Dal-Tech Devices, Inc. OFAC Settlement: $10K (2013)

Under its prior ownership and management, Dal-Tech, a distributor of microwave radio frequency devices, apparently violated the Iranian Transactions Regulations by making an unlicensed sale and export of radio frequency measurement devices ("RF devices") to Austria with knowledge that the items were intended for transshipment to Iran. The total value of the RF devices was $3,226. When Dal-Tech learned that the shipment had been returned from Austria without delivery, it re-exported the same goods to Slovenia for transshipment to Iran.

Dal-Tech did not voluntarily disclose this matter to OFAC, and the alleged violations constitute an egregious case. The base penalty amount for Dal-Tech's apparent violations is $500,000. The settlement amount of $10,000 reflects OFAC's consideration of the following facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, App. A: the criminal charges set forth in the DPA reflect knowing and willful conduct by an employee that is attributable to the company; Dal-Tech's prior management at least had reason to know that the company's goods were ultimately destined for Iran; Dal-Tech has not been the subject of any prior OFAC enforcement action; Dal-Tech lacked a sanctions compliance program at the time of the apparent violations; pursuant to the DPA, the company will implement a compliance program that includes sanctions and export compliance training of all employees; the settlement with OFAC is part of a comprehensive settlement with other federal law enforcement agencies; and the enforcement response is proportionate to the nature of the violations, given the totality of the circumstances.

The settlement coincides with a Deferred Prosecution Agreement between Dal-Tech and the United States Attorney's Office for the District of Delaware. The settlement with OFAC is described as part of a comprehensive settlement with other federal law enforcement agencies.

Dal-Tech lacked a sanctions compliance program at the time of the apparent violations. Pursuant to the DPA, the company is required to implement a compliance program that includes sanctions and export compliance training of all employees.

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