Norton Lilly International OFAC Civil Penalty: $18.8K

The violation occurred in November 2006, when Norton engaged in a transaction or dealing related to services of Iranian origin and facilitated a transaction by a foreign person involving Iranian-origin services. Norton acted as a paying agent for a foreign entity to pay port charges incurred at an Iranian port in the amount of $14,936.

OFAC determined that Norton did not voluntarily self-disclose the violation and that the violation constituted a non-egregious case. The base penalty amount was $25,000. OFAC assessed a penalty of $18,750 after considering General Factors under OFAC's Economic Sanctions Enforcement Guidelines: Norton had knowledge or reason to know that the conduct involved port charges with respect to a ship calling in Iran; Norton did not have a compliance program in place at the time of the violation; Norton cooperated with OFAC by promptly responding to OFAC's administrative subpoena and providing all relevant information regarding the violation; Norton instituted remedial measures by adopting procedures to comply with OFAC's regulations; and Norton had not been subject to an OFAC enforcement action in the five years preceding the date of the violation.

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