Custom Polymers, Inc. OFAC Settlement: $57.8K (2010)

OFAC alleged that CPI attempted to make a payment involving Sudan, on behalf of its affiliate, without an OFAC license. The payment, which amounted to $116,250, was allegedly for the purchase and export of bottle regrind from Sudan, occurring on or about August 17, 2007.

CPI did not voluntarily disclose this matter to OFAC, and OFAC determined the alleged violation constituted a non-egregious case. The base penalty amount for the violation totaled $170,000. The settlement amount of $57,800 reflects OFAC's consideration of several General Factors: CPI had no history of sanctions violations; CPI entered into the underlying contract with its supplier without knowledge or reason to know the goods were from Sudan; CPI immediately ceased all business activities with its supplier in order to avoid future U.S. sanctions violations; and CPI implemented a sanctions compliance program.

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