Maritech Commercial Inc. OFAC Settlement: $20.8K (2013)

Between on or about April 20, 2009, and on or about June 14, 2010, Maritech provided fuel inspection services, valued at $9,868, on board five vessels affiliated with the Islamic Republic of Iran Shipping Lines ("IRISL") that had been identified by OFAC as blocked property and placed on the SDN List. IRISL, which is known to engage in deceptive practices in an attempt to evade sanctions, had changed the names of four of the five vessels prior to the alleged violations; however, the vessels remained identifiable by their IMO numbers, which are unique identifiers assigned to vessels of a certain size and nature when constructed, and are permanently and visibly marked on them. At the time of the transactions, Maritech was not screening the names or IMO numbers of any of the vessels to which it provided services against the SDN List.

OFAC determined that Maritech did not voluntarily self-disclose its conduct, and the alleged violations constituted a non-egregious case. The base penalty for the alleged violations was $32,000. The settlement amount of $20,800 reflects OFAC's consideration of the General Factors Affecting Administrative Action listed in OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501 app. A. Factors considered included that Maritech had no sanctions compliance program at the time of the alleged violations; acted with reckless disregard for U.S. economic sanctions by failing to screen parties involved in its business transactions; conferred an economic or other benefit on a sanctioned entity; had no prior OFAC sanctions enforcement history; subsequently instituted a system to screen against the SDN List; and is a small company.

At the time of the alleged violations, Maritech had no sanctions compliance program and was not screening the names or IMO numbers of vessels against the SDN List. IRISL is known to engage in deceptive practices by changing vessel names to evade sanctions; however, IMO numbers are unique identifiers permanently assigned when a vessel is constructed and visibly marked on the vessel, and they do not change. Screening by IMO number, in addition to vessel name, is therefore necessary to identify blocked vessels that have been renamed. Maritech's subsequent implementation of an SDN screening system was considered by OFAC in determining the settlement amount.

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