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. 

Cited purchase correspondence between Luminultra and FPJ acknowledged that the products were being sent to Iran and that they violated export controls.  The company intentionally concealed that information in its export declarations. Despite the risk taken by Luminultra, the agents at FPJ were able to convince Luminultra to offer a discounted price.   It appears that Luminultra was at least partially motivated to accept the reduced price because it was hopeful of prospects of future sales to the Iranian market.

In other illicit trade cases, Iranian overseas purchasers have stated that their Iranian customer pays only upon delivery of goods. If they are seized in route, the loss is incurred by the trading company or distributor.  In this case, it is not specified when payment took place, but Luminultra, upon FPJ’s request, provided Canadian banking information to FPJ to avoid payment for the shipment in USD and through a US bank.^[2]

Luminultra was instructed to take several steps to hide the actual end user and destination of the products, including by omitting references to the Iranian company and address in all documents and instead listing only the UAE freight forwarder, ShipIt Freight Solutions. FPJ also asked Luminultra to undervalue the shipment to try to avoid the UAE customs duty, and to not include a real invoice in the shipment.^[3]

Legal Background of Charges

Charge 1)  15 C.F.R. § 764.2(e) - Acting with Knowledge of a Violation  - Luminultra violated the EAR with knowledge because the company knew that its exports were destined for Iran and intentionally concealed this fact.  In addition, Luminultra had knowledge that the luminometers and test kits were not considered medical devices and therefore not authorized under OFAC’s general license for export of medical devices.^[4]  

Charge 2)  15 C.F.R. § 764.2(g) - Misrepresentation and Concealment of Facts - Luminultra made false and misleading representations in connection with the submission of an EEI filing. Luminultra took deliberate actions to conceal the final destination of the shipment by falsifying the Electronic Export Information (EEI) to designate ShipIt in the UAE as the end-user.^[5]

Lessons and Recommendations

This case presents a rare, recent occasion in which an established Canada-based supplier decided not only to turn a blind eye to a questionable export but willingly violated U.S. export control and sanctions laws, in cooperation with and under direction of an Iranian agent.  Luminultra, in agreeing to a discount, appears to have been aware of the risk it was facing but violated U.S. laws in expectation of more Iranian business.  This shows that Canada needs to improve its outreach to the industry on export control obligations, sanctions implementation, and the potential costs and consequences of violations. 

Figure 1. Visualization of Company’s Export Process^[6]