Brasseler USA OFAC Settlement: $18.9K (2012)

On or about February 24, 2006, January 21, 2009, and March 20, 2009, Brasseler exported goods or services to a person in a third country with knowledge or reason to know that such goods or services were intended specifically for transshipment to Iran, without authorization from OFAC. The three alleged violations involved transactions valued at $5,241 and constituted violations of the Iranian Transactions Regulations, 31 C.F.R. part 560.

OFAC determined that Brasseler did not voluntarily self-disclose the matter and that the alleged violations constituted a non-egregious case. The base penalty amount for the alleged violations totaled $21,000. The settlement amount of $18,900 reflects OFAC's consideration of the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, App. A.

The settlement reflects several compliance-relevant considerations. Brasseler's conduct demonstrated reckless disregard for U.S. sanctions requirements and involved a pattern of concealment whereby the company masked the identities of its Iranian customers. Management level staff were involved with, and/or were aware of, both the reckless conduct and the fact that the goods or services were destined for Iran. Brasseler did not have a compliance program in place at the time of the alleged violations. OFAC also noted that the exports at issue likely would have been licensed under existing licensing policy, indicating that authorization was available had the company sought it.

This page summarizes an OFAC enforcement case based on the document archived below. SanctionsLookup assumes no liability for errors, omissions, or inaccuracies in the original documents, this summary, or any changes made to the source documents at any time.

Provided for informational purposes only and does not constitute legal or compliance advice. Always consult the source document directly rather than relying on this summary.