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Production Products OFAC Settlement: $78.8K (2015)

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Production Products, Inc. settled potential civil liability for two alleged violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544. The company shipped three duct fabrication machines to China National Precision Machinery Import and Export Corp. (CNPM), a Specially Designated National, and received payment in connection with that export without authorization from OFAC. Production Products, Inc. agreed to pay $78,750 to resolve the matter.

Penalty Amount

$78,750.00

Enforcement Date

August 5, 2015

Rank in Top Penalties

#258

Case Details

Type:
Entity
Name:
Production Products, Inc.
Industry:
Machinery & Equipment
Penalty amount:
$78,750.00
Base civil monetary penalty:
$250,000.00
Max civil monetary penalty:
$1,000,000.00
Egregious case:
No
Apparent violations:
2
Voluntary self disclosure:
No
Case:
Settlement
Violation period:
December 15, 2009 to August 18, 2010
Program:
Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544 (the "WMDPSR")
Enforcement date:
August 5, 2015

Nature of the Apparent Violations

From on or about December 15, 2009, to on or about August 18, 2010, PPI shipped three duct fabrication machines, valued at $500,000 total, to China National Precision Machinery Import and Export Corp. (CNPM) and received payment in connection with that export without authorization from OFAC. CNPM is a Specially Designated National. These shipments constitute two alleged violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544.

How OFAC Determined the Penalty

OFAC determined that PPI did not voluntarily self-disclose the alleged violations and that the alleged violations constituted a non-egregious case. The maximum penalty amount was $1,000,000 and the base penalty amount was $250,000. The settlement amount of $78,750 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

  • PPI failed to exercise a minimal degree of caution or care with respect to OFAC sanctions
  • PPI had knowledge that the transaction involved CNPM, a Specially Designated National
  • PPI did not have a sanctions compliance program in place at the time of the transaction
  • The transaction likely provided economic benefit to a Specially Designated National

Mitigating Factors

  • PPI has not received a Penalty Notice or Finding of Violation from OFAC in the five years preceding the date of the transaction giving rise to the alleged violations
  • PPI is a small, family-owned business with only ten employees
  • PPI took remedial steps to implement a sanctions compliance program
  • PPI substantially cooperated with OFAC by responding promptly and completely to OFAC's additional requests for information and documents

Official Source Documents

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Archived on June 13, 2026

SHA-256: e43b3db84c90e6144abf85dd1d2cb8817ac7bf3f7f1149e52b6039639e05ef45

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