PanAmerican Seed Company OFAC Settlement: $4.3M (2016)

Last updated: July 20, 2026

PanAmerican Seed Company, a division of Ball Horticultural Company, settled potential civil liability for alleged violations of the Iranian Transactions and Sanctions Regulations by indirectly exporting seeds, primarily of flowers, to two Iranian distributors on 48 occasions between on or about May 5, 2009 and on or about March 2, 2012. PanAm Seed agreed to pay $4,320,000 to settle the alleged violations.

Penalty Amount

$4,320,000.00

Enforcement Date

September 13, 2016

Rank in Top Penalties

#59

Case Details

Type:: Entity
Name:: PanAmerican Seed Company
Country:: 🇺🇸 United States
Industry:: Agriculture
Address:: West Chicago, Illinois
Penalty amount:: $4,320,000.00
Base civil monetary penalty:: $12,000,000.00
Max civil monetary penalty:: $12,000,000.00
Egregious case:: Yes
Apparent violations:: 48
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: May 5, 2009 to March 2, 2012
Program:: Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR)
Enforcement date:: September 13, 2016

Nature of the Apparent Violations

From on or about May 5, 2009 to on or about March 2, 2012, PanAm Seed violated § 560.204 of the ITSR by indirectly exporting seeds, primarily of flowers, to two Iranian distributors on 48 occasions. PanAm Seed shipped the seeds to consignees based in two third countries located in Europe or the Middle East, and PanAm Seed's customers arranged for the re-exportation of the seeds to Iran.

Personnel, including several mid-level managers from various business units within PanAm Seed and/or Ball Horticultural, were aware of U.S. economic sanctions programs involving Iran and the need to apply for and obtain a specific license from OFAC in order to export the seeds in question. Despite this knowledge, PanAm Seed engaged in a pattern or practice designed to conceal the involvement of Iran and/or obfuscated the fact that the seeds were ultimately destined for distributors located in Iran. PanAm Seed continued sales to its Iranian distributors for nearly eight months after its Director of Finance learned of OFAC's investigation, providing over $770,000 in economic benefit to Iran.

How OFAC Determined the Penalty

OFAC determined that PanAm Seed did not voluntarily self-disclose the Alleged Violations to OFAC, and that the Alleged Violations constitute an egregious case. Both the statutory maximum and base civil monetary penalty amounts for the Alleged Violations were $12,000,000. The settlement amount of $4,320,000 reflects OFAC's consideration of the facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Aggravating Factors

PanAm Seed willfully violated U.S. sanctions on Iran by engaging in, and systematically obfuscating, conduct it knew to be prohibited
PanAm Seed demonstrated recklessness with respect to U.S. sanctions requirements by ignoring its OFAC compliance responsibilities, despite substantial international sales and warnings that OFAC sanctions could be implicated
Multiple PanAm Seed and Ball Horticultural employees, including mid-level managers, had contemporaneous knowledge of the transactions giving rise to the Alleged Violations and that the seeds were intended for reexportation to Iran, and PanAm Seed continued sales to its Iranian distributors for nearly eight months after its Director of Finance learned of OFAC's investigation
PanAm Seed engaged in this pattern of conduct over a period of years, providing over $770,000 in economic benefit to Iran
PanAm Seed did not initially cooperate with OFAC's investigation, providing some information that was inaccurate, misleading, or incomplete
PanAm Seed is a division of Ball Horticultural, a commercially sophisticated, international corporation

Mitigating Factors

PanAm Seed has not received a Penalty Notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the Alleged Violations, making it eligible for "first offense" mitigation of up to 25 percent
The exports at issue were likely eligible for an OFAC license under the Trade Sanctions Reform and Export Enhancement Act of 2000
PanAm Seed took remedial steps to ensure future compliance with OFAC sanctions, including stopping all exports to Iran, implementing a compliance program, and training at least some of its employees on OFAC sanctions
PanAm Seed cooperated with OFAC by agreeing to toll the statute of limitations for a total of 882 days

Official Source Documents

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Archived on June 13, 2026

SHA-256: 8158090456e7c9a6d6207d2015fa68f5228a06e2eb99277d686407975f01d865