American Optisurgical, Inc. OFAC Settlement: $404.1K

From on or about May 17, 2005, to on or about April 15, 2010, AOI violated the ITSR on 36 occasions when it exported, or attempted to export, unlicensed medical goods and services to Iran, or to a person in a third country with knowledge or reason to know that the medical goods and services were intended for supply, transshipment, or reexportation to Iran; and when it engaged in transactions and dealings related to goods and/or services for exportation to Iran. In addition, OFAC alleged that on July 30, 2009, and December 10, 2009, AOI violated the RPPR when it failed to fully respond to two Administrative Subpoenas issued to AOI by OFAC. The alleged violations involved 36 transactions valued at $202,765.

OFAC determined that AOI did not voluntarily self-disclose the matter to OFAC and that the alleged violations constituted a non-egregious case. The base penalty amount for the alleged violations totaled $449,000. The settlement amount of $404,100 reflects OFAC's consideration of facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

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