Natural Person OFAC Settlement: $29.3K (2014)

From on or about May 21, 2007, to on or about November 12, 2009, the individual exported, sold, and/or supplied unlicensed medical goods and/or related financial services from the United States to Iran, in violation of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560. The alleged violations involved 19 separate transactions, valued at $49,341, in which the individual acted as a third-party recipient for goods destined for Iran and/or provided banking services to a person in Iran.

OFAC determined that the individual did not voluntarily self-disclose the matter to OFAC and that the alleged violations constituted a non-egregious case. The base penalty amount for the alleged violations totaled $163,000. The settlement amount of $29,340 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: the individual demonstrated recklessness by continuing to engage in the conduct after OFAC issued a warning letter for similar past conduct; the individual had not previously received a penalty notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the alleged violations; the goods were medical devices that are potentially licensable by OFAC under existing licensing policy; the individual cooperated with OFAC's investigation and agreed to toll the statute of limitations; and OFAC considered the totality of the circumstances to ensure that the civil monetary penalty is proportionate to the nature of the alleged violations.

The case illustrates that a prior OFAC warning letter for similar conduct is a significant factor in enforcement. Continuing prohibited activity after receiving such a warning is treated as demonstrating recklessness, which weighs in the penalty determination. Cooperation with OFAC's investigation and agreeing to toll the statute of limitations were considered in reducing the settlement amount below the base penalty.

This page summarizes an OFAC enforcement case based on the document archived below. SanctionsLookup assumes no liability for errors, omissions, or inaccuracies in the original documents, this summary, or any changes made to the source documents at any time.

Provided for informational purposes only and does not constitute legal or compliance advice. Always consult the source document directly rather than relying on this summary.