In re White Deer Management LLC and In re Unicat Catalyst Technologies LLC

From approximately 2014 through 2021, Mani Erfan, the cofounder and CEO of Unicat Catalyst Technologies LLC, conspired with others, including at least one other Unicat employee, to cause Unicat to submit bids and make sales to customers in Iran, Venezuela, Syria, and Cuba in violation of U.S. economic sanctions. In total, Erfan caused Unicat to make a total of 23 unlawful sales of chemical catalysts used in oil refining and steel production to customers in Iran, Venezuela, and Cuba. Some of the sales were effected through exports of catalysts from the United States and further violated U.S. export control laws. To further the conspiracy, the conspirators made false statements in export documents and financial records about the true identities and locations of Unicat’s customers and falsely assured some Unicat employees that the company’s business with customers subject to U.S. economic sanctions was lawful. Unicat obtained approximately $3.33 million in revenue from its unlawful sales.

Unicat was acquired by private equity firm White Deer Management LLC in 2020 during the COVID-19 pandemic.  In June 2021, Unicat’s new CEO traveled to the United States to begin integrating the company’s operations with another business recently acquired by White Deer.  During the visit, the new CEO discovered that Unicat had a pending transaction with an Iranian customer and immediately cancelled the deal.  Over the following month, White Deer retained counsel to conduct an internal investigation and self-disclosed criminal violations of sanctions and export control laws committed by Unicat to the National Security Division (NSD) under the NSD Enforcement Policy for Business Organizations (NSD Enforcement Policy). Over the ensuing months White Deer and Unicat implemented extensive remedial measures and cooperated with NSD’s investigation, resulting in Erfan’s guilty plea for his role in the conspiracy in August 2024.

On June 16, 2025, the Justice Department announced that, because of White Deer’s timely self-disclosure, extraordinary cooperation, and prompt remediation, White Deer qualified for the benefits of the provisions of the NSD Enforcement Policy that apply to Voluntary Self-Disclosures in Connection with Acquisitions (the NSD M&A Policy) and that NSD and SDTX had declined White Deer’s prosecution.

NSD and SDTX also announced that they had credited to Unicat White Deer’s timely self-disclosure of the misconduct to NSD and that they had entered into a non-prosecution agreement (NPA) to resolve Unicat’s criminal liability. In its NPA Unicat agreed to pay forfeiture totaling $3,325,052.10, representing the proceeds of its violations of U.S. sanctions and export control laws. In parallel resolutions coordinated between the Justice Department, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the Commerce Department’s Bureau of Industry and Security (BIS) Office of Export Enforcement (OEE), 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. OFAC agreed to credit Unicat’s payment of forfeiture pursuant to the NPA against the OFAC penalty, and OEE has agreed to credit Unicat’s payment to OFAC against the OEE penalty. In a separate administrative resolution with U.S. Customs and Border Protection, Unicat agreed to pay $1,655,189.57, in underpaid duties, taxes, and fees.

This resolution marked the first time since the creation of the Justice Department’s Mergers and Acquisitions Policy in March 2024 that the Department had declined the prosecution of an acquiror for self-disclosing criminal conduct discovered at an acquired entity.