, LLC admitted the export violations committed by its predecessor and agreed to pay a civil penalty of $391,183, offset by a parallel settlement with the Office of Foreign Assets Control (OFAC).
BIS imposed a three-year denial of Unicat’s export privileges, suspended during a probationary period of equal length. The denial may be activated if Unicat violates the Export Administration Regulations (EAR) or related orders during the suspension.
As part of the agreement, Unicat is required to submit annual compliance reports to BIS, reflecting obligations under its Non-Prosecution Agreement with the Department of Justice and the OFAC settlement.
Should Unicat breach the probation terms, it would face a full denial of export privileges, be barred from participating in any U.S. export-related activity, and potentially have affiliated parties added to the denial order under 15 C.F.R. § 766.23.
The case was investigated by ICE-HSI, the Defense Criminal Investigative Service, and BIS. It was prosecuted by NSD Trial Attorneys Adam P. Barry and Yifei Zheng, and SDTX Assistant U.S. Attorney S. Mark McIntyre.
[UPDATED June 23, 2025 with BIS release of Administrative Enforcemnt Settlement Agreement etc]
View a copy of the White Deer declination letter, Unicat non-prosecution agreement, and Mani Erfan's plea agreement.
OFAC Enforcement Notice and Settlement agreement.
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