DPWN & DHL Express OFAC Settlement: $9.4M (2009)

OFAC alleged that between August 2002 and March 2007, DHL made numerous shipments to Iran and Sudan in violation of the Iranian Transactions Regulations, the Sudanese Sanctions Regulations, and the Reporting, Procedures and Penalties Regulations, and that the company failed to maintain records with respect to other shipments to those countries. BIS alleged that between June 2004 and September 2004, DHL made certain unlicensed exports to Syria in violation of the Export Administration Regulations (EAR), and that in connection with a number of other exports to Syria, DHL failed to retain airway bills and other export control documents in violation of the EAR.

DHL did not voluntarily disclose this matter to OFAC or BIS. The $9,444,744 settlement is an aggregate amount covering allegations under both the OFAC Regulations and the EAR, settled jointly with OFAC and the Department of Commerce's Bureau of Industry and Security. This matter was resolved according to the prior enforcement guidelines published by OFAC at 68 Fed. Reg. 4422.

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