Ellman Pays $191,700 to Settle OFAC Violations
Ellman International of Oceanside, N.Y., agreed to pay $191,700 to settle potential civil liability for apparent violations of the Iranian Transactions Regulations, said the Treasury Department's Office of Foreign Assets Control. Under its prior ownership and management, Ellman sold and…
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exported medical equipment to Iran and engaged the services of a physician in Iran, in apparent violation of the ITR. The value of the relevant transactions from early 2005 to February 2008 totaled $317,211, OFAC said. When Ellman was acquired by a private equity investment group and it discovered Ellman's violations, Ellman's new owners and management self-reported the matter to OFAC. But the submission was determined not to be a voluntary disclosure as defined by OFAC's Economic Sanctions Enforcement Guidelines. OFAC said the apparent violations do not constitute an egregious case, but the settlement amount reflects OFAC's consideration that the transactions appear to have been undertaken by Ellman's prior owners willfully with knowledge, Ellman did not have a sanctions compliance program, but Ellman's purchasers and new owners/management substantially cooperated with the investigation and undertook significant remedial measures, including implementing a sanctions and export compliance program.