Balli Group OFAC Settlement: $15M (2010)

OFAC alleged that Balli violated §§ 560.203 and 560.204 of the Iranian Transactions Regulations when it exported three commercial airliners from the United States to Mahan Airlines in Iran, and then attempted to export three additional commercial airliners to Mahan.

The $15 million civil penalty is an aggregate settlement among Balli, OFAC, and the U.S. Department of Commerce Bureau of Industry and Security; no separate OFAC-only amount is identified. Two million dollars of that $15 million liability will be suspended and thereafter waived provided Balli remains in compliance with the EAR. Balli cooperated with OFAC's investigation of the apparent violations but did not voluntarily disclose this matter to OFAC.

Concurrently with the OFAC/BIS settlement, Balli Aviation, Ltd. pleaded guilty to a two-count criminal information brought by the U.S. Department of Justice relating to its involvement in the illegal exportation of commercial aircraft from the United States to Iran, and will pay a $2 million criminal fine. Separately, BIS imposed a five-year order denying export privileges to Balli and its representatives, agents, or employees; that denial order was suspended in its entirety provided Balli remains in compliance with the terms of the Settlement Agreement and the EAR.

As part of the Settlement Agreement, Balli agreed to hire an unaffiliated third-party consultant with expertise in U.S. export control laws and sanctions regulations to conduct external audits of Balli's compliance with U.S. export control laws and sanctions regulations.

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