Network Hardware Resale LLC OFAC Settlement: $64.8K

Between approximately April 14, 2008, and January 6, 2011, NHR exported 16 shipments of networking equipment and related accessories from the United States to Sudan, in apparent violation of the Sudanese Sanctions Regulations, 31 C.F.R. part 538, and two shipments of networking equipment and related accessories from the United States destined for Iran, in apparent violation of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560. The apparent violations totaled 18 transactions over the course of almost three years.

OFAC determined that NHR voluntarily self-disclosed this matter and that the apparent violations constitute a non-egregious case. The base penalty amount for the apparent violations was $143,906. The settlement amount of $64,758 reflects OFAC's consideration of the general factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

NHR demonstrated reckless disregard for U.S. sanctions requirements by engaging in worldwide commerce without implementing even basic OFAC compliance measures prior to discovering the apparent violations. In determining the settlement amount, OFAC considered NHR's voluntary self-disclosure, prompt corrective action, and cooperation during the investigation, including entry into a statute of limitations tolling agreement.

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