Aegis Electronic Group OFAC Settlement: $20K (2011)

Aegis, a U.S. distributor of industrial imaging products including cameras, monitors, and related control units, violated the Iranian Transactions Regulations, 31 C.F.R. part 560 (ITR), by its unlicensed sale and export of camera control units to Austria with knowledge that the items were intended for re-export to Iran. During August 2008 through January 2009, Aegis exported two camera control units from the United States to Austria for re-export to Iran. The total transaction value of the exported camera control units was $2,685. Aegis did not voluntarily disclose this matter to OFAC.

Aegis did not voluntarily disclose the apparent violations to OFAC. The base penalty amount was $10,000, the Applicable Schedule Amount established by OFAC's Economic Sanctions Enforcement Guidelines, 74 Fed. Reg. 57,593 (Nov. 9, 2009). OFAC adjusted the base amount upward to $20,000 to reflect applicable General Factors, including that the criminal charges set forth in the Deferred Prosecution Agreement reflect knowing and willful conduct by an employee attributable to the company, that there is no indication Aegis' senior management participated in the apparent violations, and that Aegis lacked a sanctions compliance program at the time of the apparent violations but has since implemented one.

The OFAC settlement is related to a Deferred Prosecution Agreement reached by Aegis and the Office of the United States Attorney for the District of Delaware. The criminal investigation was initiated by the U.S. Immigration and Customs Enforcement, Office of Investigations in Philadelphia, PA. The criminal charges set forth in the Deferred Prosecution Agreement reflect knowing and willful conduct by an employee that is attributable to the company.

Aegis lacked a sanctions compliance program at the time of the apparent violations. Following the enforcement action, it implemented a compliance program requiring sanctions and export compliance training of all employees. OFAC noted that the knowing and willful conduct of an employee was attributable to the company, and that there was no indication Aegis' senior management participated in the apparent violations.

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