ASF, Inc. OFAC Settlement: $5.4K (2011)

The transaction at issue occurred on or about May 2, 2006. OFAC alleged that ASF engaged in a transaction related to goods destined for Iran and facilitated the exportation of goods from a third country to Iran by a foreign person, without an OFAC license.

OFAC determined that ASF did not voluntarily disclose this matter and that the apparent violation constituted a non-egregious case. The base penalty amount for the alleged violation was $10,000. The settlement amount of $5,400 reflects OFAC's consideration of the following facts and circumstances under the General Factors of the Economic Sanctions Enforcement Guidelines: ASF appears to have lacked an OFAC compliance program at the time of the alleged violation; ASF had knowledge or reason to know the goods were destined for Iran; ASF has not been the subject of an OFAC enforcement action in the five years preceding the transactions at issue; the goods may have been eligible for an OFAC license; and ASF cooperated with OFAC's investigation of this matter, including by agreeing to toll the statute of limitations.

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