EGL, Inc. OFAC Settlement: $139.7K (2013)

The alleged violations of the CACR occurred from on or about April 19, 2005, to on or about December 15, 2008, when EGL's foreign affiliates engaged in 280 transactions in which they provided freight forwarding services with respect to shipments to and from Cuba. The alleged violations of the ITSR occurred from on or about August 15, 2008, to on or about October 27, 2008, when affiliates of EGL (then part of the CEVA Logistics group) acted as the freight forwarder of ten shipments containing oil rig supplies to Aban VIII, an oil drilling rig located in Iranian coastal waters and operated by Petropars, an affiliated company of the National Iranian Oil Company.

EGL made a voluntary self-disclosure of the alleged violations of the CACR, but did not make a voluntary self-disclosure of the alleged violations of the ITSR. The alleged violations constitute a non-egregious case. The base penalty amount was $206,889, and the settlement amount of $139,650 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: EGL has no history of prior sanctions violations; EGL substantially cooperated with OFAC's investigation, including by entering into statute of limitations tolling agreements and by producing responsive materials in a clear and organized fashion; EGL took remedial measures to prevent future OFAC violations; the alleged violations of the CACR and the ITSR by EGL resulted in significant harm to OFAC's sanctions programs; and EGL had reason to know that the Aban VIII was an oil rig operated by an Iranian company in Iranian waters.

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