American Export Lines OFAC Settlement: $518.1K (2017)

Last updated: July 20, 2026

Blue Sky Blue Sea, Inc., doing business as American Export Lines and International Shipping Company (USA), agreed to pay $518,063 to settle potential civil liability for 140 apparent violations of the Iranian Transactions and Sanctions Regulations by transshipping used and junked cars and parts from the United States via Iran to Afghanistan.

Penalty Amount

$518,063.00

Enforcement Date

August 17, 2017

Rank in Top Penalties

#132

Case Details

Type:: Entity
Name:: Blue Sky Blue Sea, Inc., doing business as American Export Lines and International Shipping Company (USA)
Country:: 🇺🇸 United States
Industry:: Logistics
Address:: Los Angeles, California
Penalty amount:: $518,063.00
Base civil monetary penalty:: $1,535,000.00
Max civil monetary penalty:: $35,000,000.00
Egregious case:: No
Apparent violations:: 140
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: April 25, 2010 to June 2, 2012
Program:: Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR)
Enforcement date:: August 17, 2017

Nature of the Apparent Violations

From on or about April 25, 2010 to on or about June 2, 2012, AEL appears to have violated § 560.204 of the ITSR by transshipping used and junked cars and parts from the United States via Iran to Afghanistan on 140 occasions.

How OFAC Determined the Penalty

OFAC determined that AEL did not voluntarily self-disclose the apparent violations to OFAC, and that the apparent violations constitute a non-egregious case. The maximum statutory civil monetary penalty amount for the apparent violations was $35,000,000, and the base civil monetary penalty amount was $1,535,000. The civil monetary penalty amount of $518,063 reflects OFAC's consideration of the facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. Part 501, app. A.

Aggravating Factors

AEL demonstrated a reckless disregard for U.S. sanctions requirements by failing to exercise a minimal degree of caution or care in transshipping goods through Iran.
AEL's President and co-owner knew and approved of the transshipments via Iran.
AEL provided an economic benefit to Iran through its pattern of conduct and the volume of transactions in which it engaged.
AEL is a sophisticated international full-service freight forwarder with experience with U.S. export laws and OFAC regulations, particularly the ITSR.

Mitigating Factors

The goods were transshipped through Iran and do not appear to have had an end use in Iran.
AEL has no prior OFAC sanctions history and has not received a Penalty Notice or Finding of Violation in the five years preceding the earliest date of transactions giving rise to the apparent violations, making it eligible for "first violation" mitigation of up to 25 percent.
AEL is a small business, and the apparent violations at issue constituted less than one percent of its total shipments during the time period in which the apparent violations occurred.
AEL had an OFAC compliance program in place at the time of the violations, although it was silent on transshipments via Iran.
AEL took remedial steps, including ceasing transshipments via Iran before the inception of OFAC's investigation and amending its compliance policy to address the conduct at issue.
AEL cooperated with OFAC's investigation, including by agreeing to toll the statute of limitations for a total of 804 days.

Official Source Documents

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Archived on June 13, 2026

SHA-256: 0bc1949cea09b4c715748c6e02186acf83c3b1252de6317b90946a01c8ee758f