ESCO Corporation OFAC Settlement: $2.1M (2014)

Last updated: July 20, 2026

ESCO Corporation settled potential civil liability for apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515, after its subsidiary purchased nickel briquettes made or derived from Cuban-origin nickel. ESCO agreed to pay $2,057,540 to settle the apparent violations.

Penalty Amount

$2,057,540.00

Enforcement Date

November 13, 2014

Rank in Top Penalties

#81

Case Details

Type:: Entity
Name:: ESCO Corporation
Country:: 🇺🇸 United States
Industry:: Materials & Components
Address:: Portland, Oregon
Penalty amount:: $2,057,540.00
Base civil monetary penalty:: $3,048,208.00
Egregious case:: No
Voluntary self disclosure:: Yes
Case:: Settlement
Violation period:: November 7, 2007 to June 11, 2011
Program:: Cuban Assets Control Regulations, 31 C.F.R. part 515
Enforcement date:: November 13, 2014

Nature of the Apparent Violations

ESCO's subsidiary purchased nickel briquettes made or derived from Cuban-origin nickel between on or about November 7, 2007, and on or about June 11, 2011, in apparent violation of §§ 515.201 and 515.204 of the CACR. The nickel briquettes were ultimately sourced from Specially Designated Nationals. The total transaction value for the apparent violations was $6,188,149.

How OFAC Determined the Penalty

OFAC determined that ESCO voluntarily self-disclosed the apparent violations and that the apparent violations constitute a non-egregious case. The total transaction value was $6,188,149, and the base penalty amount was $3,048,208. The settlement amount of $2,057,540 reflects OFAC's consideration of aggravating and mitigating factors pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Aggravating Factors

ESCO acted with reckless disregard for Cuba sanctions program by failing to identify, despite the presence of contemporaneous "red flags" in the public domain, that the nickel briquettes were made or derived from Cuban-origin nickel
ESCO caused significant harm to the Cuba sanctions program and its policy objectives by conducting large-volume and high-value transactions in products made or derived from Cuban-origin nickel, which were ultimately sourced from Specially Designated Nationals
ESCO is a commercially sophisticated company with international operations

Mitigating Factors

ESCO has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the first transaction giving rise to the apparent violations
ESCO has enhanced its OFAC compliance plan and conducted a thorough look-back
ESCO cooperated with OFAC's investigation, including by executing and extending a statute of limitations tolling agreement

Official Source Documents

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Archived on June 13, 2026

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