OFAC Fines Two Firms $15K and $5K for Violating Iran Transaction Regs
The Office of Foreign Assets Control has announced civil penalties of $15,000 for a Minnesota company and $5,400 for an Alabama company for separate violations of the Iran Transaction Regulations. OFAC determined that both companies did not voluntarily disclose these matters to OFAC and that the apparent violations constituted non-egregious cases. Civil penalties for both companies were lower than the base penalty for the alleged violations.
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Minnesota Company Agreed to Remit $15K for Exporting Punch Press Tool Equip to Iran
Wilson Tool International, Inc., a Minnesota company, has agreed to remit $15,000 to settle an alleged violation of the Iranian Transactions Regulations occurring on or about September 12, 2005. OFAC alleged that Wilson Tool sold and exported punch press tooling equipment to an entity in Iran without an OFAC license. The transaction value was $10,304.
The base penalty amount for the alleged violation was $25,000. The settlement amount reflects OFAC’s consideration of the following facts and circumstances, pursuant to the General Factors under OFAC’s Economic Sanctions Enforcement Guidelines: Wilson Tool has not been the subject of prior OFAC penalties or other administrative actions, and Wilson Tool cooperated with OFAC by promptly responding to OFAC’s administrative subpoenas and entering into a statute of limitations tolling agreement with OFAC.
Alabama Company Agreed to Remit $5.4K for Facilitating Export of Goods to Iran
ASF, Inc., an Alabama company, has agreed to remit $5,400 to settle allegations of a violation of the Iranian Transactions Regulations that occurred on or about May 2, 2006. OFAC alleged that ASF engaged in a transaction related to goods destined for Iran and facilitated the exportation of goods from a third country to Iran by a foreign person, without an OFAC license.
The base penalty amount for the alleged violation was $10,000. The settlement amount reflects OFAC’s consideration of the following facts and circumstances, pursuant to the General Factors under the Economic Sanctions Enforcement Guidelines: ASF appears to have lacked an OFAC compliance program at the time of the alleged violation; ASF had knowledge or reason to know the goods were destined for Iran; ASF has not been the subject of an OFAC enforcement action in the five years preceding the transactions at issue; the goods may have been eligible for an OFAC license; and ASF cooperated with OFAC’s investigation of this matter, including by agreeing to toll the statute of limitations.