Aviation Services Int'l OFAC Settlement: $750K (2010)

The apparent violations involve ASI's unlicensed export and attempted export of goods indirectly from the United States through a third country to Iran in violation of §§ 560.203 and 560.204 of the Iranian Transactions Regulations (ITR), promulgated pursuant to IEEPA and administered by OFAC. The goods included aircraft parts and other items, and the conduct occurred during the period 2005–2007. Administrative charges were filed by both OFAC and the U.S. Department of Commerce's Bureau of Industry and Security arising from the same conduct.

ASI and OFAC agreed to a settlement of $750,000 with respect to ASI's apparent violations of the ITR. OFAC's $750,000 settlement has been deemed satisfied by ASI's acceptance of criminal responsibility and agreement to pay the criminal fine, and by the sanctions imposed by BIS against ASI.

ASI and its principal owners, Robert Kraaipoel and Niels Kraaipoel, each previously pleaded guilty in the U.S. District Court for the District of Columbia to one count of criminal conspiracy to violate IEEPA after a criminal complaint arising from the same conduct was filed by the U.S. Department of Justice. ASI paid a $100,000 criminal penalty pursuant to that guilty plea. In addition, BIS issued an Export Denial Order against ASI prohibiting it from exporting any goods from the United States for a seven-year period.

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