Blue Robin, Inc. OFAC Civil Penalty: $82.3K (2015)

Last updated: July 20, 2026

Blue Robin, Inc. was assessed an $82,260 penalty by the Office of Foreign Assets Control for apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560. The violations arose from Blue Robin's importation of Web development services from an Iranian company between January 2009 and July 2010.

Penalty Amount

$82,260.00

Enforcement Date

July 29, 2015

Rank in Top Penalties

#257

Case Details

Type:: Entity
Name:: Blue Robin, Inc.
Industry:: Software
Penalty amount:: $82,260.00
Base civil monetary penalty:: $102,825.00
Max civil monetary penalty:: $8,250,000.00
Egregious case:: No
Voluntary self disclosure:: Yes
Case:: Penalty
Violation period:: January 14, 2009 to July 19, 2010
Program:: Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560
Enforcement date:: July 29, 2015

Nature of the Apparent Violations

From on or about January 14, 2009, to on or about July 19, 2010, Blue Robin violated § 560.201 of the ITSR when it conducted 33 transactions in which it imported Web development services valued at $205,650 from an Iranian company called PersiaBME. PersiaBME worked collaboratively with Blue Robin's computer engineers via a private Internet portal provided by Blue Robin to develop Web-based systems and applications that were used to automate online business processes and operations for Blue Robin's customers. Blue Robin also continued to receive services from PersiaBME in the form of technical assistance after it became aware that it had violated the ITSR; this technical assistance was not covered by the informational material exemption in § 560.210(c) of the ITSR.

How OFAC Determined the Penalty

OFAC determined that Blue Robin voluntarily self-disclosed the violations and that the violations constituted a non-egregious case. The total transaction value of the violations was $205,650. The statutory maximum civil monetary penalty for the alleged violations was $8,250,000 and the base penalty amount for the violations was $102,825. The final assessed penalty was $82,260.

Aggravating Factors

Blue Robin acted recklessly by conducting transactions over a period of more than five years with a company that it knew was located in Iran, without inquiring about the permissibility of those transactions
At least one co-owner and manager of Blue Robin knew that Blue Robin was conducting transactions with an Iranian company
The apparent violations resulted in $205,650 in economic benefit to an Iranian company
Blue Robin continued to receive services from PersiaBME in the form of technical assistance after Blue Robin became aware that it had violated the ITSR and this technical assistance was not covered by the informational material exemption in § 560.210(c) of the ITSR
Blue Robin had no OFAC compliance program in place at the time of the transactions and has not implemented one since
Blue Robin engaged in a limited remedial response to the apparent violations

Mitigating Factors

Blue Robin has no prior OFAC sanctions history, including no penalty notice or Finding of Violation in the five years preceding the date of the earliest transaction giving rise to the apparent violations
Blue Robin is a small business that claims to be suffering financial difficulties
Blue Robin substantially cooperated with OFAC's investigation, including by agreeing to toll the statute of limitations for 541 days

Official Source Documents

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Archived on June 13, 2026

SHA-256: 7402502aaeb282ebe3fc399d1cea7dfd5ca8f154191bbe4f6083d2010f1e7d2d