CMA CGM (America) LLC OFAC Settlement: $374.4K (2011)

OFAC alleged that CCA facilitated the exportation of goods from foreign ports to Sudan on at least two occasions and, in 28 separate transactions, accepted payments for shipping services provided by its foreign parent company, CMA CGM, or its foreign affiliates, in connection with shipments between third countries and Cuba, Iran, or Sudan. The apparent violations occurred between approximately December 2004 and April 2008 and implicated the Cuban Assets Control Regulations, 31 C.F.R. part 515, the Iranian Transactions Regulations, 31 C.F.R. part 560, and the Sudanese Sanctions Regulations, 31 C.F.R. part 538. The transactions involving the alleged violations were valued at approximately $402,265.

OFAC determined that CCA did not voluntarily self-disclose the matter to OFAC and that the alleged violations constituted a non-egregious case. The base penalty amount for the alleged violations totaled $640,000. The settlement amount of $374,400 reflects OFAC's consideration of General Factors under OFAC's Economic Sanctions Enforcement Guidelines.

Given the size and scope of CCA's operations and the nature of its international business, it appears to have lacked an adequate compliance program to avoid U.S. sanctions violations. CCA and CMA CGM undertook remediation to ensure that such alleged violations do not recur. Some of the goods exported from third countries to Cuba and Iran may have qualified as agricultural/medical products under the Trade Sanctions Reform and Export Enhancement Act of 2000 and, thus, may have been eligible for a license.

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