GAC Shipping OFAC Settlement: $157.5K (2014)

GAC supplied bunker fuel in Paranagua, Brazil for an Iranian vessel carrying an agricultural commodity, which OFAC alleged was a violation of § 560.206 of the ITSR. The transaction occurred in November 2008 and was valued at $513,141.

GAC did not make a voluntary self-disclosure. OFAC determined that the alleged violation did not constitute an egregious case. The maximum statutory penalty amount was $1,026,283, and the base penalty amount was $250,000. The settlement amount of $157,500 reflects OFAC's consideration of the following General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A: GAC had prior notice that supplying bunker fuel to Iranian vessels could be in violation of the ITSR; GAC Bunker Fuels (USA) LLC was a small entity; GAC has not received a penalty notice of Finding of Violation from OFAC in the five years preceding the date of the transaction giving rise to the alleged violation; and GAC cooperated with the investigation by agreeing to toll the statute of limitations.

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