ATP Tour, Inc. OFAC Settlement: $48.6K (2013)

OFAC alleged that between on or about May 8, 2007, and on or about July 15, 2010, ATP violated §§ 560.206 and 560.208 of the Iranian Transactions Regulations by approving, facilitating, and in some instances making, 18 salary payments to an individual who is ordinarily resident in Iran, for services rendered and expenses incurred in connection with ATP tournaments the individual officiated.

OFAC determined that ATP did not voluntarily self-disclose its conduct, and the alleged violations constituted a non-egregious case. The base penalty for the alleged violations was $135,000. ATP agreed to pay $48,600 to settle, reflecting OFAC's consideration of General Factors including ATP's reckless disregard for sanctions requirements, its cooperation with the investigation and agreement to toll the statute of limitations, the relatively low harm to the sanctions program, the potential licensability of the transactions under then-existing policies, and ATP's status as a non-profit, member-based organization that implemented an OFAC compliance plan.

ATP continued making salary payments to the individual after receiving a Warning Letter from OFAC on August 11, 2008, regarding transfers connected to individuals in Iran; OFAC cited this as demonstrating reckless disregard for U.S. sanctions requirements. ATP's supervisory and managerial staff were aware of the payments, yet ATP had no OFAC compliance program in place during the violation period. ATP has since implemented an OFAC compliance plan.

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