Atradius Trade Credit OFAC Settlement: $345.3K (2019)

Last updated: July 20, 2026

Atradius Trade Credit Insurance, Inc. settled its potential civil liability for two apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations, agreeing to remit $345,315 to resolve the matter. ATCI, a trade credit insurer and subsidiary of Atradius N.V., did not make a voluntary self-disclosure of the apparent violations, and OFAC determined that the apparent violations constituted a non-egregious case.

Penalty Amount

$345,315.00

Enforcement Date

August 16, 2019

Rank in Top Penalties

#164

Case Details

Type:: Entity
Name:: Atradius Trade Credit Insurance, Inc.
Country:: 🇺🇸 United States
Industry:: Insurance
Address:: Hunt Valley, Maryland
Penalty amount:: $345,315.00
Base civil monetary penalty:: $590,282.00
Egregious case:: No
Apparent violations:: 2
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: October 19, 2016 to June 20, 2017
Program:: Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. Part 598
Enforcement date:: August 16, 2019

Nature of the Apparent Violations

ATCI's two apparent violations arise from transactions involving Grupo Wisa, S.A., which OFAC designated on May 5, 2016 pursuant to the Foreign Narcotics Kingpin Designation Act, 21 U.S.C. §§ 1901–1908, and added to the SDN List. On October 19, 2016, approximately five months after Grupo Wisa's designation, a cosmetics company located in the United States assigned to ATCI the right to collect on a $5,730,680.33 debt owed by Grupo Wisa. ATCI subsequently filed a claim in Panama as a creditor in the liquidation of Grupo Wisa, and on June 20, 2017, ATCI received a payment of $4,043,174.25 from the liquidation of Grupo Wisa's assets in Panama. By accepting the assignment of the Grupo Wisa debt, and by receiving the payment from the Grupo Wisa liquidation, ATCI appears to have dealt in property or interests in property of a specially designated narcotics trafficker in violation of 31 C.F.R. § 598.203(a).

How OFAC Determined the Penalty

OFAC determined that ATCI did not make a voluntary self-disclosure and that the apparent violations constitute a non-egregious case. The total base penalty amount for the two apparent violations was $590,282. The settlement amount of $345,315 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

ATCI did not undertake any meaningful analysis or otherwise seek confirmation from OFAC that assignment of the SDN's debt and acceptance of payment from the Soho Mall Trust was permissible under existing authorizations
ATCI is a subsidiary of a sophisticated global trade credit insurance and collections conglomerate

Mitigating Factors

ATCI has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the Apparent Violations
ATCI voluntarily conducted a full internal review of the underlying facts and circumstances, provided documents from its internal review to OFAC in the course of the investigation, and took voluntary remedial action to address the cause of the Apparent Violations
ATCI agreed to undertake certain compliance commitments to ensure that its OFAC sanctions compliance program remains strong over the next several years

Compliance Takeaways

This enforcement action draws particular attention to transactions related to the assignment of an SDN's debt and highlights the importance of obtaining a specific license before engaging in activity that is not otherwise authorized.

Official Source Documents

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Archived on June 13, 2026

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