An Oklahoma-based steel designer and manufacturer settled potential civil liability with OFAC for alleged violations of the Iranian Transactions and Sanctions Regulations ("ITSR").
According to OFAC, the company's Vice President of Engineering impermissibly imported services from an Iranian engineering company owned by the vice president's brother when demand exceeded the company's internal resources. OFAC alleged that several members of the company's senior management were aware that the transactions were taking place, and that the company to which the service work was being outsourced was Iranian. According to the company, because it sells only to domestic U.S. customers and does not normally do business internationally, its management was "not attuned to the laws and regulations administered by OFAC." OFAC determined that the company violated ITSR section 201 ("Prohibited Importation of Goods or Services from Iran") and ITSR section 206 ("Prohibited Trade-Related Transactions with Iran; Goods, Technology, or Services").
OFAC determined that the violations were voluntarily self-disclosed and did not constitute an egregious case. OFAC noted that the company ceased all work with the Iranian engineering company when new management learned of the sanctions violations, and that the company took remedial steps to establish and implement risk-based controls.
To settle the charges, the company agreed to pay a $453,003 civil monetary penalty.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
