John Bean Technologies OFAC Settlement: $391.9K (2015)

JBT's apparent violations arose from a shipment of goods it sold to a Chinese company that was transported by Islamic Republic of Iran Shipping Lines (IRISL), a blocked entity, aboard a blocked vessel from Spain to China. Three distinct counts were identified under E.O. 13382 and § 544.201(a) of the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544.

First, from on or about April 8 to April 17, 2009, trade documents related to the IRISL shipment were presented to a U.S. bank for payment pursuant to a letter of credit in the amount of $2,897,936. Second, from on or about May 8 to May 19, 2009, after the U.S. bank declined to advise the letter of credit and the trade documents had been returned to JBT pursuant to an OFAC license, JBT presented those same trade documents to Banco Santander, a Spanish bank, in the amount of $2,897,936 to receive payment for the goods sold to CSA. Third, from on or about May 21 to July 9, 2009, JBT reimbursed JBT AeroTech Spain for charges paid to its freight forwarder for shipping services rendered by IRISL, and to Banco Santander for fees associated with negotiating the letter of credit, in the amount of $164,470.24, via inter-company transfer.

OFAC determined that JBT did not voluntarily self-disclose the Apparent Violations and that the Apparent Violations constitute a non-egregious case. The base penalty amount was $670,000. The settlement amount of $391,950 reflects OFAC's consideration of aggravating and mitigating factors pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

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