Life For Relief and Development OFAC Settlement: $780K

LRD appears to have violated §§ 575.210 and 575.211 of the former Iraqi Sanctions Regulations, 31 C.F.R. part 575, between September 9, 2002, and March 19, 2003. LRD knowingly and willfully formed a conspiracy for the purpose of transferring funds from the United States to Iraq, by and through Amman, Jordan, and appears to have made funds transfers pursuant to this conspiracy. OFAC considered three such funds transfers, totaling $236,000, and the formation of the conspiracy itself, in calculating the civil penalty amount.

OFAC determined that LRD did not voluntarily self-disclose the apparent violations, and that the apparent violations constituted an egregious case. The base penalty amount was $1,300,000. The final settlement amount of $780,000 reflects OFAC's consideration of facts and circumstances under the General Factors of OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A. Factors weighing against LRD included that it appears to have willfully violated U.S. economic sanctions regulations; that prior to the relevant transactions LRD had written notice from OFAC that such transfers were prohibited and that OFAC did not authorize such transactions; and that LRD's President knew of the conduct giving rise to the apparent violations and directed the funds transfers to Iraq via Jordan. Factors in LRD's favor included no prior OFAC sanctions history within the five years preceding the earliest transaction, a remedial response and agreement to establish an OFAC compliance program, cooperation by waiving the statute of limitations, and the civil settlement's status as an element of LRD's cooperation agreement with the U.S. Department of Justice.

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.