Indam International OFAC Settlement: $44.9K (2014)

Last updated: July 20, 2026

Indam International, Inc. settled potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations, agreeing to pay $44,850 after it attempted to export or exported nine shipments of goods from the United States to the United Arab Emirates, with reason to know that the shipments were intended specifically for supply, transshipment, or reexportation to two oil drilling rigs destined for or located in Iranian waters.

Penalty Amount

$44,850.00

Enforcement Date

October 31, 2014

Rank in Top Penalties

#305

Case Details

Type:: Entity
Name:: Indam International, Inc.
Country:: 🇺🇸 United States
Industry:: Trading
Address:: Houston, Texas
Penalty amount:: $44,850.00
Base civil monetary penalty:: $69,000.00
Egregious case:: No
Apparent violations:: 9
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: July 4, 2006 to October 23, 2008
Program:: Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560
Enforcement date:: October 31, 2014

Nature of the Apparent Violations

Between July 4, 2006, and October 23, 2008, Indam attempted to export or exported nine shipments of goods, collectively valued at $27,846, from the United States to the United Arab Emirates, with reason to know that the shipments were intended specifically for supply, transshipment, or reexportation to two oil drilling rigs destined for or located in Iranian waters. The apparent violations involved §§ 560.203, 560.204, and 560.206 of the ITSR.

How OFAC Determined the Penalty

OFAC determined that Indam did not voluntarily self-disclose the apparent violations, and that the apparent violations constitute a non-egregious case. The base penalty amount for the apparent violations was $69,000. After considering aggravating and mitigating factors pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A, OFAC settled for $44,850.

Aggravating Factors

Indam demonstrated reckless disregard for U.S. sanctions requirements by failing to conduct due diligence to determine the end users of its products and thereby avoid the conduct that led to the apparent violations
Indam was aware in 2008 that exporting goods for use on a rig in Iranian waters constituted a violation of the ITSR because U.S. Customs and Border Protection (CBP) had seized an Indam shipment destined for a drilling rig located in Iranian waters in July 2006
Indam's management at least had reason to know of the subject transactions, given their apparent direct involvement in the shipments
The apparent violations aided, or would have aided, the Iranian petroleum industry, resulting in actual or potential harm to the sanctions program objectives
Indam did not implement appropriate policies and procedures to ensure compliance with U.S. sanctions laws prior to engaging in the apparent violations

Mitigating Factors

Indam did not appear to have actual knowledge that the drilling rigs were destined for or located in Iranian waters at the time of the subject transactions (although Indam had reason to know these facts, because the facts were publicly and readily available before and at the time of the apparent violations)
The harm to sanctions program objectives was minimized because CBP detained in the United States five of the nine shipments, accounting for approximately 60 percent of the transactional value of the apparent violations
Indam is a small business
Indam 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
Indam took remedial measures by adopting internal controls and procedures to prevent a recurrence of the apparent violations
Indam cooperated with OFAC, including by agreeing to toll the statute of limitations
Indam forfeited the goods involved in at least four of the nine apparent violations to CBP

Official Source Documents

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Archived on June 13, 2026

SHA-256: e63aaa4873229f7a49ea3ecf1b125294b62a83b66430d56dd58eab6f00f288e9