Online Micro, LLC OFAC Settlement: $1.1M (2012)

Online and the Owner made unlicensed exports of computer-related goods indirectly from the United States through Dubai, United Arab Emirates, to Iran between 2009 and 2010, in apparent violation of § 560.204 of the Iranian Transactions Regulations, 31 C.F.R. part 560.

Online and the Owner did not voluntarily disclose the apparent violations to OFAC. OFAC considers the apparent violations to be egregious. Online, the Owner, and OFAC agreed to a settlement in the amount of $1,054,388. This settlement has been deemed satisfied by Online's and the Owner's acceptance of criminal responsibility, the criminal forfeiture of assets, and the restrictions imposed by BIS; no direct payment to OFAC was required.

Online and the Owner each pleaded guilty in the U.S. District Court for the District of Columbia to one count of criminal conspiracy to violate IEEPA and the ITR, following an indictment filed by the U.S. Department of Justice arising from the same conduct. Online and the Owner also agreed to forfeiture of a money judgment in the amount of $1,899,964. Separately, the U.S. Department of Commerce's Bureau of Industry and Security imposed Export Denial Orders on Online and the Owner prohibiting them from exporting any goods from the United States for a ten-year period. The BIS Export Denial Orders were suspended in their entirety provided Online and the Owner remain in compliance with the terms of their Settlement Agreements with BIS and with the Export Administration Regulations.

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