Great Plains Stainless OFAC Settlement: $214K (2015)

GPS's alleged violations involved two counts arising from a shipment of goods from Shanghai, China, to GPS's customer in Dubai, United Arab Emirates. For Count 1, GPS sold goods that its Chinese vendor shipped from Shanghai aboard the vessel MN Sahand, a vessel identified as blocked property on September 10, 2008 pursuant to E.O. 13382. For Count 2, GPS engaged in transactions that appear to have been intended to evade or avoid the prohibitions in the WMDPSR: the company requested the creation of new trade documents with references to the blocked vessel removed, then transferred the altered documents to its customer to facilitate the release of goods held at port in Dubai. The alleged violations occurred from on or about April 9, 2009 to on or about July 4, 2009.

This matter was not voluntarily self-disclosed to OFAC, and the alleged violations constitute a non-egregious case. The statutory maximum penalty amount was $500,000 and the base penalty amount was $340,000. The settlement amount of $214,000 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: with respect to Count 2, GPS appears to have acted willfully by obtaining an altered bill of lading that concealed the involvement of a blocked vessel, and by disregarding verbal and written guidance from OFAC stating that GPS should consult with OFAC's Licensing Division before engaging in additional transactions involving the shipping documents; GPS was aware that the conduct giving rise to certain alleged violations was prohibited without an OFAC license, given that GPS submitted a license application to OFAC seeking authorization for the same conduct; GPS did not have a compliance program in place at the time of the alleged violations; GPS has not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the first transaction; GPS had no reason to know that a blocked vessel was to be used for the shipment until the vessel's sailing date; GPS is a small company; and GPS took remedial measures to prevent a recurrence of the alleged violations.

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