Essie Cosmetics Ltd. OFAC Settlement: $450K (2012)

Essie and a former individual corporate officer knowingly sold and exported nail care products to an Iranian distributor on three occasions: on or about September 17, 2009, December 8, 2009, and February 23, 2010. The sales were made pursuant to an Exclusive Distributorship Agreement, in apparent violation of § 560.204 of the ITR. The total transaction value for the three transactions settled with OFAC was $33,299. OFAC determined that the apparent violations constituted an egregious case in light of Essie and Individual's intentional efforts to evade sanctions.

OFAC determined that Essie and the Individual did not voluntarily self-disclose the apparent violations and that the apparent violations constituted an egregious case. The base penalty was $750,000. Essie, the Individual, and OFAC agreed to a settlement in the amount of $450,000. OFAC also considered that Essie and the Individual have no history of prior OFAC violations. OFAC has considered $200,000 of its total settlement amount satisfied by Essie and Individual's agreement with the United States Attorney's Office for the Southern District of New York and by the $200,000 administrative forfeiture by the Department of Homeland Security.

Essie and the Individual cooperated with an investigation by U.S. Immigration and Customs Enforcement and entered into Non-Prosecution Agreements with the United States Attorney's Office for the Southern District of New York related to their violations of IEEPA. Pursuant to those agreements, they agreed to the civil forfeiture of $200,000 by the Department of Homeland Security. OFAC considered $200,000 of its $450,000 settlement amount satisfied by this agreement and the resulting administrative forfeiture.

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