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US Software Company Discloses Potential Sanctions Violations

UserTesting, a California-based software company, said it may have violated U.S. sanctions by allowing users in Iran to access its platform, the company said in an April 4 SEC filing. The company said it conducted an internal review of its sanctions and export control compliance in “mid-2021” and discovered that Iranian “parties” signed up for a free trial of its platform but “did not make payment to us.” UserTesting also said it found a “limited number of participant accounts that represented themselves as residing in non-embargoed countries but may have accessed our platform from embargoed countries.”

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The company said it submitted a voluntary self-disclosure to the Office of Foreign Assets Control in July but hadn't yet heard back from the agency. UserTesting is working on improving its controls and sanctions screening tools to “prevent similar activity from occurring in the future.”