Offshore Marine Laboratories OFAC Settlement: $97.7K

Between July 11, 2007, and July 17, 2008, OML exported to a company in the United Arab Emirates eight shipments of spare parts and supplies intended for supply to an offshore oil drilling rig located in Iranian waters. Both the rig owner and operator were located in Iran. Five of the eight shipments occurred after the rig owner's property and interests in property were blocked pursuant to E.O. 13382.

This matter was not voluntarily disclosed to OFAC and the alleged violations constitute a non-egregious case. The base penalty amount was $167,000. The settlement amount of $97,695 reflects OFAC's consideration of the following facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, App. A: OML harmed sanctions program objectives because the transactions aided the development of Iranian petroleum resources; OML had no OFAC compliance program in place at the time of the alleged violations; OML has no history of prior OFAC violations; OML demonstrated substantial cooperation with OFAC throughout the investigation, including entering into a statute of limitations tolling agreement; and OML took remedial measures by implementing an OFAC compliance program.

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