Richland Trace HOA OFAC Civil Penalty: $9K (2012)

Richland Trace used $9,500 of the proceeds from the February 3, 2009, sale of property in which a person designated pursuant to Executive Order 13348, Blocking Property of Certain Persons and Prohibiting the Importation of Certain Goods from Liberia, had an interest, to reimburse itself for past assessments and late fees that had accrued against the property since December 2005. OFAC determined that Richland Trace violated the prohibition against dealing in blocked property set forth in § 593.201 of the Regulations.

OFAC determined that Richland Trace did not voluntarily self-disclose the violation and that the violation constituted a non-egregious case. The base penalty amount was $10,000. The assessed penalty of $9,000 reflects OFAC's consideration of the following facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines: Richland Trace displayed reckless disregard for U.S. sanctions by failing to comply with the conditions of its OFAC license and has no history of prior OFAC violations.

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