Finans Kiymetli Madenler OFAC Civil Penalty: $750K

From on or about February 21, 2012, to on or about May 29, 2012, Finans originated at least three electronic funds transfers, totaling $257,808, processed through financial institutions located in the United States for the benefit of the Government of Iran and/or persons in Iran. Two of those transactions were blocked by the U.S. financial institution. OFAC determined that Finans violated the prohibition against the exportation of services, directly or indirectly, from the United States to Iran or the Government of Iran set forth in § 560.204 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560.

OFAC determined that Finans did not voluntarily self-disclose the violations and that the violations constituted an egregious case. The base penalty amount was $750,000. Finans has not received a Penalty Notice or Finding of Violation from OFAC in the five years preceding the date of the transactions giving rise to the violations. The assessed penalty of $750,000 reflects OFAC's consideration of the facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Finans does not appear to have had an OFAC compliance program and did not cooperate with OFAC during the course of its investigation. OFAC noted that a civil monetary penalty will have a compliance/deterrence effect by encouraging greater due diligence by foreign financial institutions that maintain accounts for third-country trading companies.

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