Natoli Engineering OFAC Settlement: $52.9K (2012)

Between November 2008 and January 2010, Natoli sold various products to Productos Farmaceuticos Collins, S.A. de C.V. ("Productos Farmaceuticos"), an entity on the Specially Designated Nationals and Blocked Persons List, and attempted to reimburse Productos Farmaceuticos for overpayments it had previously made to Natoli.

This matter was not voluntarily disclosed to OFAC and the alleged violations constitute a non-egregious case. The base penalty amount for the alleged violations was $98,000. The settlement amount of $52,920 reflects OFAC's consideration of facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 601, App. A, including that Natoli has no history of prior OFAC violations and that Natoli cooperated with OFAC's investigation.

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